Our Privacy Promise
- To keep your data safe and private;
- Not to sell your data; and
- To give you ways to manage and review your marketing choices at any time.
Why we need your data and what we do with it
Waverton will be what’s known as the ‘Controller’ of the personal data you provide to us. To allow us to provide you with your chosen service, we may be required to collect sensitive data. However, we will not collect any data about you that we do not need in order to provide you with a suitable and appropriate investment service.
The types of data we may collect about you include:
- your name;
- your email address;
- your address;
- your phone number;
- information about your computer (e.g. your IP address and browser type);
- information about how you use our website (e.g. which pages you have viewed, the time you viewed them and what you clicked on); and
- information about your mobile device.
You may choose to stop receiving cookies at any time through your web browser. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. Further information on deleting or controlling cookies is available at www.aboutcookies.org.
We may collect your IP (Internet Protocol) address to help to administer our Website. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.
We use Google Analytics to analyse our website usage and create reports for internal use at Waverton only.
Google Analytics Cookies
Security of information
Waverton has implemented accepted standards of security policies and controls that are aimed at protecting the personal data it has under its control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
Waverton personnel are required to keep personal information confidential and only authorised persons have access to such information.
What we do with your data
Our staff process all the person data we receive, however for the purposes of IT hosting, maintenance and regulatory reporting, this information may be stored on digital servers within the European Union. No third parties have access to your personal data unless it is necessary for them to do so in order for Waverton to provide the client with an investment service, or unless the law allows them to do so.
We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
Provision of information to third parties
A Data Processor is a third party with which we are required to share personal detail in the provision of investment services to the individual. Waverton will only share personal information in the following circumstances:
- where the transfer is necessary to fulfil the requirements of the operation for which the information was provided, and the third party is a Data Processor;
- in order to fulfil a request which involves other Data Processors;
- so as to assist Waverton’s professional advisors regarding matters referred to them concerning the operation of the Website;
- where requested explicitly by an authorised user of the Website; or
- as required by a court order or any other legal or regulatory requirement.
Waverton does not collect or compile personal data or information obtained through the Website for dissemination or sale to outside parties. Waverton does not undertake marketing activities for third parties
We may share your personal information with companies within the Waverton group and these third party organisations:
- Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business;
- HM Revenue & Customs, regulators and other authorities;
- Third parties as required through Waverton’s regulatory requirements arising from the provision of investment services;
- Fraud prevention agencies;
- Companies we have a joint venture or agreement to co-operate with;
- Organisations that introduce you to us;
- Independent Financial Advisors, or other regulated entities or parties involved in the management of your relationship with Waverton; or
- Companies you ask us to share your data with.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -
- The right to request a copy of your personal data which the Waverton holds about you;
- The right to request that Waverton corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for Waverton to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the Waverton provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data;
- The right to lodge a complaint with the Information Commissioners Office.
How long we keep your data
We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.
After you stop being a client, we may keep your data for up to 7 years for one of these reasons:
- To respond to any questions or complaints;
- To show that we treated you fairly; or
- To maintain records according to rules that apply to us.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time. If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact Waverton on 0207 484 7484 or by emailing firstname.lastname@example.org to have the matter investigated.
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 the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/
Your Acceptance of this Policy
This document was last updated on 26 April 2018.