The privacy of your personal information is very important to us. This Data Privacy Notice explains how we (the data controllers identified below) process your personal information. It also describes your data protection rights, including a right to object to some of the processing which we carry out.
\nIn relation to any information we collect about you and any information we process in relation to prospective clients the data controller is Tilney Smith & Williamson Limited. Tilney Investment Management Services Limited is the controller for any information we collect about you on our website. To the extent we provide products or services to you, the data controller is the Tilney Smith & Williamson Limited entity which provides these products or services to you under the applicable Terms of Business, unless we inform you otherwise. Where we communicate with you, in particular to offer services or pre-contractually, the data controller is the Tilney Smith & Williamson Limited entity named in the communications.
\nWe process personal information about you that you provide when you engage with us, including:
\nWe receive information from:
\nInformation we process about you includes:
\nWe use the personal information about you for a number of reasons:
\nWhere necessary to perform a contract with you
\nWhere necessary to comply with a legal obligation
\nWhere it is in our or a third party’s legitimate interests, as listed below, and where these interests are not overridden by your fundamental rights and freedoms
\nYou have the right to object to processing where it is in our or a third party’s legitimate interests by contacting us at: The Data Protection Officer, Tilney, The Observatory, Western Road, Bracknell, Berkshire RG12 1TL or by email: ask.dataprotection@tilney.co.uk.
\nWith your consent
\nYou have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing that we carried out before your withdrawal. If you choose to withdraw your consent, we may not be able to provide you with certain products and services.
\nWe use cookies and similar technologies on our websites and in our emails. These technologies do many different things, such as letting you navigate between web pages efficiently and remembering your preferences. In emails they help us to understand whether you have opened the email and how you have interacted with it.
\nPlease refer to our Cookie Policy for further details on these technologies, how and where we use them and how you can control them.
\nWe share your personal information with:
\nYour personal information may be transferred to or accessed from other countries (including those outside the European Economic Area) and processed for us in those countries on the basis that we will ensure that appropriate measures are in place to ensure that anyone we pass it to will provide a level of protection equivalent to United Kingdom and European data protection law.
\nSuch information could be accessed by local law enforcement agencies and other authorities to prevent and detect crime and comply with legal obligations. For further details as to where your personal information is transferred, please contact us using the details at the end of this Data Privacy Notice.
\nWe will take appropriate steps to both store and send the information you provide us with securely and employees are trained on and are aware of their responsibility to maintain your privacy.
\nWe only hold your personal information for as long as we require it to provide you with the services you have asked for or for as long as we are legally required under various business and financial laws. This includes:
\nOnce we no longer need your personal information, we securely destroy it.
\nThis section explains your rights under data protection law with respect of your personal information. If you wish to request to exercise any of these rights or if you would like further information about them, you can contact us using the details set out in the ‘How to Contact Us’ section below. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection law. Your rights may be limited, for example if fulfilling your request would unfairly reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
\nYou have the right to ask for a copy of the personal information we hold about you in a written format, free of charge.
\nYou also have the right, at no cost, to require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information.
\nIn some cases, you have the right to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.
\nYou have the right to object to the processing of your personal information in certain circumstances.
\nYou have the right to have the personal information we hold about you erased in certain circumstances unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations.
\nYou have certain rights to obtain and reuse your personal information for your own purposes across different organisations for example, if you wish to move to a new financial services provider. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely, without affecting its usability.
\nYou have the right to lodge a complaint about how we collect, process and store your personal information with the supervisory authority:
\nYou may also contact our data protection officer:
\nThis section explains the rights you have under DP Law with respect to how your personal information is held and used by us. If you wish to request to exercise any of these rights or if you would like further information about them, you can contact us using the details set out in the ‘How to Contact Us’ section below. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under DP Law.
\nYou have the right to withdraw your consent to us processing special categories of your personal information at any time. This will not affect the lawfulness of any processing of these special categories of your personal information that we carried out before your withdrawal. If you choose to withdraw your consent to us processing these special categories of your personal information, we may not be able to provide you with certain products and services.
\nYou have the right to ask for a copy of the personal information we hold about you in a written format, free of charge.
\nYou also have the right, at no cost, to require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information. In order for us to do so, you must inform us of any changes to your personal information so that we can keep it up to date.
\nIn some cases, you have the right to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.
\nYou have the right to have the personal information we hold about you erased in certain circumstances unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations. We may not be able to provide our products and services to you if you ask us to erase your personal information.
\nYou have certain rights to obtain and reuse your personal information for your own purposes across different organisations for example, if you wish to move to a new financial services provider. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely, without affecting its usability.
\nFinally you have the right to lodge a complaint about how we collect, process and store your personal data, with us in writing to this address:
\nThe Data Protection Officer, Tilney, The Observatory, Western Road, Bracknell, Berkshire, RG12 1TL
\nas well as with the supervisory authority:
\nInformation Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
\nWe keep our Data Privacy Notice under regular review and we will update this document from time to time. This Data Privacy Notice was last updated November 2018.
\nTo discuss anything in this notice please write to: The Data Protection Officer, Tilney, The Observatory, Western Road, Bracknell, Berkshire RG12 1TL. Alternatively you may contact us by email: ask.dataprotection@tilney.co.uk.
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