Barwells Wealth is a trading name of Barwells Independent Financial Management Ltd. This privacy notice explains how we use any personal information we collect about you.
It applies to Information collected by us or provided by you to our Website (including the mobile-optimised version of the website accessible from your portable hand-held device) or in any other way (such as over the telephone). It is also intended to assist you in making informed decisions when using our Website and our products and services. Please take a minute to read and understand the policy.
All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data.
What information do we collect about you?
We collect information about you when you engage us for financial planning, financial advice, equity release mortgage advice and investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
When you visit our Website (including the mobile-optimised version of the website accessible from your portable hand-held device), you may provide us with personal information such as name, postcode, email address, landline phone number, mobile phone number, and information about your requirements and the services you might be interested in (“Information”).
You may provide us with Information in a number of ways:
a) By supplying us with the information as listed above, on an individual basis by registering as a registered user, subscribing to receive updates or information from us or completing our online contact form. To become a registered user, you must provide us with your name, postcode, email address, landline phone number and mobile phone number, but you may also provide us with additional information if you choose to do so;
b) By corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
c) By downloading our digital content or applying for a job with us;
d) Through any preferences and areas of interest as advised by you on subscribing to our online services;
e) By Information provided when you use our App; and
f) By Information provided when you use our mobile-optimised website from your portable hand-held device including details of your physical location, where you have agreed to it being used.
We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our advertisers.
This is statistical data about browsing actions and patterns and does not identify you as an individual.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
We won’t share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
Five years for investment business
Three years for mortgage business
Indefinitely for pension transfers and opt-out business
Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 99 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information, please email or write to us using the contact details noted below. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We’d like to send you information about our products and services and those of Barwells Solicitors which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
We use ‘Session’ Cookies which enable you to carry information across pages of the Website and avoid having to re-enter information. Session Cookies enable us to compile statistics that help us to understand how the Website is being used and to improve its structure.
We also use ‘Persistent’ Cookies which remain in the Cookies file of your browser for longer and help us to recognise you as a unique visitor to the Website, tailoring the content of certain areas of the Website to offer you content that match your preferred interests.
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office
0303 123 1113 (local rate)
How to contact us
Or write to us at: Barwells Wealth, 1 Station Farm Barns, Station Road, Glynde, Lewes, East Sussex, BN8 6EU.