At Warriner & Co Limited we respect your privacy and the confidentiality of your personal information.
Warriner & Co Limited is an appointed representative of Quilter Financial Limited who is part of the Quilter Group of companies.
For further details on the companies in our group, please visit https://www.quilter.com/about-us/our-services/
The Privacy Notice explains:
Warriner & Co Limited provide financial planning solutions and advice through experienced and qualified advisers based in the UK.
Currently, Warriner & Co Limited and Quilter Financial Planning (Quilter) jointly determine the purposes and means of processing personal client data relating to giving advice. This means we're joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.
However, Warriner & Co Limited is solely responsible for some activities, for example any direct marketing that we undertake.
Personal information includes your name, address, or phone number and other information that isn't 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 reqirement and is important to help safeguard you against potential crime.
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.
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.
Advice data is retained for 50 years to meet our regulatory requirements.
Personal information will be securely disposed of when it's no longer required, in accordance with our Data Retention and Disposal Schedule. A copy of this is available using the contact details below.
The processing of your personal data is allowed under a number of lawful bases. The data required for the provision of products and services is processed on the basis there's a contract with you to do so. Any relevant marketing activity we undertake is done because, as a firm, we have a legitimate interest or do so. However. you have rights, as listed below, which impact how we can use and process your data.
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:
To investigate any complaint or enquiry raised in regards to your adviser or the advice given.
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 acqusition oe sale. Should this happen, you will be notified about any change to processing or data controller arising as a result of this activity.
We share your information with trusted third parties who perform tasks for us and help us to provide the service you require these include:
We're committed to ensuring the confidentiallity of the personal information that we hold and we continue to review our security controls and related policies ad 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 UK, 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 proven adequate safeguards.
In limited circumstances, data may be accessed outside of the UK i.e. by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.
Basic identifiers about you (e.g. your name and address) is matched with information from Experian Marketing Services to create demographics and infer customer 'types' so that Quilter Financial Planning and the Quilter group of companies can define groups based on factors like interests, age, location and more. This helps Quilter Financial Planning and the Quilter group of companies better understand our customers in order to adapt and improve our products and services.
If you would like to know more about the information we receive from Experian Marketing Services, you can visit their website https://www.experian.co.uk/privacy/consumer-information-portal/ which explains who Experian Marketing Services are, what they do and why.
Warriner & Co Limites 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 daya protection rights can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have the right to opt out of receiving marketing information and tell us what your communication preferences are by contacting Quilter Financial Planning using the details provided at the end of this notice. You may opt outat any time if you don't want to receive any further communications of this nature.
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 address or email listed below.
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. Quilter will liaise with Warriner & Co Limited on your behalf to effect your requests.
The Office of Data Protection
Quilter Financial Planning Limited
85 Queen Victoria Street
London EC4V 4AB
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're not processing your personal data in accordance with the law, you can complain to our regulator:
Information Governance Department
Information Commissioer's Office
0303 123 1113