Approachable Finance Limited

Introduction

This notice provides you with information concerning our collection and use of personal data. If you have any queries regarding this statement, please do not hesitate to contact us.

Legal basis

We collect, control and process your personal information because this is necessary to provide you with information, answer any queries you may have and for the provision of our services to you. Contractual necessity is therefore the lawful basis for collecting, controlling and processing your personal details and those of your employees and service providers other than sensitive personal data for which we require individual consent. We do not normally request or process any sensitive personal data.

Sensitive personal data:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Trade union membership

• Genetic data

• Biometric data

• Data concerning health

• Data concerning sex life or sexual orientation

We would discuss with you the need for the provision of sensitive data before you provide this information. It may be relevant to our advice or necessary for the underwriting of an insurance contract. The subsequent provision of sensitive personal data will be taken as consent to this processing.

Where you have disclosed sensitive personal data about an employee, we will assume that you have obtained informed consent to such sharing.

It is entirely up to you as to whether or not you choose to provide us with any personal information. If you choose not to, we simply may not be able to assist you.

We do not use your personal data for marketing purposes nor will we share your data with any other organisation for marketing purposes.

What data we collect & what do we do with it

Completing our initial enquiry form.

If you contact us via the web form on our website your data will be protected by a secure socket layer. This site is hosted at https://approachablefinance.co.uk, which is run by Rochen Ltd. We use a standard web analytics service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help to improve it. If you enter details into our webform these will be transmitted to us via email and temporarily stored on a Microsoft Hosted Exchange. The site is secured by Let’s Encrypt.

What we will do with your enquiry

Once we have responded to your enquiry your data will be continue to be held in cloud services provided by Microsoft via Office 365. Microsoft.

Doing business with us

In order to communicate with you about our services we will require your contact details including personal email addresses. Your name and email and information relating to the work we undertake for you will be stored accross our devices utilizing Microsoft processing.

All services

We collect and use information about you, which will include personal data in order for us to advise you and make arrangements for you.

Sharing your data

In order to fulfill our obligations under any contract for services we will need to share your data with third party Data Controllers and Data Processors.

Data Controllers

This will include

• Product & service providers in relation to investments, plans and pensions.

• Our compliance monitoring services.

• The Financial Conduct Authority.

• The Financial Ombudsman Service.

• Any other regulators where so required.

• Para-planning (investment research) services.

We also use external Data Processors that will hold information for the following purposes:

• Secure file sharing

• Data backup

• Dissemination of information

• Research & product sourcing

All external processors are only permitted to process your data in line with our instructions.

Data processors

Processor	Type of processing & data
CWJ Media	WordPress website hosting processes your IP address and used cookies to enhance your experience.
Let’s Encrypt	Secure socket layer – protecting the information that you input onto our website when contacting us.
Microsoft	Provides our email hosting, personal data is processed for calendar, contact and email synchronisation, One Drive secure file sharing and Office 345 software where we may process your personal data.
Dropbox	Securely sharing files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff.
Sugarsync	Securely sharing files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff. Cloud based back up service.
Iress	Research software that we use to compare insurance quotations. We enter your name and date of birth and other relevant information about you such as smoker status in order to provide quotations
Mortgage Brain	Mortgage sourcing software that enables us to compare mortgage deals. We enter your name, address, occupation, date of birth and various financial details about you.
Dynamic Planner	Software that helps us to ascertain your risk profile. We enter your name and your answers to questions around risk.

In all cases we seek to minimize the amount of personal data shared and in some cases anonomise this. It is essential, however, that we can identify you quickly and easily so information shared may be identifiable as your personal data.

We will not share your personal information in any other circumstances than those necessary for the provision of service to you or where we are required to do so by law.

Otherwise we will not share your personal information with other companies without your express authority except if the firm is sold or where we are required to do so by law.

Marketing

The information we collect about you is used solely for the purposes for which it was provided. We will never use your data or share it for marketing purposes without informing you unless we consider that we can communicate with you on the basis of legitimate interests. We will do this if we consider that a product or service that we provide might be useful to you as a business-to-business communication.

Your rights

Under data protection law you have the right to ask us for a copy of the information we hold about you, and to have any inaccuracies corrected or removed. You may also ask us to delete all personal data held by us or any controller or processor with which we have shared your data.

To do this, please either contact us in writing, by telephone or email.

Contact

For any queries about data protection please contact:

Contact name	Chris Dixon
Address	24 Main Street, Cross Hills, Keighley BD20 8TF
Telephone	0345 3503655
Web	Approachablefinance.co.uk

Where we store your Personal Data

All the data that we collect is stored on our encrypted server or back up drives in the UK or with our listed processors under contract with in the EU.

IP Addresses and Cookies

Our website uses cookies purely to enhance your experience.

(A cookie is a piece of information that is stored on your computer’s hard drive which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit.)

Vital cookies!

Ones that are essential to the operation of the website. These cookies enable a site to remember text entered in a page within the same session or to remember whether a user is logged in or not, the site cannot function without them.

Performance cookies

Performance cookies, which collect information about website usage to enhance the web experience. Examples of these include website analytics (i.e. Google Analytics) and ad-response rates (where data is collected exclusively for calculating click-through rates). They don’t collect information that can identify a particular visitor. These cookies are usually persistent and have fairly long expiry rates.

Functionality cookies

These remember the choices that users make within a web page, such as usernames, language or region to provide an enhanced, more personalised web experience. They cannot track your activity on other websites and are anonymous.

Advertising cookies

Targeting or advertising cookies collect information about your browsing habits to tailor third-party advertising to meet your interests. They are usually placed by advertisers with website operators’ permission. We do not use this type of cookie.

Any changes we may make to our privacy policy in the future will be posted on our websites where appropriate or may be notified to you by post or e-mail.