Privacy Notice

GRANGE FINANCIAL [SUSSEX] LIMITED

PRIVACY POLICY

WHO ARE WE

Grange Financial [Sussex] Limited, is a company registered in England and Wales (company number 4502151) whose registered office is situated at 88 Boundary Road, Hove, East Sussex, BN3 7GA.  The Financial Conduct Authority registration number for Grange Financial [Sussex] Limited is 229110.  Grange Financial [Sussex] Limited is registered with the Information Commissioner’s Office under registration number Z7243905

Grange Financial [Sussex] Limited is a firm that provides Financial, Mortgage, Insurance and Estate Planning Services and, for its regulated business, is an Appointed Representative of Best Practice IFA Group Limited, which is a network that provides back office services through the provision of back-up resource, technology, compliance, training and support. Best Practice IFA Group Limited is authorised and regulated by the Financial Conduct Authority under registration number is 223112.

As the operators of various financial businesses, services and websites, Grange Financial [Sussex] Limited are committed to protecting and respecting your privacy. This ‘Privacy Policy’ (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

When we mention ‘GFS’, ‘we’, ‘us’ or ‘our’ within this document, we are referring to the Grange Financial group of businesses.

For the purpose of the General Data Protection Regulation (‘GDPR’, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the ‘Data Protection Laws’) the Data Controller is Grange Financial [Sussex] Limited.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of providing our services and other information to you and also when you use our websites:

  • The information that you provide to us, for example by completing our Confidential Client Questionnaires [our fact finding documents] or filling out the contact section on our websites. This includes the information you provide when you contact us direct to enquire about our services, or request further information or apply for our services and/or ongoing servicing.
  • The types of information that you are required to provide to us will vary depending on the products that they are advising you about, but will usually include:
    • your name;
    • postal address;
    • email address;
    • telephone number;
    • date of birth;
    • gender;
    • bank details;
    • tax identifiers;
    • other information as required by your chosen product providers or as required by our regulators; and
    • information about your financial affairs, tax affairs, assets and liabilities;

and may also include special category personal data relating to:

  • your health
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys and feedback forms that we use for research purposes, although you do not have to respond to them.
  • Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

When you submit general enquiries to us [including via our websites], your name and contact details are required to enable us to respond to your enquiry.

The provision of your name, address and date of birth, as well as other personal data are required from you to enable us to fulfil our regulatory and legal obligations.

We may ask you for details of your children and dependants and/or the beneficiaries under a policy and/or the beneficiaries or executor/s under a Will – If you provide information about another person to us we expect you to ensure that they know you are doing so and that they consent to their information being provided and used by us. You might find it helpful to show them a copy of our ‘Privacy Notice’.

We will inform you, at the point of collecting information from you, whether you are required to provide any other information to us.

Information We Collect From Other Sources

We may also obtain personal information from other sources. Where we obtain information from another party, it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

In particular, we may;

  • Collect information from publicly accessible sources for example [but not limited to] the internet, Company’s House and HM Land Registry.
  • Collect information directly from Lenders or product providers on your existing contracts.

USES MADE OF YOUR INFORMATION

We rely on your consent as provided when you sign up to using our services as the ‘lawful basis’ on which we collect and use your personal data. Our legitimate interests in this data are to fulfil our contractual obligations to you and to fulfil our legal obligations as authorised and regulated firms.

Purposes of, and lawful basis, for processing

We use information held about you for the following purposes:

  • To provide you with our services and to carry out our obligations arising from any contracts entered into between you and us, including:
    • To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.
    • To operate, protect and improve our services, our business, and our clients’ experience.
    • To respond to any enquiries you submit to us.
    • As part of our efforts to keep our services safe and secure.

Where we have a contract with you to provide our services, and where the processing of your data is necessary to perform such contract, we rely on ‘performance of a contract with the data subject’ as the legal basis for the processing. In all other circumstances we rely on ‘legitimate interest’ and our legitimate interests are improvement of our services and/or prevention or detection of fraud.

  • Where you provide us with special category data, this will be used solely with your consent to research and advise on one or more products to suit your needs and to assist you with applications for and management of such products, and to provide such special category data to Best Practice and third party providers so that they can carry out the services that they provide to us.
    • To comply with our legal obligations as an authorised representative of an FCA regulated entity, including preparing and sending reports and submissions to Best Practice and/or regulatory authorities such as the FCA.  ‘Compliance with a legal obligation’ is the lawful basis on which we rely when we are carrying out regulated activities.
  • To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. In these circumstances we rely on ‘legitimate interest’ and the legitimate interest is the improvement of our services.
  • We also use your personal data where you have contacted us via the Website, by e-mail or telephone or participated in any surveys.  In these circumstances we rely on ‘legitimate interest’ and the legitimate interest is responding to and contacting you regarding the enquiries you have made in relation to the services we offer.

Marketing

In addition to the above uses, we may use your information to notify you about goods or services which may be of interest to you. Where we do this, we will contact you only if you have consented to such communication. If you do not want us to use your data in this way, please either (i) do not tick the relevant consent box situated in our Service Charter on which we collect your data; (ii) do not tick the relevant consent box situated in the your Declaration in our Fact Find document on which we collect your data; or (iii) inform us at any time by contacting us at the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

  • We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers). For example, but not limited to, our network provider, sourcing tools, product providers, our Will Writer and the host of our websites and servers.

We may disclose your personal data to any member of our group of business, which includes all our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
  • if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Client Agreement/Service Charter; or
  • to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with to provide the Website;or
  • in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

Other than as set out above and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, or with any regulatory or other legal obligation, we will not share your data with third parties unless we have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure (for example via e-mails). Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via our websites or via e-mails; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Websites may, from time to time, contain links to and from the websites of our associated businesses and our business partners. If you follow a link to any of these websites, please note that these websites have their own ‘privacy policies’ and ‘terms of use’ and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by contacting us using the e-mail contact details below. If you have any questions about how we use data collected which relates to you, again please contact us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data

  • We will hold personal data (e.g. name, address, date of birth and contact details) in line with our regulatory and legal obligations as set out by our regulator – currently a minimum of 5 years for investment business and indefinitely for occupational pension transfer or opt-out business.
  • If you contact us as a prospective customer using our e-mail address or via our Website contact form, requesting general information about our services, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact.
  • If you write any business via us we may continue to hold your personal data for an indefinite period.

Where we store your personal data

All of the information that we hold about you is stored on our secure servers within the EEA.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have, therefore, ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

If you would like further information, please contact us or the Compliance Director at Best Practice IFA Group Limited, of which we are an Appointed Representative (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your personal data may also be kept in paper format and will be securely stored within our offices.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Policy is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal data
  • otherwise restrict our processing of your personal data in certain circumstances
  • claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us or our Compliance Director at Best Practice (see the ‘Contact’ section below for details)
  • let us have enough information to identify you
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill, and
  • let us know the information to which your request relates (including any account or reference numbers, if you have them).

HOW TO COMPLAIN

We hope that we or our Compliance Director can resolve any query or concerns you raise about our use of your information, before this becomes a formal complaint and please contact us using the ‘Contact’ section below.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular, in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this ‘Privacy Policy’ at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied ‘Privacy Policy’.

INFORMATION ABOUT OUR USE OF COOKIES[AND IP ADDRESSES]

We may collect information about your mobile phone, computer or other device from which you access our Websites including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third party affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve the Website. By using our Website, you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use may include:

  • ‘Analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • ‘Strictly necessary’ cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • ‘Functionality’ cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • ‘Targeting’ cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates’ websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties affiliates may also use cookies, over which we have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy’ should be e-mailed to: info@grangefinancial.co.uk

Or write to us at:

Grange Financial [Sussex] Limited, Grange House, 68 Greenways, Ovingdean, Brighton, BN2 7BL

Or alternatively, please contact our Compliance Director at Best Practice IFA Group Ltd, Holmwood House, Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP, telephone number 01403 334455, or via email at info@bestpractice.co.uk