Alderley Private Wealth Limited (‘we’, ‘us’) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (‘Policy’) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the UK General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018 (collectively ‘Data Protection Laws’), the Data Controller is Alderley Private Wealth Limited, 10 West Street, Alderley Edge, Cheshire, SK9 7EG.

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 personal data we have collected. More information about how Best Practice uses your personal data can be found in their Privacy Notice.

Your personal information

INFORMATION WE COLLECT FROM YOU

We collect and process some or all of the following types of information from you in the course of providing our services, and through your use of our website at alderleyprivatewealth.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 financial planning advice and/or ongoing servicing. The types of information we collect will vary depending on the services and products we are advising you about, but will typically include:

• Your name

• Postal address

• Email address

• Telephone number

• Date of birth

• Gender

• Bank details

• Tax identifiers (including National Insurance number and UTR)

• Information about your financial affairs, assets, liabilities, income and expenditure

• Information about your tax affairs and tax residency

• Employment and pension details

• Estate planning and family circumstances where relevant to the advice

• Other information as required by your chosen product providers or as required by our regulators

We may also collect special category personal data relating to your health, where this is relevant to the advice we are providing — for example, in connection with protection products or pension advice. This will only be collected and processed with your explicit consent.

If you contact us, we may keep a record of that correspondence. We may also collect details of your visits to our Website, including traffic data, location data, weblogs and other communication data and the resources you access.

INFORMATION WE COLLECT FROM OTHER SOURCES

Where clients are introduced to us by professional introducers (such as solicitors, accountants or other professional advisers), we may receive personal data directly from those introducers. In such cases, we will identify the source of your data and ensure you are informed of how it will be used. The data received from introducers will be of the same nature as that described above and will be held and processed in the same manner.

We will always inform you at the point of first contact if your data has been received from a third party source.

Uses made of your information

PURPOSES OF, AND LAWFUL BASIS FOR, PROCESSING

We use information held about you for the following purposes:

To provide you with our services and to carry out our obligations arising from any contracts entered into between you and us, including:

• To provide financial planning advice, investment management and ongoing servicing.

• To send you service, support and administrative messages, reminders, updates, and information requested by you.

• To respond to any enquiries you submit to us.

• To operate, protect and improve our services, our business, and our clients’ experience.

• As part of our efforts to keep our services safe and secure.

Where we have a contract with you to provide our services, and where the processing of your data is necessary to perform that contract, we rely on ‘performance of a contract’ as the lawful basis for processing. In all other circumstances we rely on ‘legitimate interests’, and our legitimate interests are the improvement of our services and/or the prevention or detection of fraud.

Where you provide us with special category data (such as health information), this will be used solely with your explicit consent to research and advise on products to suit your needs, and to assist you with applications for and management of such products. Such data may also be shared with Best Practice and relevant third-party product providers as necessary to carry out the services they provide to us.

To comply with our legal and regulatory obligations as an FCA-authorised firm, including our obligations under the Money Laundering Regulations, and preparing and sending reports and submissions to Best Practice and/or regulatory authorities such as the FCA. ‘Compliance with a legal obligation’ is the lawful basis on which we rely when carrying out these activities.

To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access it. In these circumstances we rely on ‘legitimate interests’, and the legitimate interest is the improvement of our services.

We may use your personal data to provide statistical analysis of the use of our Website via cookies. In these circumstances we rely on your ‘consent’ to our use of non-essential cookies.

Where you have contacted us via the Website, by email or telephone, we rely on ‘legitimate interests’ to respond to and contact you regarding the enquiries you have made in relation to the services we offer.

MARKETING

In addition to the above, we may use your information to notify you about services and products which may be of interest to you. If you do not want us to use your data in this way, you may: (i) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (ii) inform us at any time by contacting us at the details set out in Section 9.

Disclosure of your information

We may disclose your personal data to the following categories of recipient:

• Best Practice IFA Group Limited, who provide us with compliance, regulatory and data protection services. Best Practice is a separate data controller and details of how they use your data can be found at www.bestpractice.co.uk/best-practice/privacy-policy.

• Third-party service providers, agents and subcontractors engaged to provide services on our behalf, such as IT hosting, back-office administration and compliance support.

• Product providers, platforms and investment managers to whom we submit applications and instructions on your behalf.

• Professional introducers where relevant to the services we are providing.

• Regulatory and legal authorities, including the FCA, HMRC and law enforcement agencies, where we are required or permitted to do so by law.

We may also disclose your personal data to third parties in the following circumstances:

• In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our client agreement or service charter.

• To protect our rights, property or safety, or that of our clients or any third party we interact with.

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, or to comply with any regulatory or legal obligation, we will not share your data with third parties without your express consent.

Keeping your personal data up to date

If your personal details change, you may update them by contacting us at the details set out in Section 9, or by accessing your data through our secure client portal. We will endeavour to update your personal data within seven working days of any new or updated information being provided to us, in order to ensure that the records we hold are as accurate and up to date as possible.

How long we keep your personal data

We will hold personal data in line with our regulatory and legal obligations, as follows:

• For investment business: a minimum of 5 years from the date the relevant record was created or the relationship ended, in line with FCA SYSC and MiFID business requirements.

• For pension transfer or opt-out business: indefinitely, in line with FCA requirements.

• For AML/KYC records: a minimum of 5 years from the end of the client relationship, in line with the Money Laundering Regulations.

• For prospective clients who contact us requesting general information: up to 12 months from our last point of contact.

Different retention periods may apply to specific categories of data. We will inform you of the applicable retention period at the point of data collection where this differs from the above.

Where we store your personal data

All information that we hold about you is stored on secure servers. Where personal data is transferred to or stored at a destination outside the United Kingdom, we will take all steps reasonably necessary to ensure that it is held securely and in accordance with this Policy and applicable Data Protection Laws.

Any such transfer will be made only where appropriate safeguards are in place, including:

• The recipient being certified under the EU–US Data Privacy Framework (DPF) and having signed up to the UK Extension to that framework (where the supplier is based in the US); or

• The parties having entered into the ICO’s International Data Transfer Agreement (IDTA) or the equivalent standard contractual clauses, as applicable.

If you would like further information about transfers of your personal data outside the UK, please contact us using the details in Section 9.

Your rights

Under the UK GDPR you have a number of important rights, free of charge. In summary, these include the right to:

• Access your personal data and obtain certain supplementary information about how it is used.

• Require us to correct any mistakes in your information.

• Require the erasure of personal data concerning you in certain circumstances.

• Receive personal data you have provided to us in a structured, commonly used and machine-readable format (data portability).

• Object at any time to the processing of your personal data for direct marketing purposes.

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

• Object in certain other circumstances to our continued processing of your personal data.

• Restrict our processing of your personal data in certain circumstances.

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

For further information on each of these rights, please refer to the guidance published by the UK Information Commissioner’s Office (ICO) at ico.org.uk.

If you would like to exercise any of these rights, please contact us using the details in Section 9, providing:

• Sufficient information to identify you.

• Proof of your identity and address (for example, a copy of your driving licence or passport and a recent utility bill or bank statement).

• Details of the information to which your request relates.

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information. If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the supervisory authority in the UK. The ICO can be contacted at ico.org.uk/concerns or by telephone on 0303 123 1113.

Contact

All questions, comments and requests regarding this Policy should be addressed to:

Alderley Private Wealth Limited
10 West Street, Alderley Edge, Cheshire, SK9 7EG

Email: hello@alderleyprivatewealth.co.uk

Changes to this policy

We reserve the right to modify this Policy at any time. Any changes we make will be published on our Website. Your continued use of our services and the Website following notification of any changes shall be deemed your acceptance of the updated Policy. We encourage you to review this Policy periodically.

Information about our use of cookies

Our Website uses cookies to distinguish you from other users and to improve your experience. By using our Website, you agree to our use of cookies as set out in this section.

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

The cookies we use include:

• ‘Strictly necessary’ cookies — required for the operation of our Website, for example to enable you to log into secure areas.

• ‘Analytical’ cookies — allow us to recognise and count visitors and to see how visitors move around the Website. This helps us improve the way the Website works.

• ‘Functionality’ cookies — used to recognise you when you return to our Website, enabling us to personalise content and remember your preferences.

• ‘Targeting’ cookies — record your visit to our Website and the pages you have visited. We use this information to make our Website and communications more relevant to your interests