Privacy policy
Privacy policy
1. Introduction
We are dedicated to safeguarding and preserving your privacy during our interactions with you and other parties to help achieve our goal of providing the highest quality of service to you.
This privacy policy explains what happens to any personal data that you provide to us, or that we collect from you, in accordance with the Data Protection Act 2018 and for as long as it is applicable in the UK, the General Data Protection Regulation (“Data Protection Legislation”).
Please also use the Glossary at clause 19 to understand some of the terms used in this privacy policy
2. Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our services or our website site, including any personally identifiable information you may provide when you contact us.
It is important that you read this privacy policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements any other privacy notices and is not intended to override them.
3. Controller
This privacy policy is issued on behalf of Bourlet Financial Planning Limited trading as Bourlet Consulting, so this is who we mean when we mention “Bourlet Consulting”, “we”, “us” or “our” in this privacy policy. Bourlet Consulting is the controller of any personal data you provide to us.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below
4. Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Robert Johnson
Bourlet Consulting
Hartham Park
Corsham
Wiltshire
SN13 0RP
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 (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.
5. Changes to the privacy policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We commit to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our privacy policy in order to keep it up to date and compliant with privacy and data protection principles. This privacy policy may be changed from time to time in order to keep pace with new developments and opportunities and to stay in line with prevailing legislation.
This version was last updated in July 2019
6. Information We Collect
We are committed to protecting the privacy of third parties we may interact with. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and job title or role.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account, investments, pensions and other financial data
- Technical Data includes internet protocol (IP) address, your login data, voice mail, digital messages, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
- Usage Data includes information about how you use our site, services which may include: IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Personal Data includes any other information about you including details of your family connections and any information about criminal convictions or other offences.
- Special Category Data includes information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
We also collect, use and share anonymised and aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy
7. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
8. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. you may give us your identity, contact and financial data by providing us with your data or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU; and
- search information providers based inside OR outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
9. Purposes for which we will use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you – for example to provide you with the services that you have sought from us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests – for example, we may analyse order data in order to provide a better service experience for our clients .
- Where we need to comply with a legal obligation – for example, we may pass on details of clients engaging in criminal activity to assist law enforcement.
- Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before processing any special category data or sending any third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
- Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new client | (a) Identity(b) Contact | Performance of a contract with you |
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us | (a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications | (a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to submit a review or take a survey | (a) Identity(b) Contact(c) Profile(d) Marketing and Communications | (a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services) |
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity(b) Contact(c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation |
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to monitor and improve our Site, services, marketing, client relationships and experiences | (a) Technical(b) Usage | Necessary for our legitimate interests (to define types of clients for our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications | Necessary for our legitimate interests (to develop our services and grow our business) |
10. Marketing
We will provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
- You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
- We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
- Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
11. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
- If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
- Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
12. How do We Protect Your Personal Data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We’re committed to ensuring we follow industry-standard security and privacy practices. We utilise the following methods and technologies, among others, to help protect your personal data:
- Authentication (usernames and passwords);
- Authorisation (permissions and roles);
- Firewalls (IP restrictions);
- Physical Access Control (locks); and
- Encryption (TLS).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Disclosures of your personal data
We may share your personal data with certain third parties for the purposes set out in the table above. These include the third parties described in the glossary (such as service providers or professional advisors) or third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or company
14. International Transfers of Your Personal Data
In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. If they are not part of the EU-US Privacy Shield, transfers will be protected by other appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
The hosting facilities for our site are situated in the UK or EEA.
You acknowledge that personal data that you submit for publication through our Site may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
15. Storing Your Personal Data
Data that is provided to us is stored on our secure servers and for backup purposes; data provided may be stored offsite in an encrypted format. Appropriate security measures are in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
16. Retaining and Deleting Personal Data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Details of our data retention policies are available on request.
For fraud purposes, we may retain client data indefinitely in order to adequately assess fraud risk.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
17. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EEA member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. However this will affect our ability to provide our services to you. We may be required to retain your personal data for legal or regulatory purposes but we will not use it for any other purpose.
You may exercise any of your rights in relation to your personal data by written notice
18. Third-party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.
19. Glossary
LAWFUL BASIS
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
- Service providers acting as processors based within the EEA who provide suppliers or subcontractors and provide services such as IT, delivery and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers principally based within the EEA who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.