Privacy Notice

Under data protection law, individuals have a right to be informed about how we use any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This is the privacy notice of ENSURED WILLS LTD

Our registered office address is at 6 Hopesay Close, Webheath, Redditch, Worcestershire, B97 5FL.

Our registered company number is 12059316.

Introduction

1. This privacy statement informs you about how we process information that we record about you, whether provided by you, or by another person or organisation. It applies to information that could identify you as an individual (“personal information”) and information that does not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

2. We are committed to the protection of your privacy and confidentiality. We recognise that you are entitled to know that your data will not be used for any unintended purpose, and will not accidentally fall into the hands of a third party.

3. We undertake to preserve the confidentiality of all information you provide to us.

4. We have in place procedures and training for data protection, confidentiality and information security. These are regularly reviewed to ensure that they remain effective.

5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

7. Except as set out below, we do not share, or sell, or disclose to a thirds party, any information collected by you.

8. Data We Process

We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our services and for other agreed purposes. Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

Personal Clients

If you are a personal client, personal data that we process may include contact information, information about your family members, and financial information such as that relating to your assets, investments, income, and expenditure. In most cases, your personal data will have been provided to us by you. However, with your consent, or if it is necessary in order to provide you with our services, we may have obtained your personal data from a third party source.

Third Parties Connected to Clients and Suppliers

We may process your personal data if you have a personal or business connection with any of our clients. For example, you may be a family member, business partner, friend other adviser. We may be given your personal data by our clients, or by third parties acting on instructions of a client. We ask our clients to bring this privacy notice to your attention as soon as they become aware that we process your personal data.

Suppliers

If you supply our business with services, including subcontracted services that we supply to our clients, then we may process your personal information. However, we do so only to the extent necessary to contract with you.

9. Information we process because we have a contractual obligation

We process personal information when a contract has been formed with us and processing is necessary to carry out our obligations under that contract, or when processing personal data is necessary in order to form a contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

10. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do so after having given careful consideration to whether you would expect us to process your data, and whether you would consider it reasonable to do so. For example, we may process your data on this basis for the purposes of:

• Record-keeping for the proper and necessary administration of our business.

• Responding to communication from you to which we believe you would expect a response.

• Protecting and asserting the legal rights of any party.

• Insuring against or obtaining professional advice that is required to manage business risk.

• Protecting your interests where we believe we have a duty to do so.

11. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

12. Communicating with you

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

13. Dealing with complaints

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person or organisation, we may decide to give that other person or organisation some of the information contained in your complaint. If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate. We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

14. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

15. Access to your personal information

15.1 At any time you may review or update personally identifiable information that we may hold about you.

15.2 To obtain a copy of any information we hold about you, you may send us a request.

15.3 After receiving the request, we will tell you when we expect to provide you with the information.

16. Verification of your information

When we receive any request to access or edit personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

17. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

17.1 to provide you with the services you have requested;

17.2 to comply with other law;

17.3 to support a claim or defence in court.

18. If you are not happy with our privacy policy

18.1 If you are not happy with our privacy policy or if you have any complaint then you should tell us.

18.2 If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done online at: https://ico.org.uk/concerns/ or by calling: 0303 123 1113, or by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

19. Review of this privacy policy

We may update this privacy notice from time to time as necessary.