Principled Finance – Privacy policy

Principled Finance Limited (“We”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect 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. By visiting www.principledfinance.co.uk you are accepting and consenting to the practices described in this policy. We also ask you to give your express consent (by way of our opt-in boxes) to the uses of your data that are detailed in this policy.

To protect your data, we subscribe to terms of The Data Protection Act 2018, Regulation (EU) 2016/279 (General Data Protection Regulation) and The Privacy and Electronic Communications (EC Directive) Regulations 2003 and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of communications, where amended (the Data Protection Legislation).

In accordance with Data Protection Legislation, We, Principled Finance Limited of International House, 24 Holborn Viaduct, London, England, EC1A 2BN are registered as a Data Controller with the Information Commissioners Office, registration number ZA081712.

We subscribe to recommended data sharing protocols contained in Data Controller Data Sharing Code of Practice issued by the Information Commissioners Office.

Further, We are regulated by the Financial Conduct Authority (FCA) and subscribe to all data protection codes of conduct and practices issued by that authority so we may protect your privacy in a way recommended by our sector.

Information we collect from you

We will collect and process the following data about you:

– Information you give us. This is information about you that you give us by filling in forms on our site www.principledfinance.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, date of birth, e-mail address and phone number, personal financial information, financial information, personal description, personal identification, a photograph or information concerning your medical history where relevant to a product.
Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
–  technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform.
–  information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

• Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We do not use automated decision making.

Cookies

Our website uses cookies. This helps us to provide you with an improved user experience when you browse our website and allows us to improve our site and service offers to you. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy Principled Finance Cookie Policy .

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. This is called website tracking. While tracking, we also collect information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or your ISP or mobile carrier. If you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honour your settings.

When accessing our website should you not wish to permit cookies to access your personal browser data then we recommend that you control access permissions on your device by adjusting your privacy control settings.

Uses made of the information

We use information held about you in the following ways:
• Information you give to us. We will use this information:
–  your details are collected when you submit one of our forms and they can be used by Principled Finance and selected partners with respect to responding to your inquiry
– to assist you in finding an approved Principled Finance third party partner or affiliate (which may be an independent financial adviser), suitable to your needs and requirements;
–  to carry out our obligations ourselves or through our sub-contractors (in which case we will remain responsible for ensuring that the subcontractor complies with this policy and data protection legislation);
–  arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
–  to provide you with information, with your prior consent, about other goods and services we offer that are similar to those that you have already purchased or inquired about;
–  to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. A list of the categories of third parties who might contact you and the goods and services they may be offering can be found here. We (or they) will contact you only if you have explicitly consented to this and by the means that you have ticked as being acceptable for this purpose on the form in which you enter your data (the registration/inquiry form). If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box on the form;
–  to notify you about changes to our service;
–  to ensure that content from our site is presented in the most effective manner for you and for your computer.

• Information we collect about you. We will use this information in the ways permitted by data protection law:
–  to notify our select panel of approved partners (including Independent Financial Advisers) who are validated by us of your needs and requirements;
–  to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
–  to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
–  to allow you to participate in interactive features of our service, when you choose to do so;
–  as part of our efforts to keep our site safe and secure;
–  to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
–  to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

How do we lawfully process your information?

The lawful grounds for processing your personal data are:

• Performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, as set out in our Terms of Use to which our privacy policy applies. We need certain personal data to process your contract and so we cannot provide you with our service where this information is not provided by you.
• Consent given by you to the processing of your personal data for one or more specific purposes, namely 1) where you have given us consent to receive electronic marketing by us and/or by our selected third parties and 2) to process information concerning your health where we require this for certain insurance products.
• Legitimate interests. This is when we may contact you where we make an assessment that you would reasonably expect us to contact you with regard to services. We make this assessment to contact you only when our interests in doing this are not overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests are to improve and to promote our services and products and better understand our customers’ interests and to notify our panel of approved partners so that they may support us in those improvements and promotions and to administer and improve our site and internal operations.

Disclosure of your information and data sharing

With your prior consent we have the right to share your personal information with:
• Any member of our group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Carefully selected third parties from whom we may receive a commission including:
–  Independent Financial Advisers validated by us who we believe to be in a position to meet your needs and requirements;
–  Carefully selected financial product specialists; Key Equity Release, an FCA authorised equity release firm, will contact you via email, SMS and/or telephone to discuss your enquiry for equity release
–  Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We may also use aggregated information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
–  Analytics and search engine providers that assist us in the improvement and optimisation of our site;
–  Bodies who verify identity and credit reference agencies for the purpose of verifying your identity and assessing your credit score where this is a condition of us entering into a contract with you.

Our business may match your profile to third party companies providing goods or services of interest to you. We try to ensure that you only receive offers that are relevant to you and fit within the context of your lifestyle and available purchasing power. For example, if you have provided your life insurance renewal data and have consented to third parties contact you one month before your renewal date, we will work with our third party partners to send you a life insurance renewal quote tailored to your needs – thus saving you time researching the entire market. Should you not wish to receive any expiry or renewal notices, please send us an e-mail at info@principledfinance.co.uk.

A list of data categories can be found here.

We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Principled Finance Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• 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 terms of use www.principledfinance.co.uk and other agreements; or to protect the rights, property, or safety of Principled Finance, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• We are obliged on occasion to make mandatory disclosure to statutory authorities where criminal or civil investigations contemplated by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, The Criminal Finances Act 2017 and Proceeds of Crime Act 2002 may apply.

Where we store your personal data

All information you provide to us is stored on our secure servers or with organisations we use as described in this notice, in both cases on servers located within the EEA. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we receive your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retaining your data

In some cases, we will have a legal or statutory obligation to retain information for a set period. For example, to comply with statutory regulation requirements such as AML which oblige our retention of data for a minimum period of 7 years.

If you ask us to delete your data then we may not be able to provide you with all of the services offered from this website where your request conflicts with our statutory obligations which require us to retain your data for minimum period regardless of your request.

Your Subject Access Rights

By way of Data Protection Legislation, you are entitled to avail of access rights to your data. These are called Subject Access Rights. They entitle you to also ask us to restrict or correct the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) where you feel it impacts on your fundamental rights and freedoms.

Where we are processing your personal data for marketing purposes you can withdraw your consent at any time. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. Where you wish to submit a subject access request, we will ask you to provide ID in order to prove that you are the person entitled to make the subject access request. Where you cannot prove your identity we may refuse your request.

You can exercise your right to withdraw or restrict processing consent by checking certain boxes on the forms we use to collect your data and if you no longer want us to use your details for marketing purposes, you can withdraw your consent by using the unsubscribe facility which can be found at the footer of every page of our website. You can also exercise the right at any time by contacting us directly at info@principledfinance.co.uk .

If you no longer wish us to hold your medical information where you have previously provided it, please withdraw your consent by using the unsubscribe facility which can be found on every page of our website.

You also have the right to request us to amend your personal data so that it is correct and complete or to delete your personal data. However, where we are obliged by law to retain your data for a statutory period we will be unable to delete your information where your deletion request contravenes law and we could refuse your request at that time.

You may request us to transfer your personal data to another person or to yourself in electronic format, If you would like us to move, copy, or transfer your information please let us know by email to info@principledfinance.co.uk. We will respond to you within 30 days after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question. Where we are unable to comply with a request we will provide the justification for the refusal.

Our site 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 that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

You have the right to request a copy of your personal data that we store and we will provide it to you free of charge within 30 calendar days from the date of your request. You can also exercise this right and any other subject access rights at any time by contacting us at info@principledfinance.co.uk .

Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. We last updated this privacy policy on [06/08/2018]
Contact and Complaints about the use of your personal data

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@principledfinance.co.uk.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.