For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) Evolution Wealth Network Limited is a Data Controller of your personal data.
IMPORTANT NOTICE ABOUT OUR COMPLIANCE SERVICES: We provide Compliance Services to your financial advisers (“Advisers”). Advisers rely on Us to assist with various aspects of their compliance activity, including FCA compliance, AML checks and data protection. As part of the Compliance Services We provide to Advisers, Advisers will send across personal data they have collected, which We will use as part of the Compliance Services We provide to them. For more information on this, please refer to the service charter (“Service Charter”) you received from your Adviser.
Your Adviser will also be a Data Controller in respect of your personal data. You should contact your Adviser should you have any enquiries relating to their processing of your personal data in the course of providing their services to you.
Information We collect from you
We collect and process some or all of the following types of information from you:
When submitting general enquiries through to Us (including through the Website), your name and e-mail address are required from you to enable Us to respond to your enquiry.
We will inform you at the point of collecting information from you, whether you are required to provide any other information to Us.
Lawful basis for processing
We rely on the fulfilment of Our contractual obligations pursuant to Our agreement with your Adviser and the adherence to Our own service charter as the lawful basis for processing your personal data.
Where you have contacted Us via the Website, by e-mail or telephone or participated in any surveys, we rely on “legitimate interest” and the legitimate interest is responding and contacting you regarding the enquiries you have made in relation to the services We offer.
Purposes of processing
We use information held about you in the following ways:
As part of your use of certain Evolution Wealth Network Ltd Services, We may share your personal data with third party regulatory authorities such as the FCA and the Financial Ombudsman Service.
We may pass your personal data to Our third party service providers, agents, subcontractors and other associated organisations for the purposes of: (i) completing tasks and providing services to you on our behalf (e.g. to host Our servers) and (ii) storing, protecting and securing your personal data.
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, 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 Us; any transmission of your data to an Evolution Wealth Network Ltd Service 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.
Keeping your personal data up to date
If your personal details change you may update them by contacting your Adviser. With certain Evolution Wealth Network Ltd Services, you may update your personal data by contacting Us directly using the contact details below. If you are unsure as to who you should contact, We will endeavour to advise you accordingly. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
Where you have contacted Us regarding an update to your personal data and We agree that this should be dealt with by Us as opposed to your Adviser, We will endeavour to update your personal data within 14 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.
How long We keep your personal data
• We will hold your personal data relating to occupational pension transfers indefinitely in order to comply with the requirements of Our regulators from time to time.
• We are required to hold your personal data relating to your investments for a minimum period of 5 years and will continue to do so for so long as Our regulators require.
• If you contact Us as a prospective customer using Our e-mail address or via Our Website contact form, requesting general information about our services, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from Our last point of contact.
• If you contact Us as a prospective customer using Our e-mail address or via Our Website contact form, requesting quotes and information about Our services in respect of specific projects, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from Our last point of contact.
• Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 12 months.
Where we store your personal data
All information 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 your Adviser. You may also contact Us using the contact details below. We will not otherwise transfer your personal data outside of the 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:
• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.
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:
• email, call or write to Us using the “Contact” details below;
• let Us have enough information to identify you,
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates.
HOW TO COMPLAIN
We hope that We 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 reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you through the applicable Evolution Wealth Network Ltd Service. Your continued use of the Evolution Wealth Network Ltd Service shall be deemed your acceptance of the varied Policy.
Where relevant, 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. 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.
For the Website, We use the following cookies:
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Tel: 01403 334499