It describes how we collect, use and process personal information, and how we keep to our legal obligations to you when doing so. Your privacy is important to us and we are committed to protecting your rights.
For the purpose of the relevant data protection legislation (including the General Data Protection Regulation (Regulation (EU) 2016/679) (the ‘GDPR’) we, Juno Wealth Management of 1b Stairbridge Court, Stairbridge Lane, Bolney, West Sussex, RH17 5PA, are responsible for your personal information.
Juno Wealth Management Ltd is a company registered in England and Wales (company number 07145500) and we are authorised and regulated by the Financial Conduct Authority under firm reference number is 652263.
The GDPR was introduced by European regulators to make sure data protection laws (those that oversea how your personal information is handled) are fit for purpose and consistent across Europe. The GDPR came into effect on 25th May 2018, and any references we make to it include any national legislation that puts it in place.
What information do we collect about you?
We collect information about you when you engage us for financial planning, financial advice and investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
When we collect and store your personal data, we are responsible as a data controller of that personal data for the purposes of the GDPR.
Information about connected individuals
We may need to gather personal information about your close family members and dependents in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Special categories of personal data: there are certain categories of personal data that are sensitive by nature. The categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain your sensitive personal data particularly in relation to health. Our policy is that should we require any special category of personal data we will only collect and process this information with your explicit consent.
We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, to meet our regulatory obligations, for training purposes, for crime prevention and to improve the quality of our customer service.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you and to provide generic updates relating to financial services and news about our company.
We won’t share your information for marketing purposes with other companies, other than the company that supplies our email marketing system.
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, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
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 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.
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.
The table below shows the reasons why we collect and store your personal date, the lawful basis for doing so and the third parties that we may share your information with:
We place great importance on protecting your personal information, and we have appropriate business measures in place to prevent anyone having unauthorised access to it or misusing it.
How do we protect your personal information?
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment busines
- Indefinitely for pension switches, pension transfers and pension opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain your data indefinitely, where we believe it’s in our legitimate interests to do so and this could be when any advice has been given or a regulated product sold.
Where we hold personal data in relation to an enquiry for our services and where no further information was gathered we will retain your data for up to one year from our last contact.
Where we hold personal data relating to an enquiry for our services where further personal data about you was gathered but no advice provided, we will retain your data for up to three years from our last contact
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.
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you do not want us to use your information for marketing purposes contact us directly by emailing firstname.lastname@example.org or use the unsubscribe functionality provided at the bottom of our marketing emails.
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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
Or write to us at Juno Wealth Management Limited, 1b Stairbridge Court, Stairbridge Lane, Bolney, West Sussex, RH17 5PA.