The Money Advice Clinic understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.moneyadviceclinic.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1.Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Money Advice Clinic which is a trading style of Financial Minefield Ltd, a limited company registered in England under company number 05073455, whose registered address is Black Bull House, 353 – 355 Station Road, Bamber Bridge, Preston, Lancashire, PR5 6EE and whose main trading address is Cotton Court, Church Street, Preston, PR13BY.
2.Information About Us
- Our Data Protection Officer is Adam Stretton of The Right Mortgage, and can be contacted by email at email@example.com, or by post at The Right Mortgage, St Johns Court, 70 St Johns Close, Knowle, Solihull, B930NH
- We are appointed representatives of The Right Mortgage Network who are authorised and regulated by the Financial Conduct Authority.
- We are a member of the Society of Will Writers.
- We are licensed Money Advisers as licensed by YOR Money Ltd.
- We are appointed Introducers to Trafford & Houghton Financial Planning Ltd
3.What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.What Data Do We Collect?
- date of birth;
- business/company name
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences and interests;
- financial information such as credit / debit card numbers;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6.How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our products andservices for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing firstname.lastname@example.org.
- Market research;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Open Enquiries will be retained for a period of 12 months.
- Regulated Advice Services will be retained on file for as long as we are liable for any potential complaint or legal claim.
- Money Advice Services will be retained on file for a period of 12 months once the client relationship has ended.
- Will Writing Services will be retained on file for as long as we are liable for any potential complaint or legal claim.
- Information held for Marketing or Business Analysis / Development will be retained on file for a period of 12 months once the client relationship has ended.
- Accounting Information will be retained on file for a period of 3 years once the client relationship has ended.
7.How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- We carry out a detailed audit on each 3rd party when considering any subscription to a data processor.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
- Contracted Arrangement to ensure they abide to GDPR.
- Assessment of where data is stored.
- Safeguarding to personal data held.
- Assessment of in business to avoid any potential problems materialising with new technology followed up with a Data Protection Impact Assessment.
8.Do We Share Your Data?
Subject to the section below, We will not share any of your data with any third parties for any purposes.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods or specific providers who provide the facility to deliver our services such CRM systems and Money Management Platforms such as your YOR Money Software. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- Microsoft 365 is what we use for emails, Contract Held, Data stored with Microsoft Corporation.
- YOR Money Software is a programme we use to assist with the delivery of our Money Advice Service, all data is stored with Amazon Web Services.
- E-Keeper is out Customer Relationship & Application Management System, all data is stored in the UK.
9.What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10.How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11.Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12.How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.
13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|Wordfence_verifiedHuman||To protect the site against malicious attacks||Yes|
13.6 Our Site uses analytics services provided by google analytics, google.com and infusionsoft. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.8 The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|NID||Third party||Google.com||Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads.|
|collect||Third party||Google Analytics||Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels.|
|_ga, _gat, _gid||Third party||Google Analytics||These cookies are used to collect information about how visitors use our website and WordPress blog. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.|
13.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
You can also complain to the Information Commissioner’s Office [ICO] if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk