Your information, how we use it and your rights
24Keys Limited is committed to protecting your personal information.
This privacy policy explains how 24Keys Limited, and its affiliated entities, use any personal information we collect about you when you use our services or websites.
Our Privacy Policy 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 given us.
We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside 24Keys Limited. The reasons we collect and use your data are:
- To fulfil our contract to provide services to you.
- When you consent to it – when you agree for us to contact you to advise you of events, or products and services from us or other organisations.
- When we have a legal duty – to obey laws and regulations that apply to us.
- When it’s in the legitimate interest of the firm or of a third party – to run our business in an efficient and proper way.
What information do we collect about you?
We collect personal data as is required to fulfil our contract with you when you sign an engagement letter or request advice, products or services and, if you agree consent, to email you about other products and services we think may be of interest to you.
Information we may collect includes:
- Contact details – names, addresses, phone numbers, email addresses
- Financial details – employment details, bank details
- Data classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
- Open data and public records
- Documentary data – passport, drivers licence
- Information on children e.g. where a child is named as a beneficiary for Inheritance Tax planning or on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
- Information that is automatically collected e.g. via cookies when you visit one of our websites
- If you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
How do we look after your information?
We limit the amount of personal data collected to what is required to fulfil our obligations to you.
We restrict, secure and control all of our information assets against unauthorised access, damage, loss or destruction: whether physical or electronic.
We will keep your personal information while you are a client or as long as required to meet our legal or regulatory obligations. We may keep it longer if we cannot delete it for legal, regulatory or technical reasons.
With your assistance we try to maintain the accuracy of your personal data.
How will we use the information about you?
We will collect and use your information only where:
- It’s necessary to provide the service or product you have requested i.e. to fulfil the Terms of our Engagement with you
- You have given us your permission (consent) e.g. when you agree for us to contact you to advise you of events, or general communication including blogs and industry insights, or to pass on your personal information to our group of companies so that they may offer you their products and services
- It’s necessary for us to meet our legal or regulatory obligations – to obey laws and regulations that apply to us.
There may be situations where the information we require is a special category of personal data under the legislation. In this case we will explain why we need it and obtain your consent to obtain the data. This situation most commonly occurs where we are arranging life assurance products and need to obtain medical information from you.
We may share your data with these organisations but only for the reasons outlined in “How the law protects you”:
- Companies we, or you, have chosen to support us in the delivery of products and services we offer
- Our Regulators and Supervisory Authorities
- HMRC
- Law enforcement for the prevention and detection of crime
We periodically check that these third parties have appropriate safeguards in place to protect your data and that they are compliant with Data Protection Regulations.
Keeping you involved and informed
We would like to send you information about our events or general communication including blogs and industry insights, which may be of interest to you. If you have consented to receive these communications, you may opt out any time by clicking the unsubscribe link at the bottom of any email.
You have a right at any time to stop us from contacting you for these purposes or giving your information to other affiliated entities.
Website visits – how we use this data?
We may collect information about your visits to our websites such as IP address, location, browser type, referral source, length of visit and number of page views. This information may be used to improve our websites’ usability and for marketing purposes. Personal data submitted on this website could be used for the purposes specified in this privacy policy or in any relevant parts of the website.
Cookies are used on this website. A cookie is a text file sent by a web server to a web browser and stored in the browser. The file is then sent back to the server each time the browser requests a page form the server. This enables the web server to identify and track the web browser.
We may send a cookie which may be stored by your browser on your computer’s hard drive. The information we obtain from the cookie could be used to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise our website for you.
Browsers usually will allow you to refuse cookies but this could have a negative impact on the usability of many websites.
For further information visit www.aboutcookies.org or www.allaboutcookies.org.
We may provide other companies with statistical information about our users; however, this information will not be used to identify an individual user.
We will not provide any personal information to a third party unless you have given your permission.
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
Access to your information and correction
The accuracy of your information is important to us and we will update the information as appropriate. If you change your contact information please notify us and we will update our records.
You have a number of specific rights, these are summarised below:
- Access – You may ask for a copy of the information we hold about you and we will provide this within one month of receipt free of charge (we may charge a fee for subsequent or duplicate requests).
- Rectification – You may ask us to correct any information that we hold that is inaccurate or incomplete.
- Erasure – You may ask us to delete or cease processing data in certain situations. Please note that we will have regulatory obligations to retain information for certain time periods and we will retain such information as we believe is necessary to fulfil these obligations.
- Restrict processing – You may ask us to cease processing information. This means that we will be able to retain it but no longer act upon it. In the event that you no longer need our services and terminate them we will automatically cease processing information.
- Portability – You may have the right to have your data transferred to another service provider in an appropriate electronic format. Please note that we will have regulatory obligations to retain copies of the information as outlined previously.
- Objection – You may have the right to object to us processing information or using it for marketing purposes.
This is a brief summary of your rights and there may be restrictions on some of them. If you wish to explore any of these rights at any time please contact us on the addresses below and we will be pleased to assist you.
Transferring your information outside of Europe
The majority of your information is processed in the UK and European Economic Area (EEA). However, as part of the services offered to you, some of your information may be transferred to countries outside the EEA.
Where your information is being processed outside of the EEA we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. We will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
Please contact us if you have any questions about our privacy policy or information we hold about you.
Please let us know if you believe we are not holding your information correctly, if you are unhappy with how we have used your personal information or have any questions about our privacy policy or information we hold about you. Our Data Protection Officer is Andrew Blair who can be contacted at:
24Keys Limited
Little Priory
Mill Street, Prestbury
Gloucestershire GL52 3BQ
You also have the right to complain to the Information Commissioners Office. You can do this:
- via their website https://ico.org.uk/concerns
- In writing to
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.