1 Advicefront Privacy Policy

What is this policy?

This is our Privacy Policy (and Cookies) Notice ("Policy") for the Advicefront website (advicefront.com) ("Site") and our products and services (together, our "Services").

It explains who we are, why and how we process personal data and, what rights you have and how to get in touch with us if you need to.

Who are we?

We are Advicefront Ltd. Our contact and other details are set out at the end of this policy.

We are the controller of personal data (this means we decide why and how we use personal data) as described in this policy, except where we explain otherwise.

We are the processer of personal data we collect, store and use on behalf of your financial advisor (your "Advisor") (and your Advisor decides why and how they use this data).

Why do we process your personal data?

We may use your personal data as a controller if:

  • You are a customer or a supplier of ours.

  • You work for a customer or a supplier of ours, or for someone who uses our Services.

  • You are someone (or you work for someone) to whom we want to advertise or market our Services.

We may use your personal data as a processer if:

  • You use our Services as part of our Services to your Advisor (including if your Advisor works with other organisations, and you access these organisations' services through our Services).

We are not responsible for how your advisor or other organisations' use your personal data.

What personal information do we collect & how do we use it?

We may use personal data about you:

A. if you work for your someone we work or cooperate with:

like the person you work for if we are a controller, or

like your Advisor, or your Advisors' AML and ID check providers, if we are a processer.

B. if you engage with us directly.

C. if we would like to send you marketing.

D. if you use our Site.

We explain what data we collect below, and then explain how we use it in the processing summary. This includes the relevant legal reason, called a 'lawful basis', for each way that we use your personal information.

If you use Advicefront because we provide our Services to your Advisor (as a processor).

We collect and use your personal information on financial advisors' behalf if:

  • if your Advisor uses Advicefront's Services,

  • if your Advisor uses other organisations, like background check providers, which link with our Services we may share data with these service providers on your advisor's behalf.

We only share your personal information with your own Advisor(s), and not with other financial advisors.

We are not responsible for how your Advisor or your Advisor's other service providers use your personal information. Please refer to their privacy policies.

A. We might collect your personal information if you work for someone, we provide our Services to, or work with.

If you are or work for an Advisor or company, we provide our Services to (or an organisation that our Services integrate with), we may receive your personal information from them and over the course of working together, including:

  • Contact information includes your work contact information, including first and last name, email address, address, and phone number(s), and your job function or department.

  • Work information includes:

    • information related to transactions between us and you or the person you work for (for example, details of goods or services that we have supplied or purchased).

    • information about you that we need for a contract with you or the person you work for (for example, right to work information credit reference data if necessary for us to carry out appropriate checks in relation to contracts with you or someone else that you work for).

    • information about events (virtual or in-person) to which you are invited, including your relevant preferences so we can organise and manage events (for example, your dietary requirements).

B. We might collect your personal information if you engage with us directly.

If you contact or engage with us (for example, to ask about or purchase our Services, or to supply us with goods or services), we will collect your contact information, sign-in details and the other information you provide.

  • Contact information includes basic contact information you provide: email address, first and last name, phone number(s), social media handle (for example, if you engage with us on social media), and your sign-in data (email and password).

  • Communications information about you that you give us in person, or via phone, e-mail, texts and online messaging, letters, our website, social media or otherwise (for example, if you ask a question, respond to a survey, or report a problem with our Services).

  • Visit data includes information about you we collect of you visit us (for example, if you sign in or are recorded on CCTV while visiting us, or you give us the registration details of your vehicle).

C. We might collect your marketing preferences.

If you are or work for someone, we provide our Services to, or we think might be interested in our Services, we may collect your contact information from you or from other sources (like your company's website).

  • Marketing preferences include your contact information, and your preferences for hearing about some or all of our Services, including any opt-outs.

D. If you visit our website.

If you visit our website, we automatically collect information, which includes:

  • technical data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), terms you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

Processing Summary

Purpose/Activity

Type of data

Lawful basis

Delivering relevant website content to you, and meeting our legal obligations to protect data and systems

  • Contact

  • Marketing

  • Automatically Collected

Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy), in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data and, where required by law, with your consent (e.g. for non-necessary cookies) (see how to withdraw your consent at any time)

Registering you as a new customer or user, including using IP address-based geolocation for digital signatures

  • Contact

  • Communications

  • Automatically collected

Performance of a contract with you, or our legitimate interest in performing our contract with the organisation you work for (without processing this data we will be unable to authorise you to use our Services)

Delivering our Services

  • Contact

  • Work

  • Communications

  • Visit

Performance of a contract with you, or our legitimate interest in performing our contract with the organisation you work for (without processing this data we will be unable to authorise you to use our Services)

Administering and protecting our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Contact

  • Work

  • Communications

  • Visit

  • Automatically Collected

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data necessary to comply with a legal obligation

Communicating with you about the Services, including:

  • Notifying you about changes to our terms or privacy policy; and

  • Asking you to leave a review or provide feedback

  • Contact

  • Marketing

Necessary for our legitimate interests (to keep you informed about changes to the Services and to request feedback on Services delivered), in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data

Making suggestions and recommendations to you about Services that may be of interest to you and to enable you to complete market research surveys where you choose to do so

  • Contact

  • Work

  • Automatically Collected

Legitimate interests in providing our customers and potential customers with information about us and our Services

Consent, if required (see how to withdraw your consent at any time).

Enabling you to enter a prize draw or competition

  • Contact

  • Marketing

Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business), in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data

Using data analytics to improve our website, Services, marketing, customer relationships and experiences

  • Contact

  • Communications

  • Work

  • Automatically Collected

Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy), in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data

Cookies

Our use of cookies to process personal data is explained in our cookie policy, which you should please read.

Who do we disclose your personal data to?

We may share your personal data with:

As a processor:

  • Your Advisor, and your Advisor's service providers (which you through our Services), for example AML and ID checking services, analytics providers, and portfolio management services.

As a controller:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

  • Our business partners and customers (for example, if you work for that customer), for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for

  • Our service providers, organisations who process your personal data on our behalf and provide services to us like web hosting, support services, helpdesk, marketing, and emailing, and including:

  • Intercom R&D Unlimited Company and Intercom Inc, our provider of an online chat facility;

  • The Rocket Science Group LLC (trading as MailChimp), our marketing and communications partner;

  • Our auditors, legal advisors and other professional advisors;

  • Credit reference agencies for the purpose of assessing your credit score where this is in the context of us entering into a contract with you or the person that you work for.

  • In relation to information obtained via our website:

  • Our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

  • Other disclosures we may make

We may disclose your personal data to third parties:

  • In if we sell or buy (or otherwise transfer) any business or assets, in which case we will disclose your personal data to the prospective seller or buyer (or if we receive any investments, to the prospective investor(s)).

  • Any person to whom disclosure is necessary to enable us to protect the rights, property, or safety of us and our clients or other third parties, and to enforce our rights under this Policy or under any agreement (for example, our Terms) with you. This includes exchanging information with other companies and organisations for the purposes of detecting and preventing fraud, credit risk reduction and cyber-crime.

  • If required to do so by court order or if we are under a duty to disclose your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation. This includes exchanging information with law enforcement agencies, regulators, or other similar government bodies.

Where do we process personal data?

We may transfer your personal data to destinations outside the United Kingdom ("UK") or European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the UK or EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things the processing of payment details and the provision of support services. We may transfer your data to Intercom Inc and Mailchimp in the United States of America. Please contact us if you would like any further information about this.

We may transfer your personal information outside the UK / EEA, including to the organisations listed below:

Recipient

Country

Transfer Safeguard

Google LLC (Google Ads / Analytics)

United States

Google Ads Standard Contractual Clauses

The Rocket Science Group LLC d/b/a MailChimp

United States

Mailchimp Standard Contractual Clauses

Intercom, Inc.

United States

Standard Contractual Clauses (signed document copy upon request)

Canny, Inc

United States

Standard Contractual Clauses (signed document copy upon request)

Twilio, Inc

United States

Standard Contractual Clauses

If you would like more information about any transfer safeguard, please contact us at: info@advicefront.com.

How do we protect your personal data?

All personal data processed by Advicefront is stored securely. Any payment transactions will be encrypted using appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long do we process personal data for?

We will generally process personal information:

  • for as long as it is necessary for the purpose(s) for which it was originally collected, and

  • for up to six years after that to identify any issues and resolve any legal proceedings

after which it will be deleted or archived.

We may keep your personal data for longer in the event of a complaint, if we reasonably believe there is a prospect of legal proceedings, or we are aware of pending or ongoing legal proceedings. In some circumstances, we may keep data longer if applicable law says we have to.

If you have opted to receive insights, newsletters, or other promotional material, but later decide to opt out from receiving these updates, or object to any other processing of your personal information, we may keep a record of your opt-out or objection so we can respect your preferences.

What are your rights?

In certain circumstances, you have the following rights in relation to personal data relating to you that we process:

a) to be provided with a copy of your personal information held by us;

b) to request the correction or deletion of your personal information held by us;

c) to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);

d) to object to the further processing of your personal information, including the right to object to marketing;

e) to request that your provided personal data be moved to a third party, and

f) if our processing is based on consent, to withdraw consent at any time.

If you would like to exercise any of your rights, you can do so

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a complaint with the Information Commissioner.

If you are outside the UK, you can find your local data protection authority here.

Our details - contacting us

Our full details are:

Advicefront Ltd
9/10 The Crescent
Wisbech, Cambridgeshire
United Kingdom
PE13 1EH
+44(0) 744 191 7077
info@advicefront.com

Changes to this policy

Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

2 Cookie Policy

We use cookies and/or other similar technologies, such as tracking GIFs, web beacons pixel codes and in-app IDs, either alone or in combination with each other to create a unique device ID.

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Services and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Services when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our Services. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting/Advertising cookies. These cookies record your visit to our Services, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on our Services you visit and on information on other websites and services you visit. This may result in you seeing our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk.

3 Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Services may not operate properly if all cookies are switched off.
If you want to disable cookies on our Services, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

  • For Microsoft Internet Explorer:

  1. Choose the menu “tools” then “Internet Options”

  2. Click on the “privacy” tab

  3. Select the appropriate setting

  • For Google Chrome:

  1. Choose Settings> Advanced

  2. Under "Privacy and security," click “Content settings”.

  3. Click “Cookies”

  • For Safari:

  1. Choose Preferences > Privacy

  2. Click on “Remove all Website Data”

  3. Click “Cookies”

  • For Mozilla Firefox:

  1. Choose the menu “tools” then “Options”

  2. Click on the icon “privacy”

  3. Find the menu “cookie” and select the relevant options

  • For Opera 6.0 and further:

  1. Choose the menu Files”> “Preferences”

  2. Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

Except for essential cookies, all cookies used on our site will expire after 15 days. You can find more information about the individual cookies we use and the purposes for which we use them here:

Cookie

Name

Purpose

More information

Advicefront Cookie

_website_cookie

This cookie is essential for our site to: Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

Advicefront Cookie

_adviser_session

This cookie is essential for our site to: Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

Google Analytics

_ga

This cookie enables us to: Estimate our audience size and usage pattern.

More info

Google Analytics

_gid

This cookie enables us to: Estimate our audience size and usage pattern.

More info

Google Analytics

_gat

This cookie enables us to: Estimate our audience size and usage pattern.

More info

Google Analytics

_gcl_au

This cookie enables us to: store and track conversions.

More info

Google Analytics

_gat_gtag_UA_68062943_3

This cookie enables us to: store and track conversions.

More info

Intercom Cookie

Intercom-session-gorkmg6c

This cookie enables users to access their conversations and have data communicated on logged out pages for 1 week.

More info

Intercom Cookie

intercom-id-gorkmg6c

This cookie enables us to: Recognise you when you return to our site.

More info

Canny Cookie

_canny_userID

This Cookie enables us to: Recognise you when you return to our site.

More info

Canny Cookie

_canny_sessionID

This Cookie enables us to: Recognise you when you return to our site.

More info

Canny Cookie

_canny_tcpenabled

This Cookie enables us to: Recognise you when you return to our site.

More info

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