For the purposes of data protection legislation, the data controller is Clever Adviser Technology Limited of Watergate House, 85 Watergate Street, Chester, Cheshire CH1 2LF.
- INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following data about you:
- information that you provide by filling in forms on our website or by phone, email or otherwise. This includes information provided at the time of registering to use our site, like your name, address, email address, phone number and financial information, and information you give when subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site;
- if you contact us, we may keep a record of that correspondence;
- if you telephone us, we will record that conversation unless you specifically ask us not to do so
- details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
- technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service;
- information we receive from other sources; including your IFA.
WHERE WE STORE YOUR INFORMATION
The data that we collect from you is stored at a destination inside the European Economic Area (“EEA”).
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 our site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
- WHY DO WE COLLECT AND PROCESS YOUR INFORMATION
We collect and process your personal information for the following reasons:
Pursuant to a contract in order to:
- process information at your request to take steps to enter into a contract;
- provide you with our products and services;
- process payments;
- make deliveries;
- maintain business and service continuity;
- send service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email or post or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our service.
On the basis of your consent:
- Where we rely on your consent for processing this will be brought to your attention when the information is collected from you;
- We will only contact you with direct marketing communications if you consent to us doing so and you have the right to withdraw consent at any time. See the What are your rights? the section below for more information.
- We will provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
In our legitimate interests of providing the best service and improving and growing our business, we will process information in order to:
- ensure that content from our site is presented in the most effective manner for you;
- allow you to participate in interactive features of our service when you choose to do so;
- notify you about changes to our service;
- provide you with a personalised service;
- improve our products and services;
- keep our site and systems safe and secure;
- understand our customer base and purchasing trends;
- defend against or exercise legal claims and investigate complaints; and
- understand the effectiveness of our marketing.
We will carry out analytics to improve our products and services as set out above.
You have the right to object to processing carried out for our legitimate interests. See the What are your rights? section below for more information.
To comply with legal requirements relating to:
- the provision of products and services;
- data protection;
- health and safety;
- anti-money laundering;
- fraud investigations;
- assisting law enforcement; and
- any other legal obligations placed on us from time to time.
- HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
- We will keep information about you for a maximum of 7 years after the end of our relationship with you unless obligations to our regulators require otherwise or we are required to remove such data from our records.
- Telephone records. We will keep these up to 7 years from the time the recording was made.
- WHO MIGHT WE SHARE YOUR INFORMATION WITH?
For the purposes set out in the ‘Why do we collect and process this information?’ the section above, we will share your personal information with:
the following categories of third parties, some of whom we appoint to provide services, including:
business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
Customer survey providers in order to receive feedback and improve our services.
Any member of our group, which means our subsidiaries.
Additionally, we will disclose your personal information to the relevant third party:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.t
- HOW IS YOUR DATA STORED AND KEPT SECURE?
At Clever Adviser, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored securely on selected third-party servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We do not transfer your data outside the European Economic Area (“EEA”). If in future we do need to transfer your data outside the EEA, we will only do so if adequate protection measures are in place in compliance with data protection legislation.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- WHAT ARE YOUR RIGHTS?
Where processing of your personal data is based on consent, you can withdraw that consent at any time.
You have the following rights. You can exercise these rights at any time by contacting us at firstname.lastname@example.org. You have the right:
- to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
- to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
- to ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest.
- to request from us access to personal information held about you;
- to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
- to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
- to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/.