Privacy Policy for Giltedge Legacy Planning

Giltedge Legacy Planning is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our services, which include personalised pension review, inheritance tax planning, retirement income strategies, investment advisory for long-term growth, defined benefit transfer advice, estate planning, financial coaching for later life, annuity and drawdown solutions, and wealth preservation. Our primary purpose is to provide comprehensive pension and retirement planning advice to individuals.

1. Information We Collect

We collect various types of information to provide and improve our services to you. This includes:

• Personal Identification Information: Name, address, date of birth, national insurance number, contact details (phone number, email address), and other identifiers necessary for financial planning and regulatory compliance.
• Financial Information: Income, expenditure, savings, investments, pension details, bank account details, tax information, and other financial data required to assess your financial situation and provide tailored advice.
• Sensitive Information: In certain limited circumstances, we may collect information about your health or other sensitive data if it is directly relevant to your financial planning needs (e.g., for certain insurance products or long-term care planning). We will always seek your explicit consent for this.
• Communication Data: Records of our correspondence and interactions with you, including calls, emails, and notes from meetings.
• Technical Data: When you access our online platform, we may collect information such as your IP address, browser type, operating system, and usage patterns. This helps us to improve our website and ensure its security.

2. How We Collect Your Information

We collect information through various methods:

• Directly from You: When you complete application forms, engage in discussions with our advisors, provide documents, or communicate with us via phone, email, or in person.
• From Third Parties: With your consent, we may obtain information from pension providers, investment platforms, financial institutions, or other professional advisors involved in your financial planning.
• Via Our Online Platform: Through cookies and similar technologies when you visit our site.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To Provide Services: To deliver comprehensive pension and retirement planning advice, including personalised pension reviews, inheritance tax planning, retirement income strategies, investment advisory, defined benefit transfer advice, estate planning, financial coaching, annuity and drawdown solutions, and wealth preservation. This involves assessing your needs, preparing financial plans, and implementing solutions.
• Client Relationship Management: To manage your account, communicate with you regarding your financial plans, and notify you of any changes to our services or relevant market developments.
• Legal and Regulatory Compliance: To comply with legal obligations, regulatory requirements (e.g., Financial Conduct Authority rules, anti-money laundering regulations), and to respond to lawful requests from public authorities.
• Internal Operations: For internal record keeping, administration, analytical purposes, and to improve the quality and security of our services and online platform.
• Marketing Communications: With your explicit consent, to send you information about services or updates that may be of interest to you. You can opt out of these communications at any time.

4. Legal Basis for Processing Personal Data

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Performance of a Contract: Processing necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (e.g., providing financial advice and managing your plans).
• Legal Obligation: Processing necessary for compliance with a legal or regulatory obligation (e.g., FCA rules, AML laws).
• Legitimate Interests: Processing necessary for the purposes of the legitimate interests pursued by Giltedge Legacy Planning or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms (e.g., improving our services, managing risks).
• Consent: Where required, we will obtain your explicit consent for specific processing activities, especially for sensitive data or direct marketing. You have the right to withdraw your consent at any time.

5. Disclosure of Your Information

We may share your information with:

• Regulatory Bodies and Authorities: To comply with legal obligations or regulatory requirements.
• Service Providers: Third-party service providers who assist us in operating our business and providing our services (e.g., IT support, compliance services, financial product providers). These third parties are obligated to protect your information and use it solely for the purposes for which we disclose it to them.
• Professional Advisors: Our auditors, legal advisors, and other professional advisors.
• With Your Consent: We will not share your personal data with any other third party without your explicit consent.

We do not sell, rent, or trade your personal information to third parties.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include encryption, access controls, secure physical storage, and regular security assessments. We also ensure that our employees are trained in data protection best practices.

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, this means holding data for a period of time after you cease to be a client, in accordance with regulatory guidelines and our internal data retention policy.

8. Your Rights

Under data protection law, you have the following rights regarding your personal data:

• The Right to Be Informed: About how your personal data is being used.
• The Right of Access: To your personal data.
• The Right to Rectification: To have inaccurate or incomplete data corrected.
• The Right to Erasure (‘Right to be Forgotten’): To request the deletion or removal of your personal data.
• The Right to Restrict Processing: To limit the way we use your personal data.
• The Right to Data Portability: To obtain and reuse your personal data for your own purposes across different services.
• The Right to Object: To certain types of processing, including direct marketing.
• Rights in Relation to Automated Decision Making and Profiling: To object to decisions being made about you solely based on automated processing, including profiling, which has a legal or similarly significant effect on you.

To exercise any of these rights, please contact us using the details provided below. We may need to verify your identity before processing your request.

9. Complaints

If you have concerns about our privacy practices, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can find their contact details on the ICO website (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any updates will be published on our online platform, and we encourage you to review this policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us at:

Giltedge Legacy Planning
4502 Cornbrook Road, Unit 3A
Manchester, Greater Manchester, M15 4QN
United Kingdom