Privacy policy.

CUSTOMERS AND SUPPLIERS PRIVACY POLICY

 

  1. GENERAL

    • Nautilus Asset Management (“we” “us” “our”) is committed to protecting and respecting your privacy. We are the data controller and will process your personal data in accordance with the Data Protection Act 1998 as amended or replaced by the General Data Protection Regulation 2016 and any national laws which relate to the processing of personal data (“data protection legislation”).

    • Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it.

    • Financial Solutions Group Limited is registered with the Information Commissioner’s Office (ICO) under Registration Number ZA227219. Nautilus Asset Management is trading name under this Registration. You can verify this information here

    • During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship. 

      We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

      •   Five years for investment business

      •   Three years for mortgage business

      •   Indefinitely for pension transfers and opt-out business

      •   Three years for insurance business

      These are minimum periods, during which we have a legal obligation to retain your records.

      We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so, for example, to respond to questions or complaints about the service or advice we have provided to you. 

    • What can you do if you are unhappy with how your personal data is processed?

       

      You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

      Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

This policy applies to information we collect about:

  • Visitors to our website

  • Customers

  • Introducers

  • Suppliers

 

  1. VISITORS TO OUR WEBSITE

    • We may collect and process personal data about you in the following circumstances:

      • when you complete the online contact forms on our website (“Site”) providing us with your name, address, email address and contact number;

      • whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;

      • when you visit our Sites we will retain details such as traffic data, location data, weblogs and other communication data, and the resources that you access (see section 2.2.2 on Cookies below); and

      • whenever you disclose your information to us, or we collect information from you in any other way, through our Sites.

    • We may also collect data in the following ways:

IP Address

  • We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

  • Cookies

Our Sites uses cookies to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to improve our Sites. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy here.

  • We may use your personal data for our legitimate interests in order to:

    • provide you with information, or services that you requested from us;

    • respond to an inquiry submitted via our online contact forms;

    • allow you to participate in interactive features of our Sites when you choose to do so;

    • ensure that content from our Sites is presented in the most effective manner for you and for your device;

    • improve our Sites and services;

    • process and deal with any complaints or inquiries made by you; and

    • contact you for marketing purposes where you have signed up for these (see section 5 for further details).

Website Links

Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites.

 

  1. CUSTOMERS

    • We will collect details such as name, address, email address, contact number, date of birth, national insurance number, and financial information in order to provide services to customers. We may also receive details of credit checks undertaken where you have supplied these to us.

  • We will share customer personal information with our employees to manage our relationship with you and we will retain customer personal data for 80 years.

  • We will use your personal data provided to comply with our contractual obligations arising from the agreements we enter into with our Customers and share the data with financial institutions who can assist in the provision of financial services to customers including product providers, lenders, banks, insurers, fund managers, platform providers and third-party para-planners (including Financial Solutions Group Limited paraplanners).

  • We will use customer personal data for our legitimate interests including:

  • sharing personal data with Financial Solutions Group Limited as they are responsible for the services we provide to our clients and have a legal obligation to monitor our compliance with the FSMA and Financial Conduct Authority rules. Further details regarding how Financial Solutions Group Limited will use customer personal data can be found by contacting Financial Solutions Group Limited on 01392 429699;

  • with your consent, marketing our other products and services by mail and email; and

  • with your consent, obtaining your sensitive personal data from third parties including your health, ethnic origin, or criminal prosecutions from third parties such as employers and credit reference agencies, fraud prevention agencies and other similar organisations.

  • We will not transfer any customer personal data outside the European Economic Area (“EEA”).

 

  1. SUPPLIERS

We will collect details such as contact names, addresses, email addresses, and telephone numbers in order to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations, and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of six years from the date of our last contact with you. We will not transfer your personal data outside the EEA.

 

  1. MARKETING

    • We may use customer personal data to provide you with details about our services, products, business updates, and events which we think may be of interest.

    • You have the right to opt out of receiving the information detailed in section 5.1 at any time. To opt-out of receiving such information you can:

      • tick the relevant box situated in the form on which we collect your information;

      • clicking the unsubscribe button contained in any such communication received; or

      • email us at nish@nautilusam.co.uk or call 02476 415555 providing us with your name and contact details.

    • Where you have subscribed to receive marketing correspondence from us we will keep your personal data for six years from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).

 

  1. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

    • In accordance with data protection legislation, we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:

      • for the performance of a contract we enter into with you;

      • where necessary for compliance with a legal obligation we are subject to; and

      • for our legitimate interests (as described within this policy).

    • We will also process your personal data including personal sensitive data where we have obtained your explicit consent.

 

  1. DISCLOSURE OF YOUR DATA to third parties

    • In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:

      • staff members in order to facilitate the provision of services to you;

      • IT software providers that host our website and store data on our behalf; and

      • to a prospective buyer of some or all of our business or assets, in which case personal data including Your Data will also be one of the transferred assets.

    • We may disclose your personal data to the police, regulatory bodies, legal advisors, or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

    • We will not sell or distribute your personal data to other organisations without your approval.

  2. CROSS-BORDER DATA TRANSFERS

We do not transfer personal data outside the EEA.  Where this is required in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation.

  1. ACCESS TO, UPDATING, DELETING, AND RESTRICTING USE OF YOUR DATA

    • It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes. 

    • Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided.

    • You can also ask us to undertake the following:

      • update or amend your personal data if you feel this is inaccurate;

      • remove your personal data from our database entirely;

      • send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract;

      • restrict the use of your personal data; and

      • provide you with access to information held about you and for this to be provided in an intelligible form.

    • We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why subject to any legal or regulatory restrictions.

    • Please send any requests relating to the above to our Privacy Officer, Nishith Patel at nish@nautilusam.co.uk specifying your name and the action you would like us to undertake. Note that in relation to requests to access personal data, we reserve the right to charge a reasonable fee to comply with your request.

 

  1. RIGHT TO WITHDRAW CONSENT

Where you have provided your consent to the collection, processing, and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at nish@nautilusam.co.uk.

  1. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

  1. CONTACT US

We have appointed a Privacy Officer- Nishith Patel to oversee compliance with this privacy policy. If you have any questions, comments, or requests regarding this policy or how we use your personal data please contact our Privacy Officer – Paul White at Financial Solutions Group Limited, an appointed representative of Prydis Wealth Limited which is authorised and regulated by the Financial Conduct Authority, Registration Number 432014 Financial Solutions Group Limited is registered in England No. 10544288. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/