Greenstone Financial Planning Limited (“we” or “us”) is committed to protecting and respecting your privacy and we value the trust you place in us when you share your personal information with us. The way we may collect and use your personal information, and the choices available to you in connection with our use of your personal information, is discussed in this Privacy & Cookies Policy (“the Policy”).
This Policy (together with any other documents referred to therein) describes our information practices relating to using this website (“our Website”).
DISCLOSURE POLICY
We will only share non-public personal information with outside parties in the limited circumstances permitted by law. For example, this includes situations where we need to share information with companies who work on our behalf to service or maintain your account or process transactions you’ve requested, when the disclosure is to a party representing you, or when required by law (for example, in response to legal process).
Additionally, we will ensure that any outside companies assisting us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we’ve asked them to perform.
Confidentiality and Security
Our employees are required to follow procedures with respect to maintaining the confidentiality of our investors’ non-public personal information. Additionally, we maintain physical, electronic, and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.
Web-Related Privacy Issues
Information we collect from you:
We collect and process information from you when you enter it on our Website; ask for a referral to a financial adviser; are referred by a Professional Introducer such as a Solicitor or Accountant; subscribe to email newsletters, press releases or other periodicals; respond to a survey or marketing communication and in the course of providing our services to you.
The decision to provide this information is optional. However, if you decide not to provide such information, you may not be able to access certain content or features available on or through our Website.
We may also collect the following information through our Website:
- User information you provide (e.g. age, gender, marital status);
- Device information (e.g. device brand and model, screen dimensions);
- Unique identification numbers (e.g. IP address and device ID);
- Browser information (e.g. URL, browser type, pages visited);
- Advertising information (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad); and
- Behavioural information (i.e. information on the behaviour or presumed interests of individuals which are linked to those individuals and may be used to create interest segments).
How we use information
The information we collect allows us to:
- Provide you with our services;
- Personalise your experience of our Website;
- Administer the Website, investigate any complaints and provide customer services;
- Provide you with information and offers on products or services that may be of interest to you (see “Marketing Communications” below);
- Gather information to form statistical and trend analysis; and
- Meet legal, regulatory and compliance requirements.
- Notify you about changes to our services;
- Survey Information. Occasionally we may ask you to participate in a brief survey to help us make smart choices as we look for ways to improve our Website. If you choose to participate, information you provide won’t be identified with you directly.
How We Share Information
We will disclose your personal information to third parties only as described in this Policy:
- Subject to applicable law, in the event that the Company is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer your personal information in connection with such transaction
- Subject to applicable law, where we believe it is necessary to protect the Company, our property, our safety and that of our affiliated entities and our users, to enforce our terms or the legal rights of the Company or others, or to comply with a request from governmental authorities, legal process, or other legal obligations.
- 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.
Marketing Communications
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 by email only if you gave us permission for this when you registered. You can change your preferences by contacting us as described below.
Additionally, we will ensure that any outside companies assisting us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we’ve asked them to perform.
Confidentiality and Security
We have also implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and unauthorised access, use, alteration or disclosure over the Internet. However, the Internet is an open system and therefore is not completely secure. We cannot and do not guarantee or warrant the security of any information that you transmit on or through our Website; 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.
The website may from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
Our Website may contain links to websites or content operated and maintained by third parties, over which we have no control. Please consult the privacy policies of these third-party websites to become familiar with their privacy practices and to learn about any choices that these companies may offer you with respect to your personal information.
Your information rights
Under the General Data Protection Regulation (GDPR) you have a number of important rights free of charge. In summary, these include rights to:
- Access your personal data and 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 structure, 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, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you wish to opt out of direct marketing, or access, review, correct, update, change or delete the personal information which we have collected about you, or limit how we use it, please contact us as described below (see “Contact Us”).
Keeping your personal data up to date
If your personal details change you may update them by accessing this data through the wealth platform portal or ba contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, 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.
How to complain
We hope that We or our Compliance Director can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the 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 Commission who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113
Changes to this Policy
From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this page. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.
If you have any questions, concerns or complaints regarding this Policy and our information practices, please contact us.
Cookies
A cookie is a small text file which includes a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device when you visit a website. Cookies are widely used to make websites work efficiently and to collect information about your online preferences.
How do we use cookies?
We use cookies and other tracking technologies to customise content and advertising, provide social media features and to see how our visitors move through our website. We use this information to make decisions about ways to improve the services we offer you.
We use all or some of the following categories of cookies on our website:
Strictly necessary cookies
These cookies are essential for parts of our website to operate. They enable you to move around our website and allow us to recognise you within our website so that we can provide you with service that you have asked for such as remembering your sign-in details.
Functionality cookies
These cookies help us customise our site content based on your preferences. They remember choices you make such as identifying yourself as a particular investor type (Retail, Professional or Institutional), your language, the country you visit our website from and any changes you make to text size or other parts of our web pages. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Performance cookies
These cookies collect information on how you use our website in order to help us improve areas such as navigation and to help us fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve. The information stored by these cookies never shows personal details from which your identity can be established.
Targeting cookies
These cookies collect information about your browsing habits in order to make advertising, and the content we deliver, more relevant to you and your interests. They are also used to limit the number of times you see an advert or particular content, as well as help measure the effectiveness of an advertising or marketing campaign. These cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers.
Analytical cookies
These cookies 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.
Social Media cookies
These cookies allow you to share our website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
Web beacons
Some of our web pages may contain electronic images known as web beacons (also known as clear gifs or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.
You can find more information about cookies, behavioural advertising and online privacy at www.allaboutcookies.org or www.youronlinechoices.eu.
How do I reject cookies?
At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
Please consult the following links for information on cookie management and blocking according to your browser:
Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11.
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://support.apple.com/kb/PH19214?locale=en_GB
You can also manage cookie storage by using (as above): www.youronlinechoices.com/
Contact
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to info@greenstonefp.co.uk; or you may write to us a Greenstone Financial Planning Limited, 78 Pall Mall, LONDON, SW1Y 5ES. Alternatively, please contact our Compliance Director at Best Practice IFA Group Ltd, Sussex House, North Street, Horsham, West Sussex, RH12 1RQ; telephone number 01403 334455; or via email at info@bestpractice.co.uk