ATKINSON FINANCIAL SERVICES LIMITED PRIVACY POLICY

Atkinson Financial Services Limited are committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently.

This privacy policy explains:

• Who we are
• What personal information we collect
• Other data we collect
• How long we keep your personal information for
• The basis on which we collect your personal information
• How we use your personal information
• Who we share your information with and why
• How we keep your information secure
• Your rights
• Updates or amendments to our privacy policy
• How to contact us
• How to complain

Who we are

Atkinson Financial Services Limited is a limited company registered in England and Wales with company number 12046322 at 90-92 Scott Street, Barrow-in-Furness, Cumbria, LA14 1QE.

Atkinson Financial Services Limited is authorised and regulated by the Financial Conduct Authority. Our Firm reference number is 915934.

We are a firm of Independent Financial Advisers providing financial planning solutions to private individuals, businesses and charities throughout Cumbria and North Lancashire.

We operate a website at www.atkinsonfs.co.uk.  

For data protection purposes, Atkinson Financial Services Limited is registered with the Information Commissioner’s Office (ICO) under reference number: ZA585078.

What personal information we collect

Personal information includes your name, address, or phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial advisor, visit our website(s) or register to receive one of our newsletters.

The type of personal information we collect will depend on the purpose for which it is collected and includes:

• Contact details
• Information to verify your identity
• Family, lifestyle, health and financial information
• Payment details

We collect personal information directly from you. For example, we ask for personal information at the start of our relationship and in subsequent communications in order to check your identity and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.

We also collect personal information via our website. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information. 

Special category information

In some instances, it is necessary to collect more sensitive information (such as health or lifestyle information) which is called special category data. This is to allow us to provide our financial advice service to you. We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely. You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.

Cookies

We also collect information about you from other sources. For example, our website (www.atkinsonfs.co.uk) automatically collects information from your computer using “cookies” which provides us with limited personal information.

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

Our website uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited. For further information visit www.aboutcookies.org or www.allaboutcookies.org.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy .

Other data we collect

We also collect un-identified and non-identifiable information pertaining to website users, which may be made available or gathered via your use of our website (Non-personal Information). We are not aware of the identity of a user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our website. We may also collect information on your activity on the website (e.g. pages viewed, online browsing, clicks, actions, etc.).

How long we keep your personal information for

We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements.

Personal information will be securely disposed of when it is no longer required, in accordance with our Data Retention and Disposal Schedule. A copy of this is available using the contact details below.

The basis on which we collect your personal information

The processing of your personal data is allowed under a number of lawful bases. The data required for the provision of products and services is processed on the basis there is a contract with you to do so. Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so. However, you have rights, as listed below, which impact how we can use and process your data.

How we use your personal information

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements. This includes the following:

• Providing our advice, products or services to you
• Carrying out transactions you have requested
• Confirming and verifying your identity for security purposes
• Detecting and preventing fraud, crime, money laundering or other malpractice.

We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we process your information to send you marketing that is tailored to your interests.

Our business purposes include the following:

• Enhancing, modifying, and personalising our services for the benefit of our customers
• Providing communications which we think will be of interest to you
• Market or customer satisfaction research or statistical analysis
• Audit and record keeping purposes
• Enhancing the security of our network and information systems.

You have the right to object to this processing if you wish, please see “Your Rights” section below. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

We may also process your personal data as part of an acquisition or sale. Should this happen, you will be notified about any change to processing or data controller arising as a result of this activity.

Who we share your information with and why

We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include:

• Third parties to verify your identity, in line with money laundering or other requirements;
• Third parties who perform tasks for us to help us set up or service your financial products (these third parties may be based in countries outside the European Economic Area (EEA) but where they are, we will undertake an assessment of safeguards in place);
• Third parties for the hosting and operating of our website;
• Other organisations, including regulatory bodies, the police and fraud prevention agencies, to prevent and detect fraud;
• Third parties where required by law, court order or regulation; and
• Third parties as part of an acquisition or sale.

How we keep your information secure

We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

If we work with third parties in countries outside the EU, we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.

In limited circumstances data may be accessed outside of the EEA i.e. by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.

Your rights

Atkinson Financial Services Limited tries to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below. This privacy policy was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here.

Marketing

If you would like to receive news, offers and promotions from Atkinson Financial Services Ltd via email, you can select to do so on our website. You have the right to opt out of receiving marketing information and tell us what your communication preferences are by contacting Atkinson Financial Services Limited using the details provided at the end of this policy or by using the opt out option on any email marketing. You may opt out at any time.

Individual data rights and requests

• The right to be informed – You can request that we provide ‘fair processing information’, typically through this privacy policy;
• The right of access – You may request a copy of the personal information we hold about you using the contact details found on the end of this privacy policy;
• The right to rectification – The accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information;
• The right to erasure – You may request the deletion or removal of personal data where there is no compelling reason for its continued processing;
• The right to object – You may object to the processing of your data based on legitimate interests;
• The right to restrict processing - You have a right to request we ‘block’ or suppress processing of your personal data;
• The right to data portability – You may request to obtain and reuse your data; and
• The right not to be subject to automated decision-making including profiling.

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the number/address listed below.

Updates or amendments to our privacy policy

We reserve the right to periodically amend or revise our privacy policy; material changes will be effective immediately upon the display of the revised privacy policy. Your continued use of our services, following the notification of such amendments, constitutes your acknowledgment and consent of such amendments to the privacy policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have questions about this policy, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details:

Mr Nigel Atkinson
Data Protection Officer

Atkinson Financial Services Limited
90-92 Scott Street
Barrow-in-Furness
Cumbria
LA14 1QE

T: 01229-870938

How to complain

If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

If you are not satisfied with our response, or believe we are not processing your personal data in accordance with the law you can complain to our data protection regulator:

Information Governance Department

Information Commissioner's Office
Wycliffe HouseWater Lane
Wilmslow
Cheshire
SK9 5AF

T: 0303 123 1113

W: www.ico.org.uk/concerns

Last updated: 22^nd November 2021