Privacy Policy

The information that we hold may be supplied by you directly to us when you register with our website LowesIM.co.uk or by communicating with us by telephone, e-mail or face to face meetings. This includes information you provide when you subscribe to our services, participate in discussion boards or other social media functions on our website, provide us with feedback, participate in surveys, and when you report a problem with our website. The information you give us may include the following; –

• your name and title, address, email address and phone number
• employment and job application details, e.g. date of birth, employment history, qualifications, equality monitoring information
• photographic identification
• in certain circumstances, your and others’ signature(s), National Insurance number(s), financial details such as bank account details and details of any relevant sanctions or similar restrictions
• in certain circumstances, data relating to health (including disabilities), ethnicity, race, religious beliefs, trade union membership and other ‘special category personal data’
• the content of any enquiry submitted over our website
• any other personal data we collect (such as the client reference number which may be assigned to you) in the context of our work for our clients or in the course of operating our business. This may include Fact Find data such as details of your assets and liabilities, income and expenditure and general information regarding your financial situation including existing protection, pension, savings and investments and estate planning provision.

We class this as being ‘personally identifiable information’, which means it can be used to identify you, personally.

If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy policy and if they have any concerns please contact us in one of the ways described below.

We will use this information:

• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
• to improve the service, we offer you and to try and ensure that you get the best from our website, ensuring that content is presented in the most effective manner for you and for the devices you use to access it;
• to allow you to participate in interactive features of our service, when you choose to do so;
• to enable us to discharge our services to you and for other related purposes including updating and enhancing client records, legal and regulatory compliance and crime prevention
• as part of our efforts to keep our website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our website about services that may interest you or them.

We may collect and process information about you through various means, including:

• via our website (e.g. on our ‘Contact Us’ page or our news and insight subscription form, submitting a job application etc.)
• in the course of carrying out work for you
• otherwise through providing our services or operating our business.

We may also collect the following information from you automatically when you visit our website:

• technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as clicks, and page-view duration), and methods used to browse away from the page and any phone number used to call our customer service number.
• We may monitor or record telephone conversations or other communications between you and us. We will use these recordings or transcripts of them to check your instructions to us, analyse, assess and improve our services to clients, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

The personal data we obtain from other sources may include the following:
• From other websites we operate or other services we provide
• From advertising networks, analytics providers and search information providers.
• From product providers: product details
• From identification and verification checking agencies: identity information and sanction check information

Cookies

A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user’s computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website. For information about our use of cookies and how to decline them please read our Cookie Policy.

We use information that you give to us or we collect from other third parties on your behalf as part of our services. We will use this information to:

• administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
• verify your identity as part of our identity authentication;
• provide you with the information and services that you request from us;
• provide you with information about other services we offer that are like those that you have already acquired or enquired about;
• provide you with information about or services we feel may interest you or be best for you;
• your data may be shared with product providers to validate if you are an existing customer or for fraud prevention purposes. The product provider does not have permission to use this data for any other purpose including marketing.
• notify you about changes to our services;
• ensure that content from our website is presented in the most effective manner for you and your device; and
• aggregate it on an anonymous basis with other data for data analytical and reporting purposes.

We will rely on the following legal bases under European Data Protection Legislation for processing your personal data:

Performance of, or entry into, a contract. The personal data that we are required to collect to comply with any other professional and regulatory obligations which apply to us must be provided to us for us to perform this contract – we would not be able to act for you without this personal data.
Compliance with a legal obligation to which we are subject.

We have a legitimate interest in doing so as a financial services provider (and where our legitimate interests are not overridden by your (or the relevant individual’s) own interests or fundamental rights or freedoms). These legitimate interests will include our interests in managing our relationship with our clients, administering visits to our offices and ascertaining achievement of proper standards/ compliance with policies, practices or procedures.  We may also act on legitimate interests in processing your information to improve our products and services.  We may periodically send promotional materials by email about new products or services, special offers or other information which we think you may find interesting.
Where processing of ‘special category data’ is necessary in the context of the establishment, exercise or defence of claims. In certain circumstances, where we need to process ‘special category data’ in the context of our agreed work and where we have obtained your express consent to do so. As we will explain at the time we collect your consent, you may withdraw it at any time in accordance with the information we provide to you at that time.

Where you have a partner residing at the same address, who is also a client of the Lowes Group with the same adviser, your accounts will be considered as one for privacy purposes. If you wish to keep your account information confidential from each other you will need to inform us in writing and separate advisers will be appointed.

Disclosure of your data to others may be necessary to ensure the smooth provision to you of services and information you request. Your data may be disclosed to the other entities as described below.

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties including:

• Fraud prevention agencies, to prevent crime and trace those responsible;
• Business partners, suppliers and sub-contractors for the performance of any contract we enter with you;
• Advertisers and advertising networks that require the data (in an aggregated format whereby individuals cannot be individually identified), to select and serve relevant adverts to you and others and to make sure their adverts reach their intended audience (for example, by telling them how many women or men have clicked on an advert); and
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.
• We may be required to share your data with our Regulator, the Financial Conduct Authority (FCA) and other third parties including auditors or insurers.

We may disclose your personal information to third parties if:

• Lowes Investment Management Ltd or substantially all its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets; and
• We are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Lowes Investment Management Ltd, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
• If you register to use any of our services, which requires us to source information from a service provider we may, in accordance with our terms share your personal data with such service providers to provide these services to you.
• Your personal data will not be sold, distributed or leased to third party organisations unless we are required to do by law or we have received your consent to do so.

We have processes and systems that protect our clients and ourselves against fraud and other crime. Information can be used to prevent crime and trace those responsible. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information.

Sending your information outside of the EEA

If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) (e.g. a professional advisor or third party engaged by us or you as part of our work under an engagement letter) for example where the transfer is necessary to perform a contract in place with you, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep these details secure and free from unauthorised access, loss or damage by use of technology and internal systems and controls. We will update the technology and our internal systems as new technology becomes available and is appropriate to our systems.

How long we keep your information for

How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for those purposes.

Third party websites

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

You have a right to be informed about the collection and use of your personal data.  We provide you with this information within this document entitled Privacy Policy.

European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.

You can access the personal information we hold on you by writing to us at: FAO: Data Protection Officer, Lowes Investment Management Limited, Fernwood House, Clayton Road, Jesmond, Newcastle upon Tyne, NE2 1TL.  You can also contact us by email at LIM@Lowes.co.uk.

You have the additional rights to request rectification and erasure of your personal data and to request restriction of, and to otherwise object to, our processing of your personal data and you can exercise these rights at any time by contacting LIM@Lowes.co.uk. There may be instances when we cannot delete your data for legal, regulatory or technical reasons.

Where technically feasible, you will also be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise this right by contacting us at LIM@Lowes.co.uk.

You have a right relating to automated decision making and profiling.  We will only carry out this type of activity if it we have an acceptable lawful basis for doing so and if certain conditions apply.  You have the right to object to profiling.

You have a right to be informed about the collection and use of your personal data.  Our Privacy notice provides information explaining our purposes for processing your personal data, our retention periods for that personal data, and who it will be shared with. We call this ‘privacy information’.

We will regularly review, and where necessary, update our Privacy Notice. Please check our website regularly to ensure you are fully up-to-date with how we deal with the information you have provided to us.

You have the right to access your personal data and supplementary information.  You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.

You can access the personal information we hold on you by writing to us at: FAO: Data Protection Officer, Lowes Investment Management Limited, Fernwood House, Clayton Road, Jesmond, Newcastle upon Tyne, NE2 1TL.  You can also contact us by email at LIM@Lowes.co.uk.

We will ask you to provide proof of identity before we show you your personal information – this is so we can prevent unauthorised access.

Information will be provided within one month of receipt of a request and an initial request for your personal data will be responded to free of charge.

Please note: For any access request made that is deemed excessive or especially repetitive, we may charge a ‘reasonable fee’ for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. (That fee will be based upon the administrative costs of providing the information).

You have the right to have inaccurate personal data rectified or completed if it is incomplete. If you have any concerns about the accuracy or completeness of your personal data, you can raise these with us either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: For any access request made that is deemed unfounded or excessive, we may charge a ‘reasonable fee’ for the administration costs of complying with the request.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

If you believe we should erase your data, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: For any access request made that is deemed unfounded or excessive, we may charge a ‘reasonable fee’ for the administration costs of complying with the request.

You can ask that we restrict our use of your personal data in certain circumstances, for example:

• where you think the information is inaccurate and we need to verify it;
• where our use of your personal data is not lawful but you do not want us to erase it;
• where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
• where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.
  
  

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

If you would like us to consider restricting or suppressing your data, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: We may refuse to comply with a request for restriction if we believe the request is unsupported or excessive, taking into account whether the request is repetitive in nature.  Alternatively, we may request a reasonable fee to deal with the request.  We will base the reasonable fee on the administrative costs of complying with the request. If we decide to charge a fee we will contact you promptly to inform you.

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

We will stop processing personal data for direct marketing purposes as soon as we receive an objection and this request will be processed free of charge.

You can exercise your rights to object at any time by contacting LIM@Lowes.co.uk.

You have the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services.  This right may apply in the following circumstances; –

• you have provided the personal data to us
• where the processing has been carried out based on your consent or for the performance of a contract and
• where the processing is carried out by automated means.
  
  

If you would like to request a transfer of data to another organisation, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: We may be unable to transmit the data directly to another organisation if this is not technically feasible.

If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision-making processes to protect your rights and freedoms.

You have a right relating to automated decision making and profiling.  We will only carry out this type of activity if it is; –

• necessary for the entry into or performance of a contract
• authorised by law
• based on your explicit consent.
  
  

In addition, if we do carry out profiling, the following conditions will apply; –

• we will use appropriate statistical procedures for the profiling
• implement appropriate technical and organisational measures to enable inaccuracies to be corrected and reduce errors; and
• secure personal data in a way that is proportionate to the risk

You have the right to object to profiling as explained above.

You can exercise this right to object at any time by contacting LIM@Lowes.co.uk.

If you are not satisfied with the level of information provided in this privacy policy, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.

If you would like to exercise any of the above rights, please:

• email or write to Data Protection Officer at LIM@lowes.co.uk or by post to Lowes Investment Management Ltd, Fernwood House, Clayton Road, Jesmond, Newcastle upon Tyne, NE2 1TL
• let us have enough information to identify you, e.g. name, address, date of birth;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.