Cadence Financial Planning Limited Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Post

Cadence Financial Planning Limited, Seven Hills House, South Street, Morley, LEEDS, LS27 8AT, GB

Telephone

01484 253067

Email

hello@cadencefp.co.uk

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Gender
• Occupation
• Date of birth
• Marital status
• Third party information (such as family members or other relevant parties)
• Payment details (including card or bank information for transfers and direct debits)
• Financial data (including income and expenditure)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Employment details (including salary, sick pay and length of service)
• Credit history and credit reference information
• Health information (such as medical records or health conditions)
• Criminal records data (including driving or other convictions)
• Video recordings
• Audio recordings (e.g. calls)
• Records of meetings and decisions
• Account access information
• Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences
• Technical data, including information about browser and operating systems

We also collect or use the following special category information for the operation of client or customer accounts. This information is subject to additional protection due to its sensitive nature:

• Health information

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Purchase or account history
• Website and app user journey information
• IP addresses

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Identification documents
• Client account information
• Health and safety information
• Any other personal information required to comply with legal obligations
• Safeguarding information

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

• Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Where we get personal information from

• Directly from you
• Regulatory authorities
• Suppliers and service providers

How long we keep information

COBS (Conduct of Business Sourcebook) data retention rules vary by record type, with common periods being a minimum of five years for appropriateness and suitability records, or three years for other suitability records. Some specific records, like those related to pension transfers, require indefinite retention, while general records of client orders and transactions must be kept for six years. All records must be retained in a way that is accessible to the Financial Conduct Authority (FCA).

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Data processors

Family Capital Limited

This data processor does the following activities for us: Principal Firm

Others we share personal information with

• Other financial or fraud investigation authorities
• Professional or legal advisors
• Regulatory authorities

Sharing information outside the UK

Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name

SEI

Category of recipient

Institutional Platform

Country the personal information is sent to

United States of America

How the transfer complies with UK data protection law

The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint