WEBSITE PRIVACY NOTICE
Culverhouse & Co (the ‘Data Controller’) is the trading name of Culverhouse & Co Ltd and Culverhouse Financial Planning Ltd . This privacy notice explains how we use any personal information we collect about you.
Use of personal information
We will comply with GDPR data protection law. This says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
What information do we hold about you?
We collect personal contact information (such as, but not limited to, name, address, telephone number, date of birth and email address, career history plus any information you provide about your enquiry and financial situation) when you:
• Fill out one of our enquiry forms.
• Book a meeting/conversation with us.
• Subscribe to our email newsletter
• Provide us with your marketing preferences.
• Send us your CV in response to a job advertisement.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
When you browse our website, we collect statistical anonymised information about your browsing. This may include, but is not limited to, traffic data, location data, weblogs and other communication data and the resources that you access (see ‘IP addresses, cookies and web beacons’ section for further information).
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for processing of your data is to answer your enquiry or book a meeting with you if you have specifically requested this.
Also, if you consent we will use your data to make suggestions and recommendations to you about other goods and services that may interest you.
Web browsing information is used to identify our users’ browsing actions and patterns as a group and is anonymised.
If you apply for one of the job opportunities advertised, we need to collect your personal data to assess your suitability for the position applied for and so we can contact you.
How will we use the information about you?
The information you provide will allow us to:
• Answer your enquiry.
• Make suggestions and recommendations to you about other goods and services that may interest you, if you have consented to this.
• Create anonymised reports about web browsing habits.
• Contact you about your job application. Your contact details any details you provide in a CV or application form will be treated as confidential and we will not pass them on to anyone else or approach referees without your prior consent.
How will we use your information for marketing purposes?
If you agree, we may contact you about products or services that we think may be of interest to you.
If you agree, we’ll share your personal information between our companies(Culverhouse & Co Ltd and Culverhouse Financial Planning Ltd) so that they may offer you their products and services.
We won’t share your information for marketing purposes with companies outside of our own.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance or legal services as well as product and platform providers, where applicable.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. In addition, to comply with the EU’s General Data Protection Regulation we will encrypt any personal identifiable data we send to you or to third parties and will provide means for you to send any personal identifiable data to us using electronic secure messaging.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
IP addresses, cookies and web beacons
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, to improve the structure and content of our site and to report aggregate information to our advertisers and our members. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are.
A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.
Two types of cookies are used by us on our site:
Session (Transient) cookies: these cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user; and
Persistent (Permanent/Stored) cookies: these cookies are stored on your hard drive until they expire (i.e based on a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as Web surfing behaviour or user preferences for a specific site.
Session Cookies allow you to carry information across pages of our site and avoid having to re-enter information and to allow you to access stored information.
Persistent Cookies help us recognise you as a unique visitor (just a number) when you return to our website and to allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly.
Our website may contain electronic images known as web beacons which allows us to count users who have visited those pages and deliver co-branded services. Web beacons are not used to access your personally identifiable information on our site. They are a technique to compile aggregated statistics about our website’s usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view and a description of the page on which the web beacon resides.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
How long do we keep hold of your information?
In principle, if you have provided us with your personal data because you have made an enquiry about our company or the services it provides, your personal data shouldn’t be held for longer than is required to service your enquiry. Usually, this period is x months/years from the point of initial enquiry.
If you have provided us with permission to use your data for marketing purposes, we usually hold this data for 2 years from the point of submission. At this point we will ask you to update your marketing preferences.
However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate).
How to contact us
Call us on 01689 862211 or write to us at: 7 High Street, Farnborough Village, Kent, BR6 7BQ.
This notice was last reviewed on 3rd June 2019