Who are we?

Colmore Partners Limited is incorporated in England and Wales (Company No: 11350861) and is a Data Controller under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.

Colmore Partners are registered with the Information Commissioners Office (ICO) under reference ZA843894. Given the scale and nature of our operations we are not required to appoint a Data Protection Officer.

Contact Details

If you have any questions or require further information in relation to this policy please contact Kelly Howles at Colmore Partners Ltd, 23 Colmore Row, Birmingham, B3 2BS or e-mail kelly.howles@colmorepartners.co.uk.

What information do we collect?

Colmore Partners collects data from clients together with information from investment and insurance providers in order to provide clients with financial planning advice.

We collect and process some or all of the following types of information from you in the course of providing our services and other information to you and your use of our website www.colmorepartners.co.uk (“Website”)

• Information that you provide to us by any means, when you request information from us, or provide information to us with the intention of enabling us to provide you with advice and/or ongoing servicing

• The types of information that you are required to provide to us will vary depending on the products that they are advising you about, but will usually include:

• your name
• postal address;
• email address;
• telephone number;
• date of birth;
• gender;
• bank details;
• tax identifiers;
• other information as required by your chosen product providers or as required by our regulators; and
• information about your financial affairs, tax affairs, assets and liabilities;

and may also include Special Category Data relating to your health

• If you contact us, we may keep a record of that correspondence.

• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

We may process sensitive ‘special category data’ in relation to a client’s physical or mental health where the client is deemed to be a vulnerable client or if there is a power of attorney on the account or if it is required to put in place insurance.

Data is also collected from employees which is then used for payroll and HR management purposes.

How will we use the information?

Data collected for clients will be used to set up individual records on systems provided by Best Practice IFA Group Limited and to verify client identity in accordance with anti-money laundering requirement.

On an ongoing basis data collected will be used to support our contractual financial advisory services and to provide regular financial update reports to our clients. It may also be passed on to Investment Managers and Product Providers where required by them to provide their services to our clients.

Special Category Data in relation to health information is typically required for mortgage and protection advice, along with some investment advice areas such as pensions.

Colmore Partners may also, from time to time contact clients with information promoting our services, or other similar services, in which we believe clients may be interested. If, at any time, you wish to stop receiving these communications you may unsubscribe by clicking the relevant link or by e-mailing kelly.howles@colmorepartners.co.uk

How secure is your data?

Once received any data is scanned and kept in electronic form. Paper records are usually securely shredded within 4 weeks and are not kept longer than 12 months.

We have in place a separate IT security policy to protect the personal data that we hold from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss.

The policy covers who can access our network, password protocols, back up procedures and the encrypted transfer of any personal data by e-mail.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by accessing this data through the wealth platform portal, or by contacting us using the contact details above.

Who will we share the information with?

We are an authorised representative of the Best Practice IFA Group Limited (“Best Practice”), who assist us with various aspects of our compliance activity, including FCA compliance, AML checks and data protection. In order that Best Practice can provide these services, we are required to share with them personal data we have collected. More information about how Best Practice will use your personal data can be found in their Privacy Notice at https://www.bestpractice.co.uk/best-practice/privacy-policy.

There may also be occasions when we are required to share data by law e.g. the protection or detection of crime or fraud or as demanded by the FCA. If you are a Client and we receive a Subject Access Request (SAR) then your data will be passed to the Data Protection Officer at Best Practice IFA ltd who can be contacted on 01403 334455 or in writing at Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.

We do not actively transfer data outside of the EEA and will not do so without your consent. It is, however, possible that data on our IT network may be held on Microsoft cloud servers which are physically located in parts of the world outside of the EEA.

How long will we keep your information for?

We will keep your information, in electronic form, throughout the period of time that we do work for you, or have an ongoing business relationship, and afterwards for a minimum period of five years for investment business and indefinitely for occupational pension transfer or opt-out business.

Information about the use of cookies

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third party affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

Our Website may use cookies to distinguish you from other users of our Website in order to help us to provide you with a good experience when you browse our Website and also to allow us to improve the Website. By using our Website, you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use may include:

• “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

• “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

• “Functionality” cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates’ websites. We will use this information to make our Website, any offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third party affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

What rights do you have?

You have a series of rights under the General Data Protection Regulation including the right to access a copy of the information we hold about you. In summary, those include rights to:

• access to your personal data;

• require us to correct any mistakes in your information which we hold;

• require the erasure of personal data concerning you in certain situations;

• receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

• object at any time to processing of personal data concerning you for direct marketing;

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

• object in certain other situations to our continued processing of your personal data;

• otherwise restrict our processing of your personal data in certain circumstances;

• claim compensation for damages caused by our breach of any data protection laws.

Further information on your rights can be obtained from us using the contact details above. If you wish to remove your consent to us processing your data please contact Kelly Howles.

Who can you complain to if you are unhappy about what we have done with your information?

If you are unhappy about the way we are using your information then initially you should contact Colmore Partners at the above address and if your complaint remains unresolved then you can contact the ICO, details are available at www.ico.org.uk or telephone 0303 123 1113.

Changes to our Privacy and Cookies Policy

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied Privacy Policy.

Colmore Partners Limited

April 2024