This notice described how Renaissance Wealth Management (UK) Limited (“RWM”) uses personal data. It outlines RWM’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection Regulation 2016/679 (“GDPR”).
GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
RWM needs to use your personal data to provide its services to you and this notice outlines the following with regard to RWM processing your personal data:
1. Which data items are used, how they are used and who they are shared with;
2. Why this is done and the lawful basis for processing;
3. Your rights as the data subject and RWM’s obligations.
Why RWM needs to process personal data:
Your data is collected to effectively and properly manage your account(s) with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the data for several different purposes, including:
I. To provide regulatory investment services and to carry out obligations arising from agreements entered into between you and RWM;
II. To provide you with information, products or services that you request from us (including through our website) or which we feel may interest you, where you have consented to be contacted for such purposes;
III. To make our procedures more efficient, to implement security measures and to combat fraud and other crimes;
IV. To provide your data to competent authorities (including tax authorities), courts and bodies as required by law or requested, or to affiliates for internal investigations and reporting; and
V. To notify you about changes to our products and services and your investments.
RWM may collect data:
I. When you, or your agent, contacts RWM in relation to business and services offered;
II. When you complete documents or forms during the course of business with RWM;
III. From service providers and other third parties that assist us in conducting business;
IV. When you telephone RWM; and
V. When you use the RWM website or online services.
RWM stores your data on physical and electronic media. Data is safeguarded by RWM and its service providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards.
The data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our service providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all data wherever it may be held by RWM, will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your data to RWM, you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure. Although RWM will do the utmost to protect your data, we cannot guarantee the security of your data transmitted electronically and any such transmission is at your own risk.
Types of data that might be collected:
During RWM’s relationship with you, RWM will collect and process data about you, including:
I. Information which individuals and entities provide when contacting us (including through using our website) such as their names, postal addresses, telephone numbers, identification documents and e-mail addresses;
II. Corporate information;
III. Details of services provided to you;
IV. Details of purchases and redemptions of financial instruments;
V. Where permitted or required by regulators or the law, special categories of personal information such as health information or information relating to criminal convictions or offences;
VI. Detailed financial information, including investment portfolio details, income levels, taxation details, domicile and sources of income and/or wealth; and
VII. Information regarding relationships you have with bans and/or other financial institutions (including banking details).
RWM uses service providers to conduct aspects of its business (including client reporting) and your data may be disclosed to such service providers and their affiliates. Such disclosures will only be made in circumstances where necessary in order to the purpose for which you have provided such data. Such service providers may disclose such data to each other and to each other’s affiliates in order to achieve the same purposes.
RWM and its service providers may also be required to disclose your data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from RWM and its service providers, including your data. RWM and its service providers will comply with these laws to the extent required.
RWM will not sell your data to any third party. Wherever possible, service providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your data.
RWM will retain your personal data for a period of up to seven years following the point where the business relationship is ceased.
It may be necessary to retain your personal data beyond this period depending on additional legal/regulatory obligations. Thereafter, RWM will refrain from collecting any further personal data on you and shall take the appropriate steps to dispose of any record containing your personal information to the extent this is operationally feasible and appropriate.
Lawful basis for processing:
RWM assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. Given that RWM is an FCA regulated firm, the lawful basis for the processing of the majority of data is to meet RWM’s obligations to the FCA (legal obligation basis) or to fulfil its obligations to you under contract (contractual basis).
Other lawful basis may be used where RWM’s assessment finds it necessary and appropriate.
Data Subject rights:
You have the following rights, in certain circumstances, in relation to your personal information:I. Right to access your personal information (in an easily readable form);
II. Right to rectify your personal information;
III. Right to restrict the use of your personal information (in certain specific circumstances);
IV. Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the “right to be forgotten”) that applies in some contexts under GDPR is not likely to be applicable to most, if not all, of the personal information you provide to RWM, given the specific nature of the purposes for which RWM uses the data, as described above;
V. Right to object to processing of your personal information (in certain specific circumstances);
VI. Right to data portability (in certain specific circumstances);
VII. Right to withdraw consent (in certain specific circumstances); and
VIII. Right to receive information regarding any entities we disclose your data to.
Where RWM, or its service providers requires your personal information to comply with any Anti-money Laundering or other legal requirements, failure to provide this information means RWM UK will not be able to accept you as a client or investor.
RWM shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.
Changes to this notice:
RWM is required to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the RWM website (www.ukrwm.co.uk).
How to contact RWM:
Under GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.
51 Holland Street
Renaissance Wealth Management (UK) Limited
26 September 2018