Privacy Policy

Background

DB Wealth Planning & Preservation Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About [Us] OR [Me]

DB Wealth Planning & Preservation Ltd.
Registered in England under company number: 09462056
Registered address: F4 Worth Corner, Turners Hill Road, Crawley, RH10 7SL
Main trading address: As above.
Data Protection Officer: Doug Bennett.
Email address: dougbennett@dbwpp.co.uk
Telephone number: 01293 889377.
Postal Address: F4, Worth Corner, Turners Hill Road, Crawley, RH10 7SL

2. What Does This Notice Cover?

This Privacy Information explains how [we] OR [I] use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that [we] OR [I] use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which [we] OR [I] will always work to uphold:

a) The right to be informed about [our] or [my] collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact [us] OR [me] to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data [we] OR [I] hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by [us] OR [me] is inaccurate or incomplete. Please contact [us] OR [me] using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask [us] OR [me] to delete or otherwise dispose of any of your personal data that [we] OR [I] have. Please contact [us] OR [me] using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to [us] OR [me] using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to [us] OR [me] directly, [we] OR [I] am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] OR [me] for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. [[we] OR [I] do not use your personal data in this way] OR [Part 6 explains more about how [we] OR [I] use your personal data, including [automated decision-making] AND/OR [profiling]].

For more information about [our] OR [my] use of your personal data or exercising your rights as outlined above, please contact [us] OR [me] using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about [our] OR [my] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

[We] OR [I] may collect some or all of the following personal data (this may vary according to your relationship with [us] OR [me]):

  • [Name;]
  • [Date of birth;]
  • [Gender;]
  • [Address;]
  • [Email address;]
  • [Telephone number;]
  • [Business name;]
  • [Job title;]
  • [Profession;]
  • [Payment information;]
  • [Information about your preferences and interests;]
  • [Financial information – e.g. details regarding your assets and liabilities.]
6. How Do You Use My Personal Data?

Under the GDPR, [we] OR [I] must always have a lawful basis for using personal data. This may be because the data is necessary for [our] OR [my] performance of a contract with you, because you have consented to [our] OR [my] use of your personal data, or because it is in [our] OR [my] legitimate business interests to use it. Your personal data [will be used for] OR [may be used for one of] the following purposes:

  • [Providing and managing your account.]
  • [Supplying [our] OR [my] [products] AND/OR [services] to you. Your personal details are required in order for [us] OR [me] to enter into a contract with you.]
  • [Personalising and tailoring [our] OR [my] [products] AND/OR [services] for you.]
  • [Communicating with you. This may include responding to emails or calls from you.]
  • [Supplying you with information by [email] AND/OR [post] that you have opted-in to (you may unsubscribe or opt-out at any time by emailing office@dbwpp.co.uk).]

[With your permission and/or where permitted by law, [we] OR [I] may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on [our] OR [my] [products] AND/OR [services]. You will not be sent any unlawful marketing or spam. [We] OR [I] will always work to fully protect your rights and comply with [our] OR [my] obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]

7. How Long Will You Keep My Personal Data?

[We] OR [I] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • Data will be kept indefinitely or until you notify us you no longer wish us to have your data on our files;
8. How and Where Do You Store or Transfer My Personal Data?

[[We] OR [I] will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.]

 

Please contact [us] OR [me] using the details below in Part 11 for further information about the particular data protection mechanism used by [us] OR [me] when transferring your personal data to a third country.]

The security of your personal data is essential to [us] OR [me], and to protect your data, [we] OR [I] take these important measures, including the following:

  • Our website is fully encrypted with SSL security.
9. Do You Share My Personal Data?

[[[We] OR [I] may share your personal data with other companies in [our] OR [my] group for future financial advice. This includes [subsidiaries] AND/OR [[our] OR [my] holding company and its subsidiaries.]]

[[We] OR [I] may sometimes contract with the following third parties to supply [products] AND/OR [services] to you on [our] OR [my] behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that [we] OR [I] hold.

  • Growth by Design Limited (marketing agency – “Data Processor”) for the purpose of email communication connected to education of services/products provided/available from us and case studies relevant to service/products available, free guidance/helpful resources. Growth by Design Limited is a company registered in England and Wales under number 10328235 whose registered office is at 14 More House Business Centre, Ditchling Road, Wivelsfield, East Sussex, RH17 7RE.

If any of your personal data is required by a third party, as described above, [we] OR [I] will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, [our] OR [my] obligations, and the third party’s obligations under the law, as described above in Part 8.]

[If any personal data is transferred outside of the EEA, [we] OR [I] will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.]

In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

10. How Can I Access My Personal Data?

If you want to know what personal data [we] OR [I] have about you, you can ask [us] OR [me] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] OR [me] everything [we] OR [I] need to know to respond to your request as quickly as possible.]

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] OR [my] administrative costs in responding.

[We] OR [I] will respond to your subject access request within 14 days and, in any case, not more than] one month of receiving it. Normally, [we] OR [I] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] OR [I] receive your request. You will be kept fully informed of [our] OR [my] progress.

11. How Do I Contact You?

To contact [us] OR [me] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Doug Bennett]:

Email address: office@dbwpp.co.uk.

Telephone number: 01293 889377.

Postal Address: F4 Worth Corner, Turners Hill Road, Crawley, RH10 7SL.

12. Changes to this Privacy Notice

[We] OR [I] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] OR [I] change [our] OR [my] business in a way that affects personal data protection.

Any changes will be made available at www.dbwpp.co.uk.