Privacy Notice
Titan Financial Planning Limited is committed to protecting your personal information.
This Privacy Notice contains important information about what personal details we collect, what we do with that information, who we may share it with and why, and your choices and rights when it comes to the personal information you have provided us with.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contractual obligations with you. We also have an obligation to process your personal data due to our legal obligations and our legitimate interests as a company.
The information we collect about you is essential for us to carry out the services we provide to you. Without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations.
Where special category data is required, we will obtain your explicit consent in order to collect and process this information.
What information do we collect about you?
The information we collect about you is required in order to provide our services to you. This information will relate to your personal and financial circumstances. It may also include special categories of personal data (for example, your health) if this is necessary for the provision of our services. We will collect this information from you directly through completion of our internal documentation.
Who might we share your information with?
In order to deliver our services to you, we may need to share your details with our group of companies, holding companies and any third parties such as those we engage for professional compliance, legal services or auditors as well as product and platform providers that we use to arrange financial products for you, where appropriate. We may also be required to share your personal information with our regulator, the Financial Conduct Authority (FCA).
In order to fulfil our obligations in respect of identification and residency verification, the prevention of money laundering and other financial crime, we will submit your details to third party agencies for these purposes.
We will ensure each group company and third party service provider receiving your information, understands and commits to all relevant and applicable data confidentiality obligations.
How long do we hold your information?
In principle, your personal information should not be retained for longer than is required under our contractual obligations, however, we are subject to regulatory requirements to retain this information for specified minimum periods.
You have the right to request deletion of your personal data however this will be subject to the restrictions of our regulatory requirements and legitimate interests as noted above.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA). However, some of your information may be processed by third parties we work with outside of the EEA. Where your information is being processed outside of the EEA, we take additional steps to ensure that their information is protected to at least an equivalent level as would be applied by UK/EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and systems security very seriously and we endeavour to comply with our obligations at all times. For personal information that is collected, recorded or used in any way, whether on paper, online or via any other media, appropriate safeguards will be applied in line with our regulatory data protection obligations.
Your individual rights
You have several rights in relation to how your information is used. These rights are:
Right to be Informed
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with.
Right of Access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold, you may make a data subject access request (DSAR). If you would like a copy of some or all of your information, please put your request in writing.
Right to Rectification
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 you believe to be incorrect.
Right to Erasure
You have the right to request the deletion of your personal information. We will comply with this request, subject to the restrictions of our regulatory obligations, however this will mean that we may be unable to provide our services to you.
Right to Restrict Processing
You can request that we block or suppress the processing of your personal information in certain circumstances. This means that we will still be permitted to retain your information, but only to ensure that we do not use it in the future for those reasons you have restricted. However, this may impact on the services we can provide you with.
Right to Data Portability
You can ask for a copy of your personal information for your own purposes. In certain circumstances you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
Right to Object
You can object to us processing your personal information, however this may mean that we are unable to provide our services to you.
How to make a complaint
We will endeavour to collect, use and safeguard your personal information in line with data protection regulations. If you do not believe that we have handled your personal information as set out in this Privacy Notice, please contact us and we will rectify matters where possible and appropriate.
If you are still dissatisfied, you can complain to the supervisory authority, in the UK this is the:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
www.ico.org.uk
This Privacy Notice will be reviewed and amended as applicable.