Privacy Notice and Cookies

Please read our Privacy Notice carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described in ( Section 2 below), you agree that we may collect, store and use it (a) in order to perform our contractual obligations to you, (b) based on our legitimate interest for processing (i.e. for internal administrative purposes or for the detection or prevention of crime) or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.

1. Who We Are

Our Privacy Notice applies to all products, applications and services offered by Curtis Banks Ltd (incorporated in England with company registration number 492502 and whose registered Head Office address is:

Curtis Banks Ltd, 3 Temple Quay, Bristol, BS1 6DZ

2. How We Collect Information

To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services ( E.g: we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described in Section 12).

We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information, ( E.g: information from credit agencies, search information providers or public sources ( E.g: for client due diligence purposes), but in each case as permitted by applicable laws.

If you intend giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protections laws. In so far as required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

3. How We Use Your Information

To the extent permissible under applicable law, we use your information to:

To the extent permitted by applicable law, we retain information about you after the closure of your Pension / Account or if your application is declined or where you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

Our website, applications (including mobile applications) and services may contain technology that enables us to:

You can manage your privacy settings within your browser or our applications and services (where applicable).

In addition to the purposes described in Section 3, we may also use information we gather to deliver In-Product Messaging or Information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 5 and 6 of this Privacy Notice provide further details on how we will do this.

We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.

Mobile Data:

We may obtain information through mobile applications that you or your users install on their mobile devices to access and use our website, applications or services or which you or your users use to provide other services related to that mobile application ( E.g: to sync information from our application or service with such mobile application). These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read that third party’s own privacy notice as it will apply to your use of that third party mobile application. We are not responsible for such third party mobile applications and their use of your personal information.

Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services ( E.g: activity undertaken within a mobile application may be logged).

You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.

4. Sharing Your Information

We may share your information with:

Please Note: We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

5. Marketing

From time to time, where you have consented to us sending information (we may use your information, to contact you by telephone, post, SMS or email with details about our applications, products and services which we feel may be of interest to you.

Or with:

*For the sole purpose of administering your Curtis Banks Ltd Product requirements and satisfying our regulatory responsibilities.

You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by using Section 13 to contact us in writing or via email.

6. Your Information & Your Rights

If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will have the rights:

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know ( see Section 13), so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes or ask for your information to be deleted as set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, products and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes or as otherwise permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

7. Changes, Modifications & Adjustments Changes to Our Privacy Notice

Curtis Banks Ltd reserves the right to change, modify or adjust this Privacy Notice from time to time; however we will not reduce your rights under this Privacy Notice.

8. Security & Storage of Information

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe, we will not share this password with anyone.

If you believe your account has been compromised, contact us immediately at compliance@curtisbanks.co.uk in order for us to take additional steps to protect your personal information as appropriate.

9. Transfers Outside of the European Economic Area

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

Our website and some of our applications or services or parts of them may also be hosted outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) meaning that we may transfer any information which is submitted by you through the website or the application or service to other territories outside of the EEA.

We may use service providers based outside of the EEA to help us provide our website, applications and services to you ( E.g: platform and payment providers who help us deliver our applications and services or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications and services to you.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations ( E.g: we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Notice). Curtis Banks Ltd is subject to its Data Protection Policy designed to protect data in accordance with EU data protection laws. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

10. Other Sites & Social Media

If you follow a link from our website, application or service to another site or service, this notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Our websites, applications or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.

11. Curtis Banks Ltd - Electronic Mail Containing Personal Information

Financial Advisers, third parties, clients, users, etc, may, from time to time, forward electronic mail ( Secure Messages), containing Personally Identifiable Information (PII) to Curtis Banks Ltd via our Secure Online Portal.

To access the Secure Online Portal, you are required to be a Registered Authorised User with a Username and Password in order for Curtis Banks Ltd to verify you as an authorised user.

Curtis Banks Ltd will only use this information for the purpose of identifying the original user from the initial electronic mail message, in order to access required data / information.

12. Cookies, Analytics & Traffic Data

Cookies are small text files which are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you.

Our cookies may be Session Cookies ( E.g: temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or Persistent Cookies ( E.g: cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).

Curtis Banks Ltd may use the following different types of Cookies:

Strictly Necessary Cookies:

These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website.

Performance Cookies & Analytics Technologies:

These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don't collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.

Functionality Cookies:

These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting or Advertising Cookies:

These cookies can be used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operators’ permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Web Beacons & Parameter Tracking:

We may also use cookies and similar software known as web beacons to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of any products or services purchased. These web beacons collect limited information which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.

IP Address & Traffic Data:

We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.

Google Analytics Cookies:

Google Analytics Cookies are used to collect information about how you use our website, view information, products, investments or on-line tools, in order to compile reports to help us improve our websites. Cookies collect information in an anonymous form, including the number of visitors to the site, the name of your Internet Service Provider (ISP), the website you last visited, the pages you request/visit, the date and time of those requests and the number of visits you made to the website, during normal website usage.

For more information on Google Analytics: http://tools.google.com/dlpage/gaoptout

How to Disable Cookies:

You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the allaboutcookies.org website.

13. Contact Us

Curtis Banks Ltd takes your privacy very seriously; therefore, our privacy practices are designed to provide a high level of protection for your Personal Information and our systems. If you have any requests, questions or queries about Curtis Banks Ltd Practices, please contact the Data Protection Officer by:

E-Mail: compliance@curtisbanks.co.uk

Or

In Writing: Curtis Banks Ltd, Head Office, 3 Temple Quay, Bristol, BS1 6DZ

Please Note: If you are a registered authorised user, please contact the Curtis Banks Ltd - Data Protection Officer, by Secure Message, via our Secure Online Portal.