At clarity Ltd (‘clarity’), we are committed to protecting and respecting your privacy. As a business that provides financial advice and investment management services, we hold personal information on our clients and potential clients in order to deliver our services.
We are a registered data controller, as well as a data processor, under the General Data Protection Regulation (GDPR).
This privacy notice explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.
We may hold your personal information if you are a clarity client, if you use our website or otherwise contact us seeking our services.
This privacy notice will be updated from time to time, in line with changes to our systems, processes and procedures, so please check this page occasionally to ensure you’re happy with any changes.
By using our website and/or our services, you’re agreeing to be bound by the terms set out in this notice.
Any questions regarding how we collect, store or process data should be sent by email to enquiries@clarityglobal.com or by post to:
The Data Protection OfficerAlternatively, you can contact us by telephone on 0800 368 7511.
We obtain information about you if you are a clarity client or seek our services, and/or you use our website.
We collect information in a number of ways, including:
As the information we collect and hold is often required to enable us to provide our services, if you opt not to provide it we may not be able to continue to advise you. Likewise, we cannot advise you or provide you with services without holding certain personal information about you.
If you complete any forms on our website, or use our clarityONLINE service, then the personal information we collect might include your name, address, email address, IP address, investment policy details and information regarding what pages are accessed and when.
If you are a client, or are seeking advice, or other services from us, we undertake a ‘getting to know you’ process. This includes obtaining information about your personal and financial circumstances and objectives. Where you have existing investments or policies we obtain information on these from you and/or upon consent from you directly from the providers concerned. We assess your ‘attitude to risk’ and ‘capacity for loss’ and record this in our documentation. We retain records of any investments or policies that you arrange through us.
In addition, where applicable, we hold information you provide to us about other people, for example your spouse or partner, joint applicants or beneficiaries for products you have with us.
Where we are providing you with an ongoing service, we will update the information we hold about you as part of our review process.
There may be situations where the information we require in order to advise you is sensitive personal data, such as information about your health, which is classed as ‘special category information’ under the GDPR. In these circumstances we will explain why we need it and obtain your consent to obtain and hold the data. This situation most commonly occurs where we are arranging insurance products and need to obtain medical information from you.
We store information in three main ways:
There are also some rare circumstances, mainly in relation to our accounting and finance records, where certain information is held in paper files. In these circumstances, the records are held in suitably secure filing systems at our premises.
We use your information to:
We may also aggregate customer data to produce and or publish statistical reports, however these reports never include information that would enable any individual to be identified.
We are required by legislation and the Financial Conduct Authority (FCA) to retain records for specified periods. These vary dependent upon the nature of the service provided.
We do not share personally identifiable information with third parties other than with our primary business partners, and this is solely as necessary to provide the information or services you have requested.
We will never sell or rent your information to third parties.
We will never share your information with third parties for marketing purposes.
We may pass your information to our third-party service providers (including investment houses and life assurance firms), agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, such as paraplanning and compliance support. Where we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. Please be reassured that we will never release your information to third parties beyond the firm for them to use for their own purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
We will make appropriate contact with you to provide the agreed services. Where this includes our ongoing advisory services, we will contact you at the agreed intervals to undertake our review. We may also contact you at other times if we believe you need to take action (e.g. if you should consider making ISA or pension contributions before tax year end) or be aware of changes in the economic situation. These communications form a core part of clarity’s service.
We will only contact you for marketing purposes where you have given your prior consent for us to do so or, on occasion, where we believe you may have a legitimate interest in the information we are providing. You can change your marketing preferences at any time in your clarityONLINE account, by post or by emailing: adminteam@clarityglobal.com.
The accuracy of your information is important to us. Where we provide just an initial advice service, the information will reflect your situation at that time and we will not normally update this (apart from a change of contact information). Where we are providing an ongoing service, we will update the information as appropriate when we undertake a review with you. If your contact information changes in between reviews, please notify us and we will update our records.
Under the GDPR you have a number of specific rights in relation to your personal information, as summarised below:
ACCESS
You have the right at any time to request a copy of the personal information we hold about you. Should you wish to receive a copy of this, please contact our administration team at our Woking address or email adminteam@clarityglobal.com.
Our security procedures mean that we may request proof of identity. We will provide this information within one month of receiving your request and proof of identity, free of charge (we may charge a fee for subsequent or duplicate requests).
RECTIFICATION
You may ask us to correct any information that we hold that is inaccurate or incomplete.
ERASURE
You may ask us to delete or cease processing data in certain situations. Please note that where we have regulatory obligations to retain information for certain time periods, we will retain such information as we believe is necessary to fulfil these obligations.
RESTRICT PROCESSING
You may ask us to cease processing information. This means that we will be able to retain it but no longer act upon it. In the event that you no longer need our services and terminate them we will automatically cease processing information.
PORTABILITY
You may have the right to have your data transferred to another service provider in an appropriate electronic format. Please note that we will have regulatory obligations to retain copies of the information as outlined previously.
OBJECTION
You have the right to object to us using information for marketing purposes and may have the right to object to us processing information.
This is a brief summary of your rights and there may be restrictions on some of them. If you wish to explore any of these rights at any time, please contact us on the addresses above and we will be pleased to assist you.
When you give us personal information, we take steps to ensure that it is retained securely and processed in a confidential manner. We will ensure that it is held in accordance with the Data Protection Act 1998 and, from 25 May 2018, the GDPR. Your information may be accessed by your adviser and our support staff for the purposes of providing our services to you. In addition, it may be accessed by senior managers and our compliance consultants (or the FCA) for the purposes of ensuring compliance with our regulatory obligations and reviewing the quality of our advice.
Once we receive your information, we make our best effort to ensure its security on our systems. Our security controls are aligned to industry standards and good practice. All employees are trained (and undertake annual refresher training) in storing and transmitting client information. Where we have given (or where you have chosen) a password that enables you to access certain parts of our websites or documents, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
As mentioned above, we take privacy very seriously and are committed to the following: Educating you on web tracking and how to avoid web tracking
Our web-tracking solution uses a first-party cookie to track visitor activity on our websites. We use this information to improve the content of our sites as well as to provide visitors with a more relevant overall experience. As mentioned earlier, we never share information you provide to us with third parties (other than our own third-party service providers). If you do not want our site to place a cookie on your browser and track your activity you may leave the site, or you may browse the site using privacy mode in your web browser. To learn how to use privacy mode please refer to online guides that are relevant to the browser you use.
If you complete a form on our website your information will be stored in our CRM and/or support systems and some amount of your past browsing on our website may be available to our staff to determine your interests so we may more effectively engage with you and improve our site. However, as mentioned above, if you use private browsing you can provide us with your information without making your past activity on our website available to us.
Like many other websites, the clarity website uses cookies. Cookies are small pieces of information sent by a website to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.
clarity uses cookies for form field memory, login, and other site customisations and for statistical purposes related to website administration, usage and customer interactions.
Our websites and services also use Google Analytics to analyse the use of the websites and generate statistical and other information about website use by means of cookies, which are stored on users’ computers.
It is possible to switch off cookies by setting your browser preferences. Turning cookies off will result in loss of functionality when using our website.
Using only permission based web-tracking technologies.
We use first party HTML browser cookies in our web-tracking technology. This means that visitors to our site are easily able to set their browsers to reject cookies and are easily able to delete cookies set by our website. For example, to set the Internet Explorer browser to reject cookies go to Tools > Internet Options > Privacy > Settings and select the privacy level (using the slider bar) that you prefer. To delete cookies in Internet Explorer, go to Tools > Internet Options > General > Browsing History and click the Delete button then select the cookies option.
We never use visitor identification techniques that involve sharing information you provide to us with other sites, or vice versa.
Our website may contain links to websites run by other organisations. This privacy notice applies only to our website‚ so we encourage you to read the privacy information on the other sites you visit. We cannot be responsible for the privacy policies and practices of other sites, even if you access them using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
As part of the services offered to you through this website, the information you provide to us may be transferred to countries outside the European Union (‘EU’). By way of example, this may happen if any of our servers are, from time to time, located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in this privacy notice, please write to us at our Woking address or email us at enquiries@clarityglobal.com.
If you are still unhappy with any dealings with us regarding your personal information you may complain to the Information Commissioners Office (ICO). You can do this via their website https://ico.org.uk/concerns, or by calling 0303 123 1113.
We keep our privacy policy and practices under regular review. This privacy notice was last updated in May 2018 in line with the introduction of the GDPR.