Privacy policy

CRAVEN STREET WEALTH

Privacy Notice

December 2023

1. Purpose of this notice

This notice describes how we collect and use personal data about you, in accordance with current applicable UK Data Protection Legislation together with other laws which relate to privacy and electronic communications.  In this notice, we refer to these laws as “Data Protection Law”.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. About us

“We”, “us”, “our” and “ours” means Craven Street Financial Planning Limited t/a Craven Street Wealth (Registered number 03852054) registered with Companies House in England and Wales and have a registered office of 3 Gough Square, 3^rd Floor, London EC4A 3DE.

For the purpose of Data Protection Law and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under Data Protection Law to notify you of the information contained in this privacy notice.

We have appointed a Head of Privacy. Our Head of Privacy is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Head of Privacy you can do so using the contact details in section 13 below.

3. How we may collect your personal data

We obtain personal data about you, for example:

• when you request a proposal from us in respect of the services we provide;
• when you engage us to provide our services and also during the provision of those services;
• when you contact us by email, telephone, post or social media (for example when you have a query about our services); or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House).

4. The kind of information that we hold about you

The information we hold about you may include the following:

• your personal details (such as your full name, date of birth, nationality, address, national insurance number and bank account details);
• special categories of personal data as defined in Data Protection Law;
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities; or
• information we receive from other sources, such as publicly available information or information from your existing providers or professional contacts.

Special categories of personal data: there are certain categories of personal data that are sensitive by nature. The categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain your sensitive personal data particularly in relation to health. Our policy is that should we require any special category of personal data we will only gather this with your explicit consent.

5. How we use personal data about you

We may process your personal data for purposes necessary for the performance of our contract with you, and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, trustee or attorney.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent: in these limited circumstances where your consent is required for the processing of your personal data, you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be an employee, trustee or attorney;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you;
• seek your thoughts and opinions on the services we provide; and
• notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any regulatory, statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. Data sharing

Why might you share my personal data with third parties?

We will only share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers, other professional firms that we work with and product and platform providers that we use to arrange financial products for you. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, compliance, accountancy, legal and banking services, as well as product and platform providers.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

We may provide links to third party websites, plug-ins, applications and cloud software.  The providers of these links will have their own privacy notices explaining why and how personal data is collected and processed by the cloud software.  We encourage individuals using this cloud software to refer to these privacy notices.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

7. Transferring personal data outside the European Economic Area (EEA)

We do not transfer your personal data outside the European Economic Area (EEA).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. Our website (cravenstreetwealth.com and/or www.cravenstreet.co.uk)

We may collect some information from visitors to our website (including your name, email address and phone number). This information is used only to respond to enquiries (including information you provide when you register to use our website, subscribe to our service, make an enquiry, enter a competition and promotion or survey) and to monitor website usage. We will not pass on these details to third parties or use them for any other purposes unless instructed by you to do so.

Cookies and logging of IP addresses are used to enable us to monitor site traffic and repeat visitor statistics. These statistics will not include information that can be used to identify any individual. Such information is anonymous and held on a temporary basis.

You will not receive unsolicited paper or electronic mail as a result of using an electronic form on our website unless we have explicitly requested and received your permission.

Where personal data is requested through forms, such data is only used for the purpose stated on the form and will not be given or sold to any third parties.

10. Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details at section 13 below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data subject to the restrictions of our regulatory obligations and legitimate interests. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please contact our Head of Privacy by using the contact details noted at section 13 below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to certain direct marketing that you have indicated you would like to receive from us) you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email fp@cravenstreetwealth.com

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

12. Changes to this notice

Any changes we may make to our privacy notice in the future will be updated on our website at: www.cravenstreetwealth.com.

This privacy notice was last updated on 19 January 2023.

13. Contact us

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our Head of Privacy by emailing info@cravenstreetwealth.com or by telephone on +44 (0)330 320 9280.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

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

Telephone – +44 (0)303 123 1113 (local rate) or +44 (0)1625 545 745

Website – https://ico.org.uk/concerns