Positive Pennine is a trading style of Pennine Wealth Solutions LLP, which is authorised and regulated by the Financial Conduct Authority.
About the policy
Data protection principles
Pennine Wealth Solutions LLP adheres to the following principles when processing your personal data:
Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data minimisation – data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy – data must be accurate and, where necessary, kept up to date.
Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
What personal data we collect
We collect information about you when you engage us for Discretionary Management Services. This information will relate to your Company 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.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information.
Information we collect from third parties
We may also receive personal information from third parties who we work closely with and who are entitled to share that information, e.g. Financial Advisers and Regulators, but only as permitted by applicable law.
Information we collect online
Each time you visit Pennine Wealth Solutions website we may automatically collect the following information:
Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone settings, browser plug-in types and versions, operating systems and platforms, etc.; and
Information about your visit, including the full Uniform Resource Locators (URL) of the internet sites you came through to our websites and which pages you visited (including date and time); page response times; download errors; length of visits to certain pages; page interaction information; and methods used to browse away from the page, provided we can do so lawfully.
Sensitive personal data
We do not collect sensitive personal data. This data is defined by data protection laws and includes, a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health.
We do not knowingly collect data relating to children
Why do we need to collect 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.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use your data
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.
If you agree, we’ll pass on your personal information to our group of companies so that they may offer you their products and services.
We won’t share your information for marketing purposes with companies outside our group of companies/other companies.
Who we share your data with
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 written 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.
Transfer of data outside of the European economic area
The data we collect may be processed by our service providers operating outside the EEA. In these cases, we take step to ensure measures and controls are in place to protect your information in accordance with applicable data protection law and regulations in the UK.
Security of your personal data
The security and storage of your personal information is very important to us.
The personal information we collect from you is stored by us on secure servers, protected through a combination of physical and electronic access controls, firewall technology and other security measures.
We will not disclose any personal information, under any circumstances, unless we are satisfied that the individual requesting it has the appropriate authority.
Although we use market standard security software to protect your personal information, we cannot guarantee the security of your or your client’s data transmitted by you to our websites, secure portals, applications or services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe. We will not share this password with anyone. If you believe your account has been compromised, please contact us by any method given above so we can take additional steps to protect your personal information as appropriate.
How long we keep your data
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than deemed necessary.
You have the right to request deletion of your personal data. We’ll comply with this request, where possible, and subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the following rights:
To be informed about how we obtain and use your information;
To ask for a copy of the information that we hold about you;
To have your information rectified;
To request us to restrict processing of your personal data;
To request to have your information erased (Right to be forgotten);
To have information you provided to us, returned to you or sent directly to another company, in a structured, commonly used and machine-readable format where technically feasible (Data Portability);
Where the processing of your information is based on your consent, the right at any time to withdraw that consent; and to lodge a complaint with the Information Commissioner’s Office (ICO), the supervisory authority responsible for data protection matters.
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
0303 123 1113 (local rate)
You cannot opt out of receiving regulatory or legal information or updates (e.g. information about a change to our product terms and conditions).
If you withdraw your consent to the processing of your personal information or you ask for your information to be erased, we may not be able to provide you with access to all or parts of our website, applications, products or services. If we are not able to comply with your request, we will confirm this to you along with confirmation of the lawful basis which we will rely on to continue processing your personal data.
Your right to access personal data
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 and those of other companies in our group 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 or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work
Other websites and Social Media
How to contact us