This notice describes how Renaissance Wealth Management UK Limited (RWM UK) uses personal data. It outlines RWM UK’s data protection obligations, and your data protection rights under the Data Protection Act 2018 and other relevant data protection laws.
Our policy is to protect your privacy and your personal information. This Privacy Notice sets out the information we collect from you in order for you to use our services, how we manage that data and our reasons for holding it. We respect the confidentiality of your information and your right to privacy.
From time to time, we may update this Privacy Notice and will notify you of these changes by posting the updated terms on our website www.ukrwm.co.uk.
Collection of your data:
We may collect personal data about you from different places, including:
- directly from you;
- from someone acting on your behalf;
- from publicly available sources (such as media stories and online registers or directories) or third parties (such as credit reference agencies and fraud prevention agencies and criminal record checks); or
- where we or our designated service providers might generate such information.
We do not collect personal information from visitors to our website.
We will only collect this directly from you or someone acting on your behalf and never from a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have expressly consented to them doing so.
Our web pages and emails do not, at date hereof, contain cookies, web beacons or pixel tags, or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Should this change in future, this notice will be updated accordingly.
We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
Categories of personal data:We may collect, use and share certain categories of your personal data which include, without limitation, your:
- name, surname, date of birth, gender, postal address, phone number, email address and mobile number;
- nationality, national insurance number(s) and other national identity number(s);
- passport information or other identification information;
- tax status and tax identification number;
- employment details, proof of income (such as payslips or bank statements) and details about your personal wealth (for example your properties or investments);
- education and experience data;
- data concerning your health;
- information about criminal convictions and offences;
- corporate data;
- your trading experience and transaction history;
- bank account details and/or account balance information.
Using your personal data:
We will only use your personal data when we are allowed to do so under data protection laws in order to fulfil our legal and/or regulatory obligations, provide our contractual services to you or because we have a legitimate business interest.
RWM UK is an FCA regulated firm, the lawful basis for the processing of the majority of data is to meet RWM UK’s obligations under the FCA (legal obligation basis) or to fulfil its obligation to you under contract (contractual basis).
Sensitive personal data:
In order to meet our regulatory obligations in relation to our assessment of your investment objectives and customer vulnerability, we may collect and use your sensitive personal data, in particular information relating to your health. We will only collect this type of data from you and with your consent.
Sharing your personal data:
When we use your personal data for the purposes as set out above, we may only share it with:
- our group companies, our delegates or other appointed agents;
- any trustee, depository, stock exchange, custodian, clearing or settlement houses, market counterparty broker or other third parties contracted with us and that have agreed to be bound by appropriate confidentiality agreements;
- service providers outsourced by us for the purposes of conducting client due diligence checks and other similar checks;
- any law enforcement, regulatory and other governmental, quasi-governmental or judicial authorities;
- any introducer or financial intermediary from whom we receive your personal data;
- persons acting on your behalf, including your financial advisers, appointed representatives, agents or your bank; or
- other third parties placing reliance on us to carry out due diligence on you in connection with investments made on your behalf, including fund administrators and other entities performing a similar function in relation to your investments.
Transfer of your personal data to third parties and outside the United Kingdom:
We, or the above recipients, may transfer your personal date to third parties, both inside and outside of the United Kingdom (such as South Africa, where data privacy laws are not equivalent to those in the United Kingdom). In those instances, we will take the necessary steps to ensure that your personal data is protected in accordance with data protection laws.
You have the right to:
- receive certain information about our processing activities;
- request access which may be subject to a fee (as amended from time to time) to meet our costs in providing you with details of the personal data we hold about you;
- request the rectification, erasure or withdrawal of your personal data;
- restrict or object to the processing of your personal data;
- prevent our use of your personal data for direct marketing purposes; and
- in certain circumstances, request to transfer your personal data from us to another data controller.
If you wish to exercise any of these rights, you should contact us at:
- Renaissance Wealth Management UK Limited
- Niddry Lodge
- 51 Holland Street
- W8 7JB
Please note that in some circumstances we might not be able to comply fully with your request if it conflicts with data protection laws or other laws and regulatory obligations by which we are bound.
Security of your personal data:
We have taken, and will continue to take, the necessary steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. We will retain your personal information for only as long as required by applicable laws and regulations.
Concerns or complaints:
If you are concerned about any aspect of our conduct regarding your privacy, you can raise a concern or make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at email@example.com. We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your complaint, or you believe we have not adequately resolved the matter, you have the right to complain to the Information Commissioner’s Officer (the ‘ICO’). You can find further details on the ICO website at https://ico.org.uk/.
You also have the right, at any time, to complain to the Information Commissioner’s Office. As an independent UK authority, the ICO upholds information rights in the public interest, promotes openness by public bodies and data privacy for individuals.
Renaissance Wealth Management UK Limited is registered with the Information Commissioner’s Office, registration number ZA279879.
15 February 2024