First Wealth (London) Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected 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.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (collectively the “Data Protection Laws”) the Data Controller is the Compliance Director at Best Practice IFA Group Ltd.
We are an authorised representative of the Best Practice IFA Group Limited (“Best Practice”), who assist Us with various aspects of our compliance activity, including FCA compliance, AML checks and data protection. In order that Best Practice can provide these services, we are required to send across personal data We have collected. More information about how Best Practice will use your personal data can be found in their Privacy Notice at bestpractice.co.uk/best-practice/privacy-policy/.
We collect and process some or all of the following types of information from you in the course of providing our services and other information to you and your use of our website firstwealth.co.uk.
and may also include special category personal data relating to:
The provision of your name, address and date of birth, as well as certain other personal data that we will notify you of from time to time, is required from you to enable Us to advise you and to fulfil our regulatory and legal obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
We use information held about you for the following purposes:
Where we have a contract with you to provide our services, and where the processing of your data is necessary to perform such contract, we rely on “performance of a contract with the data subject” as the legal basis for the processing. In all other circumstances we rely on “legitimate interest” and our legitimate interests are improvement of our services and/or prevention or detection of fraud.
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. If you do not want Us to use your data in this way please either (i) tick the relevant box situated on your service charter on which We collect your data; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
We routinely disclose your personal data to third parties as follows:
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us or with any regulatory or other legal obligation, We will not share your data with third parties unless We have procured your express consent to do so.
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
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 the 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.
If your personal details change you may update them by accessing this data through the wealth platform portal, or by 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 e-mailing firstname.lastname@example.org, or contact the team on 0207 467 2700.
We will endeavour to update your personal data within seven 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.
All of the information that We hold about you is stored on our secure servers within the EEA.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and We have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
If you would like further information, please contact Us or the Compliance Director at Best Practice (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
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 would like to exercise any of those rights, please:
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 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 Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website, including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties’ affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to Anthony Villis, Managing Director at First Wealth (London) Limited, 6 Broadstone Place, London, W1U 7EN. Or alternatively please contact our Compliance Director at Best Practice IFA Group Limited, Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP, telephone number 01403 334455, or via email at email@example.com.