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

Robert@bourletconsulting.com

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:

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:

Technical Data from the following parties:

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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new client(a) Identity(b) ContactPerformance 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) TechnicalNecessary 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) UsageNecessary 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 CommunicationsNecessary 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.

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.

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:

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

THIRD PARTIES

YOUR LEGAL RIGHTS

You have the right to: