Altero Privacy Policy

Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Altero Financial Services Limited, CRN: 03466101 (“Altero Financial Services” “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through the Altero Financial Services website and the services we provide (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email.

This Policy is effective from 25 May 2018.

 

Purpose of the processing

We may process personal information about you in different ways depending on our relationship with you. Please click on the link below which most closely identifies your relationship with us:

  1. You are a client or were a client of our financial services.
  2. You are a supplier or an employee of a supplier to us.
  3. You are a third party with whom we are in contact during the delivery of services to our clients or the possible delivery of services to prospective clients.
  4. You are a prospective client or a prospective supplier.
  5. You are an employee, a former employee or a relative of either.
  6. We have received your information from a third party.
  7. Your relationship with us is not covered by any of the above.

1. Clients or former clients of our financial services

We will collect and store personal information including contact details of our clients so that we can provide our Services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us in accordance with our retention policy following completion of the contract(s) between us and after you cease to be our client so that we can review our performance if any complaints or issues arise after completion of the contract and reconcile any ongoing commission where this continues to be paid. The length of time that we keep client files will depend on the nature of the Services provided. Where we are advising our clients on a financial product or transaction, then we would usually retain a file for 80 years after conclusion of the matter. However, if relating to a pension transfer, pension conversion, pension opt-out or FSAVC the file will be retained indefinitely, in line with regulatory requirements.

We will not send you general marketing information as part of a group emailing campaign unless you have consented to being contacted in this way.


2. You are a supplier or an employee of a supplier to us.

We will collect and store personal information including contact details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of 6 years following completion of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion of the contract.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is in our legitimate interests to grow our business and explore new business opportunities with you.We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group emailing campaign unless you have consented to being contacted in this way.


3. You are a third party with whom we are in contact during the delivery of services to our clients or the possible delivery of services to prospective clients.

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our clients or discussions relating to Services to prospective clients. We may receive that information from you, a client, a supplier, an introducer or otherwise as a result of an interaction between you and our suppliers or clients.  We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our clients or engage with prospective clients with a view to establishing a contract for services. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our clients, we will also retain that information and any information relating to that contract in accordance with our file retention policy following completion of that contract(s). This is so we can comply with the Financial Conduct Regulations and so that we can review the file if any complaints or issues arise after completion of the contract. The length of time that we keep client files will depend on the nature of the Services provided. Where we are advising our clients on a financial product or transaction, then we would usually retain a file for 80 years after conclusion of the matter. However, if relating to a pension transfer, pension conversion, pension opt-out or FSAVC the file will be retained indefinitely, in line with regulatory requirements.

Where your information is stored in our contacts database but is not kept in a client or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is in our legitimate interests to grow our business and explore new business opportunities with you.   We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group mailing, emailing or telephone campaign unless you have consented to be contacted in this way.


4. You are a prospective client or a prospective supplier.

We will collect, store and use personal information including contact details of people who we might do business with as a supplier or a client for the purpose of growing our business and exploring new business opportunities. We may collect this information from you, when you contact us (including through this website) or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us. We may contact you about new business opportunities for us to work together with you and to keep you informed of our activities. 

We are processing your personal information in this way because it is in our legitimate interests to grow our business and explore new business opportunities with you.  We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

Where your information is stored in our contacts database but is not kept in a client or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

We will not send you general marketing information as part of a group mailing, emailing or telephone campaign unless you have consented to be contacted in this way.


5. You are an employee, former employee or a relative of either.

We will collect and store personal information including contact details of our employees so that we can deliver a number of employee related services, in accordance with our employment contract with you. We will also retain that information and any information relating to the contract between us in accordance with our retention policy after you cease to be an employee so that we can review our performance if any complaints or issues arise after the termination of employment. We retain employee information for the purpose of referencing for 6 years after end of employment.

Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (where we have a legitimate interest to hold that information for example in relation to sharing a Altero Financial Services car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it in connection with the relevant benefit and/or policy in accordance with this privacy policy.

Click here for our full privacy policy for employees, former employees or relatives of either.


6. We have received your information from a third party.

If we have received your personal information from a third party, for example an introducer, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.

If you become a client or a prospective client as a result of an introduction, Altero Financial Services will become a controller in relation to your personal information and the relevant sections of this policy will apply.


7. Your relationship with us is not covered by any of the above

We may hold your contact details and personal information as a result of an interaction between you and one of our employees or prospective employees. This interaction could be as a result of a potential business acquisition or disposal and/or the introduction of new business to Altero Financial Services. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties.  We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.  We carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

Where you provide us with personal information about another person
If you give us personal information about another person, you must ensure that:
(a) You are legally entitled to give us that information;
(b) the disclosure is in accordance with any applicable data protection or privacy laws; and
(c) such other person has also read this policy.

Personal information we hold
We will store contact information and the contents of any correspondence between us. We may also record or take notes during telephone calls and meetings which we will store on any applicable file.

We may also process sensitive information, for example, relating to your health. Such sensitive information will only be processed where that information is relevant to the goods or services we are providing or receiving from you. We will ask for your consent to the processing of sensitive information as part of your initial engagement with us. We may also process sensitive information in relation to your family members without their consent where that relates only to insurance business.

Some of our services provide data and document storage as an integral part of the product or solution offering. Documents and data stored by our clients may contain personal information in financial product application forms, power of attorney documents, business and personal tax forms, payroll and financial data, and other financially-related documents, for example. Any information stored by or on behalf of our clients is controlled and managed by and only made accessible to those clients, Altero Financial Services staff or others our clients may authorise from time to time.

We may be required to use and retain personal information for other legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.

When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed by us in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it. Altero Financial Services and our third-party providers set and use cookies and similar technologies to store and manage user preferences, enable content and gather analytic and usage data. For further information on our use of cookies, please see our Cookie Policy.

When we share personal information
Altero Financial Services shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

1. Within Altero Financial Services: Our business is supported by a variety of people who are part of Altero Financial Services’ teams and functions. Personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees within Altero Financial Services and any contractors are required to follow our data privacy and security policies when handling personal information. 

2. Our business partners: We occasionally partner with other organisations to deliver Services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a client of both Altero Financial Services and our partners, and we and our partners may collect and share information about you. Altero Financial Services will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information.

3. Our third-party service providers: We partner with and are supported by service providers around the UK. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; property management; and order fulfilment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.

4. Third parties for legal reasons: We will share personal information when we believe it is required, such as:

• to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
•  in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
• to protect our rights, users, systems, and Services.

Where we store and process personal information
We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.

We store information in hard copy files, which are stored in our offices and/or in archived storage space in the UK. We also store information in electronic files using cloud hosting servers on servers in the UK. We collaborate with third parties such as cloud hosting services, suppliers, and technology support to serve the needs of our business, workforce, and clients. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Altero Financial Services or to third parties in areas outside of your home country, but we will not transfer your data outside of the European Economic Area.

How we secure personal information
Altero Financial Services takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

How long we keep personal information
We retain personal information for as long as we reasonably require it for business or regulatory purposes. In determining data retention periods, Altero Financial Services takes into consideration local laws, contractual obligations, and the expectations and requirements of our clients and suppliers. When we no longer need personal information or when you request us to delete your information, where this is legal, we will securely delete or destroy it. The length of time that we keep client and supplier files will depend on the nature of the goods and services received or provided. Where we are advising our clients on a financial product or transaction, then we would usually retain a file for 80 years after conclusion of the matter. However, if relating to a pension transfer, pension conversion, pension opt-out or FSAVC the file will be retained indefinitely, in line with regulatory requirements.

Your right to access and correct your personal information
We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or safely delete your personal information.

1. Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

2. Correction, deletion, restriction or transfer: You have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion or transfer of your personal information or to restrict or object to the processing. Please note that it is not always possible to comply with such requests due to legal requirements and other obligations and factors. Remember that you can contact us about our use of your personal information by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

3. Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

4. Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know in writing, by email or by telephone.

5. Filing a complaint: If you are not satisfied with how Altero Financial Services manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk). However, firstly, we would want the opportunity to put right any concerns, therefore we ask that you raise your concerns with us initially using the “Contact Us” option on our website or let us know in writing, by email or by telephone.


Children’s privacy
Where we need to collect personal data by law such as proof of identity, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your engagement with us but we will notify you if this is the case at the time.

How to contact us
Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email:
clientservices@attivogroup.co.uk

Address:
Attn: The Privacy Officer
Attivo Group
Jessop House
Jessop Avenue
Cheltenham
GL50 3SH

Telephone:
01242 585444