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Our Privacy Policy & Data Protection Notice

Aqua Sulis Financial Management Ltd are committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently. 

Aqua Sulis Financial Management Ltd are appointed representatives (AR) of Intrinsic Financial Services Ltd (IFS) who are authorised and regulated by the Financial Conduct Authority (FCA).   IFS are part of Old Mutual Wealth UK.

This Privacy Notice explains:  

WHO WE ARE

Aqua Sulis Financial Management Ltd provide financial planning solutions and advice through experienced and qualified advisers based in the UK.

Currently Aqua Sulis Financial Management Ltd and IFS jointly determine the purposes and means of processing personal client data relating to giving advice.  This means we are joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.  

However, Aqua Sulis Financial Management Ltd is solely responsible for some activities, for example any direct marketing that we undertake.

WHAT PERSONAL INFORMATION WE COLLECT

Personal information includes your name, address, or phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial advisor, visit a website we may have or register to receive one of our newsletters (if applicable).

The type of personal information we collect will depend on the purpose for which it is collected and includes:

We collect personal information directly from you.  For example, we ask for personal information at the start of our relationship and in subsequent communications in order to check your identity, and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.

SPECIAL CATEGORY INFORMATION

In some instances, it is necessary to collect more sensitive information (such as health or lifestyle information) which is called special category data.  This is to allow us to provide our financial advice service to you.  We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely.  You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.

COOKIES 

We also collect information about you from other sources. For example, our website automatically collects information from your computer using “cookies” which provides us with limited personal information.  Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners. For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result. 

DATA RETENTION

We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements.  Personal information will be securely disposed of when it is no longer required, in accordance with our Data Retention and Disposal Schedule.  A copy of this is available using the contact details below.

ON WHAT BASIS DO WE COLLECT DATA

The processing of your personal data is allowed under a number of lawful basis.  The data required for the provision of products and services is processed on the basis there is a contract with you to do so.  Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so however you have rights, as listed below, which impact how we can use and process your data.

HOW WE USE YOUR PERSONAL INFORMATION

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements.  This includes the following:

We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we process your information to send you marketing that is tailored to your interests.

Our business purposes include the following:

You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

We may also process your personal data as part of an acquisition or sale.  Should this happen, you will notified about any change to processing or data controller arising as a result of this activity.

WHO WE SHARE YOUR INFORMATION WITH AND WHY

We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include: 

HOW WE KEEP YOUR INFORMATION SECURE

We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure. 

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

If we work with third parties in countries outside the EU we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.  

In limited circumstances data may be accessed outside of the EEA ie by employees when they travel.  In these circumstances we ensure there are appropriate information security measures in place to safeguard your information.

YOUR RIGHTS 

Aqua Sulis Financial Management Ltd tries to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below.  This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

MARKETING 

You have the right to opt out of marketing information and tell us what your communication preferences are by contacting IFS using the details provided at the end of this notice or by using the opt out option below or on any email marketing. You may opt out at any time if you don’t want to receive any further communications of this nature.

INDIVIDUAL DATA RIGHTS AND REQUESTS

The purposes of the processing;

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the number/address listed below.

HOW TO CONTACT US

If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details. Aqua Sulis Financial Management Ltd will liaise with IFS on your behalf to affect your requests.   

The Office of Data Protection, Intrinsic Financial Services Group, Wiltshire Court, Farnsby Street, Swindon SN1 5AH

HOW TO COMPLAIN

If you wish to raise a complaint about how we have handled your personal data, you can contact The Office of Data Protection who will investigate the matter. 

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to our regulator:

Information Governance department, Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel: 0303 123 1113

www.ico.org.uk/concerns

CONSENT TO GATHER SPECIAL CATEGORY DATA

As detailed above, in some instances, it is necessary for us to collect more sensitive information (such as health or lifestyle information) which is called special category data. This is to allow us to provide our financial advice service to you.  This is where we need to gather your consent to the collection and processing of this data. You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer access the service or product the information was gathered for.

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ELECTRONIC MARKETING

We may want to send you relevant marketing electronically from time to time. If you do not wish to receive electronic marketing then please tick the box below to opt out. 

Aqua Sulis Financial Management Ltd is an Appointed Representative of CAERUS Financial Ltd which is authorised and regulated by the Financial Conduct Authority.

© 2018. Reg’d in England & Wales No. 11119852. Reg’d Address: The Island House, The Island, Midsomer Norton, Radstock, BA3 2DZ   

COOKIE POLICIES  |  TERMS

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Aqua Sulis Financial Management Ltd is an Appointed Representative of CAERUS Financial Ltd which is authorised and regulated by the Financial Conduct Authority.

© 2018. Reg’d in England & Wales No. 11119852. Reg’d Address: The Island House, The Island, Midsomer Norton, Radstock, BA3 2DZ  COOKIE POLICIES  |  TERMS

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