Privacy Policy | Ermin Fosse

Privacy Notice

This Privacy Notice sets out how we, Ermin Fosse Financial Management LLP (the Company) processes your personal data, and your rights in relation to the personal data we process. In this Privacy Notice, “us”, “we” and “our” refers to the Company.

The Company is the data controller of your personal data and is subject to the Data Protection Act 2018 (“DPA”) and to the UK General Data Protection Regulations.

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of it, with which you may have been provided, or had sight of, before the date stated below, as well as anything to the contrary contained in any agreement with us.

This Privacy Notice is effective from 25th January 2021.

1 Purposes of the processing

We collect and process personal data about you throughout, and following the end of, our relationship with you. How we collect your data and the purposes of the processing depend on the nature of our relationship with you. Please refer to the section below that applies to you:

You are, or were, a client of Ermin Fosse Financial Management LLP

We will collect and process:
- Your name, contact information and personal details
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details
- Information about your knowledge and experience in the investment field
- An understanding of your goals and objectives in connection with your wealth
- Information about your employment, education, family or personal circumstances, and interests
- Information or background checks to assess whether you may represent a money laundering risk, for example, whether you are a Politically Exposed Person
- Information concerning your health where relevant to services we provide and we will obtain your explicit consent to process this type of data

We will collect and process your data because it is necessary for the performance of a contract to which you are a party.
We will collect your personal data:
- through information you provide on application or other forms
- from your agents, intermediaries, insurance companies, fund managers, investment managers and custodians of your assets
- from publicly available sources, or from third parties, where we need to conduct background checks on you
from the information you provide to us when you meet with one of our Partners or other employees
We will retain any data for 80 years post termination of our contract with you.

You are a prospective client of Ermin Fosse Financial Management LLP

We will collect and process:
- Your name, contact information and sufficient personal details to determine whether we will progress our relationship
We will collect and process your data because it is in our legitimate business interests to pursue new business opportunities.
We will collect your personal data:
- from the information you provide to us through our website or by email or telephone when you first contact us
- from the information you provide to us when you meet with one of our Partners or other employees
If you do not proceed to become a client of ours, we will retain your data for up to 3 years.

You are an associate of a prospective client, existing client, or former client of Ermin Fosse Financial Management LLP

We will collect and process:
- Your name, contact information and personal details
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth
- Information about your employment, education, family or personal circumstances, and interests
- Information concerning your health where relevant to services we provide to our associated client
We will collect and process your data because it is necessary for the performance of a contract with our client, so it is in our legitimate business interest to do so.
We will collect your personal data:
- from a third party to whom you have given permission to provide us with that data during the course of our relationship with them
We will keep your data for 80 years (where you are an associate of a client or former client) and for up to 3 years where you are an associate of a prospective client.

If you are providing data on a party associated to you, you must ensure that you are entitled to provide that information to us and that the third party has read this privacy notice.

You are a prospective employee of Ermin Fosse Financial Management LLP

We will collect and process:
- Your name, contact information and personal information (such as date of birth, right to work documentation)
- Information relating to your employment history, previous salaries and qualifications
- Reference information from previous employers and from background checks
- Any other information that you provide to us during the application process
We will collect and process your data because it is in our legitimate business interests to gather all information necessary to make an informed decision on whether to offer you an employment contract with us
We will collect your personal data:
- from information you provide when you first contact us and throughout the recruitment process
We will keep your data for up to 5 years following the end of the recruitment process or application.

You are a supplier or a former supplier of services to Ermin Fosse Financial Management LLP

We will collect and process:
- Your name and work-related contact details
We will collect and process your data because it is needed to fulfil our contract with you
We will collect your personal data:
- from information you provide during the course of our business relationship

You are an existing or prospective client and you access our website and/or subscribe to our periodic newsletter

We will collect and process:
- Your email address
- Your name and contact details
- Information about your computer (your IP address and browser)
- Information about your use of our website
- Information about your mobile device (such as geographical location)

Further information can be found in our Cookies policy here.

We will collect this data because it is in our legitimate business interests to pursue new business opportunities or if you are an existing client it is to provide a service to you in line with our contract
We will collect your personal data:
- When you provide it to us through the use of our website
If you subscribe to our newsletter you have the option to unsubscribe from the mailing list at any time

We may record the video and/or audio of online meetings that we hold with you. We will store recordings on our servers and retain the recordings in line with the appropriate retention policy.

We record and store all telephone calls and these recordings are retained for 12 months.

In addition to the specific legal bases described above, we may also process your personal data because it is necessary for our legitimate interests.

In this respect, we may process your personal data for the following:

Training our staff or monitoring their performance including through the recording, storage and monitoring of telephone calls
For the administration and management of our business, including recovering money you owe to us
Seeking advice on our rights and obligations, such as where we require our own legal advice.

We may also process your data for our compliance with a legal obligation which we are under.

In this respect, we may use your personal data for the following:

To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws, and where we are required to monitor, record or store telephone conversations.

2 Sharing your data

We will only share your data with third parties to the extent necessary to run our business, to fulfil any contracts with you, where it is in our legitimate interest, where required by law, or to enforce our legal rights. We may share your data with the following:

Your advisers, agents, intermediaries, insurance companies, fund managers and investment managers and custodians
Third party administrators who we may engage to assist in delivering the services to you
Our advisers where it is necessary for us to obtain their advice or assistance
Other third parties such as intermediaries, insurance companies, fund managers or investment managers, custodians & brokers who we introduce to you
Our data storage providers including storage of telephone recordings
Our back-office system provider, Intelliflo which provides the Intelligent Office software
IT and web development service providers
A third-party marketing platform, Mailchimp, for the delivery of our e-newsletter
Third party HR, accountancy and compliance service providers
With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business
Our auditors where it is necessary as part of their auditing functions
With third parties who assist us in conducting background checks
With relevant regulators or law enforcement agencies, where we are required to do so.

Most of your data is processed in the UK and the European Economic Area (EEA). We may process some of your data in other countries such as the USA and India. Where we process your data outside of the UK or the EEA, we will ensure that your data is protected to at least an equivalent level as would be applied by the UK or EEA data privacy laws.

3 Your rights

You have the following rights in respect of any of your personal data that we hold

Right to be informed - about the collection and use of your personal data
Right of access - to obtain access to, and copies of, the personal data that we hold about you
Right to rectification - to have inaccurate data held about you rectified or completed if it is incomplete
Right to erasure - to require us to erase your personal data
Right to restrict processing - to require us to restrict our data processing activities
Right to data portability - to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller
Right to object - to object to the processing of your data in certain circumstances

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights under data protection legislation at www.ico.org.uk

4 Protecting your data

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

5 Children’s privacy

We may collect personal information relating to children under the age of 13 as part of the advice process being provided to a related family member or guardian. We will not collect personal information directly from children under the age of 13.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer using the following:

By post The Privacy Officer, Ermin Fosse Financial Management LLP, 55 Dyer Street, Cirencester, Gloucestershire GL7 2PP

By email info@erminfosse.co.uk

By telephone 01285 649200

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner (www.ico.org.uk).