This notice explains how we use the personal information we collect about you.
We collect information about you when you first engage with us prior to our Introductory Meeting. This meeting takes place with a view to KMD providing financial planning, advice and investment advice. This information will relate to your personal and financial circumstances.
We may go on to collect more information when you voluntarily provide copies of personal and product documentation, complete self-evaluation questionnaires, undertake client surveys or provide other feedback to us. For example, later on, it may also include special categories of personal data such information about your health, if that is necessary for the provision of our services.
We may collect technical data about the type of internet browser and computer operating system you use. This information does not identify you as an individual and is only used to track website visits. This is a technology called ‘cookies’ which can be used to provide you with tailored information from a website. A cookie is an element of data, a file that is nothing but a line of text that a website can send to your browser, which may then store it on your system. This will help us to identify you when you return to the site and allows us to tailor content to your personal preferences. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. However, in a few cases some of our website features may not function as a result.
The primary legal basis on which we gather, intend to process and use your information relates to the performance of our contract with you. The information we collect is essential for us to be able to effectively carry out the services that you require of us. Without collecting your personal data, we would also be unable to fulfil our legal and regulatory obligations. Where special category data is required, we will obtain your explicit consent in order to collect and process this information.
With your prior agreement, we may email you about other products or services we think may be of interest to you. We will not share your information with other companies for marketing purposes.
In order to deliver our services to you effectively, we may send your details to third parties such as those we engage for professional compliance, accountancy or legal services, as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit. All sensitive documents sent electronically will be password protected.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.
In principle, your personal data should not be held for longer than is required under the terms of our Client Agreement with you. As our services involve advice for long term investments such as pension portfolios and assurance-based products with long maturation periods, we will need to hold and process your personal data relating to such long-term investments until after their maturation dates, plus any additional period required by law or by any regulator. Under FCA regulation, we have a mandatory requirement to retain your data for specified periods and for some products, such as occupational pension transfers, we are required to retain this data indefinitely.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email or write to us using the contact details given below.
We have an obligation to ensure that your personal information is accurate and up-to-date. Please ask us to correct or remove any information that you think is incorrect.
You 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
Tel: 0303 123 1113 (local rate)