The Purpose of this Notice
As part of our arrangement with you, Kay Capital Management has certain obligations under privacy laws, including the Data Protection Act (the “Act”) to notify individuals how it will process any personal information it collects about them. Our associated group companies (“CAERUS Capital Group”) may also be provided with personal information about you. This Notice will inform you of what personal information we collect, how that information is used, where it is transferred and how you may wish to view such information. You may be assured that we will treat all personal information as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will be taken to safeguard against unauthorised or unlawful processing and accidental loss, destruction or damage to the information.
What type of information will be processed?
We collect and process various personal data about you for the purposes of providing advice, administration and management services, which are explained in more detail below. ‘Processing’ is defined in the Act but could include obtaining, recording or holding information or data. ‘Personal Data’ is information which can identify you as a living individual, including where used in conjunction with other information. Common examples of personal data which may be collected and used by us in our day to day business activities include:
• Date of birth
• Marital status
• Telephone number and other contact details (including e-mail address)
• Job title
• Bank details and other financial details
Depending upon the types of products and services you require, the information collected and processed may also contain ‘sensitive data’ for purposes of the Act, which includes information held by us as to:
• Your physical or mental health or condition
• The commission or alleged commission of any offence by you
• Any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings
• Sexual life
• In limited circumstances, your membership of a Trade Union, your political opinions, religious or similar beliefs
Any information which we receive fairly and lawfully relating to one of the above categories constitutes sensitive personal data. Examples of likely items which may contain sensitive personal data (although this is not an exhaustive list) are life insurance questionnaires, medical reports and SSP self-certification forms.
Please note that, as with personal data, you have freedom of choice when it comes to your decision as to whether you provide us with sensitive personal data. In addition to your right to request that we stop processing your personal data and sensitive personal data at any time, you have an opportunity at the end of this Notice to choose not to provide sensitive personal data to us at all. You should however, note that if you exercise this right or subsequently request that we stop processing all or part of your personal data and/or sensitive personal data, this could impact upon our ability to provide you with certain types of product and services and may ultimately result in us being unable to provide them to you at all.
How will your personal data be collected and used?
We collect personal data from you to extent necessary to provide advice, administrative and management services and, subject to provisions below, related marketing activities.
We, or our associated group companies (“CAERUS Capital Group”) may process your personal data and sensitive personal data for the following reasons:
• the administration, management and provision of advice in relation to financial services products;
• our legitimate business process and activities including internal audit, accounting, business planning and proposed and actual transactions (including joint ventures and disposals of business); and
• compliance with legal (including dealing with claims), regulatory and other good governance obligations.
This list is not exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal data that we maintain will be kept in paper files, while other personal data will be included in computerised files and electronic databases.
Who might your personal data be shared with?
Your personal data will be made available for the purposes mentioned above and only to responsible management, human resources, accounting, audit, compliance, information technology and other corporate staff including within CAERUS Financial Limited. It may also be made available to third parties providing relevant services to us, including regulatory support.
Certain personal data will also be reported to government authorities where required by law and for tax or other purposes. Personal data may also be released to external parties as required by legislation, or by legal process, as well as to companies you authorise us to release your personal data to. We will not sell your personal data to any third party.
We and our Group Companies may wish to provide you with information about new products, services promotions and other information in which we think you may be interested. We may send you such information by postal mail, fax and telephone, unless you have registered with the appropriate Preference Service (we would be grateful if you could let us know if this is the case). If you purchase a product from us we may retain your address for future mailings. If you do not want your information used for direct marketing purposes at any time, please contact our customer services department by e-mail at firstname.lastname@example.org or by telephone on 01704 533111 to let us know and we will not send you any direct marketing.
We would also like to provide you with the above information by e-mail. However, we appreciate that e-mail ‘spam’ had become a problem in recent years. If you are a customer or you have previously asked us for information on our products:
• we may contact you regarding your purchase or other matters regarding transactions between us or your customer relationship with us or send you information on our products by e-mail, unless you have asked us not to do so; and
• we may also use your e-mail address to send you information about our products and services that we think may be of interest to you by way of informational e-mails, unless you have asked us not to do so.
A consent tick box is provided on the Confirmation of Receipt form where you should indicate your preference to receive e-mail marketing. If you decide at any time that you no longer wish to receive marketing e-mails from us, please e-mail us at email@example.com .
Your right to review and amend personal data
You have the right to review your personal data and sensitive personal data held by us and have any inaccurate information about you corrected. If you wish to do so, or to notify a change in your details, please contact The Data Protection Officer, Richard Kay, on 01704 533111 or in writing at Suite 1, 40 Hoghton Street, Southport, PR9 0PQ. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.
How to request that we cease processing of personal data
If at any time you wish us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer, Richard Kay, 01704 533111 or in writing at 40 Hoghton Street, Southport, PR9 0PQ.
By a submitting this enquiry you are confirming that you accept the terms of this Notice. Before doing so, please contact us if you have any queries or concerns regarding the contents of this Notice.