Nexus IFA Limited & Nexus Financial Planning understand their obligations in regards to your fundamental right to a private life and have implemented systems and controls to ensure your rights and freedoms are protected.
Nexus IFA Limited & Nexus Financial Planning undertake to meet their obligations under the Data Protection Act, the Privacy and Electronic Communications Regulations and the EU General Data Protection Regulation (GDPR).
|WHO WILL PROCESS YOUR PERSONAL INFORMATION?|
|Your personal information will be initially processed by Advisers & staff of Nexus IFA Limited and/or Nexus Financial Planning who are both Appointed Representatives of The Whitechurch Network Limited. Your personal data will be further processed by On-Line Partnership Group Limited on behalf of its subsidiary company The Whitechurch Network Limited who act as our Principal for regulatory purposes. All parties will process your personal data in accordance with this privacy notice.
|WHY IS YOUR PERSONAL INFORMATION REQUIRED?|
|Your personal information may be required to reply to an enquiry or to enable us to take necessary steps at your request prior to entering into a contract to provide financial services and to perform such a contract. This may include identity and age verification checks, reviewing assets and liabilities, bank account validation, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other applicable legislation.
|WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?|
|Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you.
|WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION?|
|Your personal data is essential to enable us to answer your enquiry or to take steps at your request prior to entering into a contract to provide financial services or to perform a contract to which you are a party. Without this information we will not be able to proceed any further.
|WHAT MAKES THE PROCESSING LAWFUL?|
|Because the processing is necessary:
· for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
· for compliance with a legal obligation to which we are subject;
· for the performance of a task carried out in the public interest;
· for the purposes of the legitimate interests pursued by us.
|KEEPING YOUR INFORMATION UP TO DATE|
|We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and where possible notify relevant third parties of any changes.
|WHAT ABOUT SENSITIVE PERSONAL DATA?|
|Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities. In such cases you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time.
|HOW WILL WE FURTHER USE YOUR PERSONAL INFORMATION (OUR LEGITIMATE INTERESTS)?|
|· To contact you to ensure that our records of your personal information are correct;
· To respond to questions or complaints you have about our services;
· To update you with changes in our terms;
· For statistical or research analysis relating to the performance of our business or that of our principal and understanding the changing needs of our clients;
· To review, improve and develop services we offer or handle complaints;
· To pursue debts or unpaid fees;
· To evidence company practices;
· To evidence the standards and processes carried out conform to the company’s ethical standards and expectations;
· For direct marketing activities;
· To protect the business from risks which might be introduced by an individual.
You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue.
|PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST|
|We will use the information provided to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd.
|WHAT INFORMATION IS REQUIRED?|
|We only collect information that is necessary to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful we will inform you about any personal data we receive about you from third parties that you may be unaware of.
|HOW SECURE WILL YOUR DATA BE?|
|We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures will be in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another individual or organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding confidentiality with appropriate security measures in place and only process your information in the way we’ve authorised them to. These organisations won’t be entitled to use your personal information for their own purposes. If necessary, we will security check them to make sure they meet the security requirements we’ve set. Please contact our Data Controller if you would like further information.
|WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?|
|We may share your information with:
· Appropriate staff such as those who carry out financial or compliance functions.
· Organisations that need your information because we are required to provide it by law (e.g. The FCA, ombudsman services, HMRC etc).
· Organisations that carry out credit references or identity checks such as GB Group Plc or CreditSafe Business Solutions Ltd. These organisations may keep a record of the information and may disclose the fact that a search of its records was made to its other customers for the purposes of assessing the risk of giving credit, to prevent fraud and to trace debtors.
· Sometimes other authorised firms with specialist advisers, such as pension specialists, who assist us in providing suitable financial advice and services. You will be provided with their details if this applies.
· Organisations and individuals contracted by us to carry out specific administrative, financial, compliance or direct marketing functions. These contractors will only process your information under our instructions and operate under the same obligations for data protection as we ourselves operate.
· Law enforcement agencies, courts or other public authorities if we have to, or are authorised to by law.
· Product providers we use to provide financial services or for direct marketing (see below).
Where we or our Principal go through a business transaction, such as a merger, being acquired by another company or selling a portion of its assets, your information will, in most instances, be part of the assets transferred.
|TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION|
|We do not usually transfer any of your personal data outside of the EU except:
· When we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases Creditsafe encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.
· When we use a third party data processor contracted to perform direct marketing functions. The data they process is limited to contact details only. Some companies, like Mailchimp, may transfer and process this data outside of the EU. In such cases Mailchimp have agreed to provide an adequate level of protection for the data processed, in line & accordance with the requirements of EU Data Protection Laws.
|WHAT ABOUT DIRECT MARKETING?|
|We will use the information provided now and in the future to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can choose which method you’d prefer us to use to contact you (by email or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity. Contact our Data Controller (see below) to let them know about your preferences.
|VISITORS TO OUR WEBSITE|
|When someone visits our website – www.nexusifa.co.uk – we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, such as on an enquiry form, we will be clear about this and explain what we intend to do with it. We will use your contact details to communicate with you, we may also, with your consent, use your information to send you news about our products and services.
|WHAT ABOUT COOKIES?|
|TYPES OF INFORMATION WE PROCESS|
|Information about you that we collect and use includes:
· Information about a person’s identity such as their name, date of birth and contact details.
· Information connected to a product or service.
· Information about your contact with us, e.g. meetings, phone calls, emails / letters
· Information that is automatically collected e.g. via cookies when you visit one of our websites
· Information if you visit our office, e.g. visual images collected via closed circuit television (CCTV)
· Information classified as ‘sensitive’ personal information, e.g. relating to your health. This information will only be collected and used where it’s needed to provide a product or service you have requested or to comply with our legal obligations in matters of employment.
· Information you may provide us about other people, e.g. joint applicants or beneficiaries for products.
· Information on children, e.g. where a child is named as a beneficiary on the application for a policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender).
|HOW DO WE COLLECT YOUR INFORMATION?|
|We may collect your personal information from a variety of ways, including:
· a telephone conversations with us
· emails or letters you send to us
· an application form for a product or service
· meetings with us
· our websites or via our social media pages
|AUTOMATED DECISION-MAKING PROCESSES|
|We sometimes use automated processes when making decisions but you will not be subject to a decision based solely on automated processing, including profiling.
|TELEPHONE CALL RECORDING|
|In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 we may record incoming or outgoing telephone conversations for the following purposes:
· Establishing facts and evidence for business transactions;
· Ensuring compliance with regulatory or self-regulatory practices;
· Ascertaining and demonstrating that standards are being met;
· Preventing or detecting crime;
· Investigating or detecting the unauthorised use of that or any other telecommunication system;
· Safeguarding the effective operation of the telecommunications system.
|HOW LONG WILL WE KEEP YOUR INFORMATION FOR?|
|The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet these requirements. We will not keep your information for longer than is necessary.
|REQUESTING A COPY OF THE INFORMATION WE HOLD|
|You may at any time ask for a copy of the information we hold about you – it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect your personal data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.
|You have the right, on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims.
You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose.
|WHAT ARE YOUR OTHER LEGAL RIGHTS?|
|In addition to the rights above the additional following rights:
· Where you have given consent, you have the right to withdraw previous consent to processing your personal data at any time;
· You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning your data;
· You have the right to receive data you have provided to us in a structured, commonly used and machine readable format;
· You have the right to lodge a complaint with the regulator (please see below).
To exercise any of these rights please contact our Data Controller (details below).
|HOW TO CONTACT OUR DATA CONTROLLER|
|You can contact our Data Controller about any data protection or marketing issues by:
• Writing to:
Nexus Data Controller, 2-4 York Buildings, Cornhill, Bridgwater, Somerset, TA6 3BS,
• Telephoning: 01278 439494
• Emailing: email@example.com
HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR?
|• By writing to:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• By telephoning: 0303 123 1113
• By emailing: firstname.lastname@example.org
You can at any time change or withdraw your consent from the Cookie Declaration on our website.
Your consent applies to the following website: www.blog.nexusifa.co.uk
What are cookies ?
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The third-party cookies used on our websites are used mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
What types of cookies might we use ?
Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket and checkout securely.
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The information stored in these cookies may also be used by the third-party ad providers to show you ads on other websites on the browser as well.
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The list below details the cookies used in our website.
|_ga, _gid||cookies asssociated with Google Universal Analytics – used to distinguish unique users, track amount of visits, and the time of the visit and keeps track of returning visits. No personal information is stored in the cookies.|
|eu_cn, external_referer, guest_id, personalization_id, tfw-exp||cookies set by Twitter – used to help display tweets on the site, monitor referral links, used to identify those logged into Twitter and collect data related to the Twitter platform.|
|eucookielaw||technical cookie which prevents the banner from being displayed to the same user again for 30 days|
|lang||used to store language preferences|
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