This Policy explains when and why we collect personal information about people who enquire about our services. The policy also explains how we use that information, the conditions under which we may disclose information to others and how we keep personal information secure.
When using the term “processing”, we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (so practically anything we do to your personal data is processing!)
Who we are and how to contact us
Investments and Pensions for Europe (IPE) is an independent information website that connects British citizens who are currently resident in Europe with financial companies who offer specialist overseas investments advice.
We connect you to qualified, regulated independent financial advisers across Europe who are up to date with the complex and rapidly changing world of financial services and tax regulation.
Investments & Pensions for Europe
What type of information is collected?
We only collect data which you supply when requesting us to contact you or when requesting one of our guides. Typically this information can be grouped as follow:-
- Identity Data includes first name, maiden name, last name and gender.
- Contact Data country of residence, email address and telephone numbers.
- Usage Data includes information about how you use our website, products and services, and navigate through the website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
How we collect information from you
We collect information about you when you:
- use our website ‘contact us’ form to enquire about services or request a guide from us
- call our office to enquire about our services
We do not collect any other information apart from what you enter on our website
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that IPE employees comply with legal obligations.
How we use your personal information
We use personal information in connection with the following purposes:
Provision of services and account management:
- **We provide your details to a qualified, regulated financial service company who will either contact you by email or telephone to support you and offer financial advice as IPE are an information only website as previously mentioned.
- to meet a legal or regulatory obligation.
- to ensure that content from our site is presented in the most effective manner for you;
- to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to notify you about changes to our service;
- as part of our efforts to keep our site safe and secure;
- to provide you with information about other services we offer that are like those that you already have or have enquired about;
If you do not want your personal information to be used for marketing purposes, please contact us on the above details.
Change of Purpose:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on the above details.
How long we keep your information for
Your individual rights
You have certain rights under applicable legislation, and under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’).
Right Information and access
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Right to erasure (‘right to be forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
- the personal information is no longer necessary for the purpose for which it was collected;
- you withdraw your consent to consent based processing and no other legal justification for processing applies;
- you object to processing for direct marketing purposes;
- we unlawfully processed your personal information; and
- erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
- Exercising the right of freedom of expression and information;
- Complying with a legal obligation under EU or other applicable law;
- The performance of a task carried out in the public interest;
- Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
- The establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
Instead of requesting erasure, you also have the right to right to restrict processing of your personal information where:
- you contest the accuracy of the personal information;
- processing is unlawful, but you do not want us to erase it;
- we no longer need to process your personal information, but you need us to retain your information as you need it for the establishment, exercise, or defence of legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
You also have the right to object to processing of your personal information under certain circumstances, such as:
- where the processing is based on your consent and you withdraw that consent;
- where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms; or
- where we are processing your personal data for direct marketing purposes
Exercise of this right may impact the services we can provide, and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.
Right to data portability
With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to freedom from automated decision-making
As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
Right to object to direct marketing (‘opting out’)
You have a choice about whether you wish to receive information from us.
We will not contact you for marketing purposes unless:
- you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
- you have otherwise given your prior consent (such as when you download one of our guides)
You can change your marketing preferences at any time by contacting us on the above details. On each marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
Right to request access
You also have a right to access information we hold about you. You can exercise this right at any time by contacting us on the above details.
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then reply in a reasonable time. this is deemed to be 10 working days.
Sharing your personal information
We only pass your information to qualified financial service business partners who contact you to support you on a one to one basis.
Transferring your information outside of the European Economic Area
If you live outside the EEA, there may be instances where as part of the services offered to you the information which you provide to us may be transferred to financial counsultants based outside of the European Economic Area (“EEA”). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.
Keeping your information safe
At IPE, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have several security measures in place to help prevent fraud and cybercrime.
If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, business partners or employees, we will inform them without undue delay.
We educate and train our employees on our information security, fraud prevention and privacy obligations annually. Information Security awareness also forms part of our new employee induction program.
We also educate our employees in identifying potential financial crime and internal fraud. any suspicious activity is reported to the policy director.
We will always interact with you in a safe, secure and consistent manner
To keep your information secure and to protect our clients from fraud, IPE will only interact with you i
When interacting with you, we will:
- Verify who we are and you are when speaking to you on the phone, by asking you some security questions.
We will not:
- Ask you for any password over the phone.
- Ask you for any form of payment.
Physical controls – As well as protecting your digital information, PFE also protects its offices where personal data may be used and stored. This includes secure disposal of confidential waste and hardware, personal card access and locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.
Logical controls – IPE uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We have a business continuity plan.
The key drivers in developing the business continuity plans are;
- To mitigate the risks that could lead to the significant disruption of our services to our clients.
- To provide a recovery plan that supports a timely and full restoration of our services for our clients
Whilst we take appropriate technical and organisational measures to safeguard your personal information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.
Privacy Protections for Children Using the Internet
Protecting children’s privacy is important to us. For that reason, we do not collect or maintain information on our website from those we know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue use of our website.
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