Our ...

Privacy Policy

Introduction

Jackson Jeffrey Financial Services Limited (“we”, “us”, or “our”) are committed to respecting and protecting your privacy. This Privacy Policy (the “Policy”) explains how we will collect, store and use any personal data you provide via our website, email or networking with our Directors and when you otherwise communicate with us (including in the course of the financial services we provide or the running of our business).

Our details are as follows:

• Data controller: Jackson Jeffrey Financial Services Ltd, 44 Cygnet Court, Timothy’s Bridge Road, Stratford-upon-Avon, Warwickshire, CV37 9NW. ICO Registration No Z1893980.

This Policy may change from time to time and, if it does, the up-to-date version will always be available on our website and becomes effective immediately.

Please take the time to read this Policy, which contains important information about the way in which we process personal data.

For the purposes of this Policy, “European Data Protection Legislation” is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 2018) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”) or any equivalent legislation amending, supplementing or replacing the GDPR.

Information we may collect about you

We may collect and process information about you and your personnel through various means, including:

• in the course of providing our financial services to you or your business
• via our website (e.g. on our ‘Contact Us’ page or our newsletter subscription form, submitting a job application etc.)
• by email or other electronic correspondence
• by telephone
• external events (e.g. at industry or client events and/or other meetings or events hosted or attended by us)
• otherwise through providing our services or operating our business.

The personal data you give to us may include:

• your name and title
• contact information, including telephone number, postal address and email address
• information relating to your location, preferences and / or interests
• photographic identification, your and others’ signature(s), National Insurance number(s) and financial details including bank account details
• in certain circumstances, data relating to health (including disabilities) and other ‘special category personal data’
• the content of any enquiry submitted over our website
• employment and job application details, e.g. date of birth, employment history, qualifications, equality monitoring information.
• any other personal data we collect (such as the client reference number which may be assigned to you) in the context of our work for our clients or in the course of operating our business

Each time you visit our website, we may automatically collect the following information:

• Web usage information (e.g. IP address), browser type and version, time zone setting, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).

We may ask you for information when you report a problem with our website.

If you contact us, we may keep a record of that correspondence.

Cookie Policy

Our website uses cookies to distinguish you from other users, to improve your experience on our website, and, to recommend content that may be of interest to you. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Some of our website pages contain links to third party sites for example, LinkedIn and the Pensions Regulator. To control third party cookies, you can adjust your browser settings.

How we will use your information

We may use your information for the following purposes:

• to respond to any query that you may submit to us
• to manage our relationship with you (and/or your business), including by maintaining our database of clients and other third parties for administration, and accounting and relationship management purposes
• to complete our contractual obligations to you, or otherwise taking steps as described in our engagement terms and/or our Retail Client Agreement (including any associated administration)
• to carry out any relevant conflict checks, anti-money laundering and sanctions checks and fulfilling our obligations under any relevant anti-money laundering law or regulation (including under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017)
• to send you any relevant information on our services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent to do so or we are otherwise able to do so in accordance with applicable European Data Protection Legislation:-

– to process any job application you (or your representative) has submitted

– to ensure that our website’s content is presented in the most effective manner for you and your device

– to customise our website according to your interests

– to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses

– to allow you to participate in interactive features on our website when you choose to do so

– as part of our efforts to keep our website safe and secure

– to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you

– to ensure we appropriately administer any attendance / visits to our offices

– to comply with any other professional and regulatory obligations which apply to us or policies that we have in place

– as we feel is necessary to prevent illegal activity or to protect our interests.

Legal grounds for processing your information

We will rely on the following legal bases under European Data Protection Legislation for processing your personal data:

• Where you have provided your consent for to our processing your data for one or more specific purposes;
• Performance of, or entry into, a contract. The personal data we are required to collect in order to comply with any professional and regulatory obligations which apply to us must be provided in order for us to perform this contract. We will not be able to act for you without this personal data.
• Legal Obligation. In order to comply with a legal obligation to which we are subject.
• We have a legitimate interest in doing so as a financial services provider (and where our legitimate interests are not overridden by your own interests or fundamental rights or freedoms).

As we will explain at the time we collect your consent, you may withdraw it at any time in accordance with the information we provide to you at that time.

Sharing your information

We may share your details with carefully selected third parties. These may include service providers, support services and organisations that enable us to fulfil our contractual obligations to you and/or our clients in the course of business.

If we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the European Data Protection Legislation.

We may disclose your information to third parties when:

• you specifically request this or it is necessary to provide our financial services to you;
• we feel other companies’ products and services may interest you (only if we have your consent to this);
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of our website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The third parties include:

• our preferred Product Providers & Investment Houses (including as permitted by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 which, for the purposes of preventing money laundering or terrorist financing, may require us to disclose your personal data)
• our insurers
• our auditors, including external accreditation bodies
• other professional advisors or third parties (including accountants & technical experts) with whom we engage as part of our work for our clients or who our clients separately engage in the same context
• our Regulator, the Financial Conduct Authority (FCA)
• our data processors providing email security, data governance and other IT and business support services
• our email marketing platform provider and our website platform provider
• analytics and search engine providers that assist us in the improvement and optimisation of our website
• any third party you ask us to share your data with.

Our website may, from time to time, contain links to and from the websites of advertisers and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We will not rent or sell our users’ or other contacts’ details to any other organisation or individual.

Storage and retention of your personal data

We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on our website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot absolutely guarantee the security of your data.

We will keep your information stored on our systems for as long as it takes to provide the services to you and in accordance with our Terms of Business. We may keep your data for longer than our stated retention period if we cannot delete it for legal, regulatory or technical reasons.

Any contact details stored on our client relationship management database will be removed from our mailing lists if they do not interact with our emails (i.e. open emails or click on links within them) for a certain period following which they will be moved to an archive folder before being deleted permanently.

The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

We will, subject to paragraph 7.2, not store your information for longer than is reasonably necessary or required by law.

Sending your information outside of the EEA

If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) (e.g. a professional advisor or third party engaged by us or you as part of our work under an engagement letter) we will ensure we do so in compliance with European Data Protection Legislation, including where applicable by ensuring that the transfer is necessary to perform a contract in place with you or a contract entered into in your interests. If these transfers affect you, you may contact us to obtain more precise information and a copy of relevant documentation.

Withdrawal of consent

Where we process your personal data we do so on the basis that you have provided your consent for us to do so for the purposes set out in this Policy when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at justask@jjfsltd.com or via the web form on our Contact Us page.

If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.

Your rights

European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.

You can access the personal information we hold on you by writing to us at: FAO: Data Protection Officer, Jackson Jeffrey Financial Services Limited, 44 Cygnet Court, Timothy’s Bridge Road, Stratford-upon-Avon, Warwickshire, CV37 9NW. You can also contact us by email at justask@jjfsltd.com  or by completing our web form via our Contact Us page.

We will ask you to provide proof of identity before we show you your personal information – this is so we can prevent unauthorised access.

Please note: For any access request that is deemed excessive or especially repetitive, we may charge a ‘reasonable fee’ for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. (That fee will be based upon the administrative costs of providing the information).

You have the additional rights to request rectification and erasure of your personal data and to request restriction of, and to otherwise object to, our processing of your personal data and you can exercise these rights at any time by contacting our Data Protection Officer or by completing our web form via our Contact Us page.

You are also entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise this right by contacting us by writing to Data Protection Officer, Jackson Jeffrey Financial Services Ltd, 44 Cygnet Court, Timothy’s Bridge Road, Stratford-upon-Avon, Warwickshire, CV37 9NW or by email at  justask@jjfsltd.com or completing our web form via our Contact Us

Complaints

If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.

You also have the right to make a complaint to the Information Commissioner’s Office. For more details please visit the ICO website at ico.org.uk.

Contact

Questions, comments and requests regarding this Policy should be addressed to our Data Protection Officer:

Name: Helen Jeffrey
Address: Jackson Jeffrey Financial Services Ltd, 44 Cygnet Court, Timothy’s Bridge Road, Stratford-upon-Avon, Warwickshire, CV37 9NW.
Email address: justask@jjfsltd.com
Telephone number: 01789 263257