Sandringham Financial Partners (“Sandringham”) are a leading provider of financial advice within the UK. We take your privacy seriously and will only use your personal information where it is necessary to provide you with the products and services you have agreed to and to make sure the content you have consented us to provide you with is relevant and interesting to you.
Any questions regarding our privacy practices should be sent by email to firstname.lastname@example.org or by writing to Sandringham Financial Partners, 5th Floor, 30 Market Street, Huddersfield, HD1 2HG. Alternatively, you can telephone 01484 504900.
How we collect your data
We obtain information about you during interaction with our Partnership Development Consultants, when you apply to join Sandringham, when referred to us via either our Partner Get Partner scheme or other 3rd party, when you register for any of our events or information you provide via our websites.
What information is being collected
We collect the information required to provide you with relevant, personalised and interesting content. This information may also be used to proceed with your application to join Sandringham.
We use many different kinds of personal information, and group them together like this.
|Type of personal information||Description|
|Contact||Where you live and how to contact you.|
|Financial||Your financial position, status and history.|
|Socio-Demographic||This includes details about your work or profession, age and nationality.|
|Social Relationships||Information about your family|
|Contractual||Details about the products or services we provide to you.|
|Communications||What we learn about you from letters, emails and conversations between us.|
|Open Data and Public Records||Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.|
|Usage Data||Other data about how you use our products and services.|
|Documentary Data||Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.|
|Special types of data||The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:
• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Health data including gender
• Criminal convictions and offences
|Consents||Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you.|
|National Identifier||A number or code given to you by a government to identify who you are, such as a National Insurance number.|
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. If the information is required to process your application to join Sandringham we may need to decline your application.
Any data collection that is optional would be made clear at the point of collection.
Why we process your data
We may use your information to:
- to carry out our obligations arising from any contracts entered into by you and us;
- To process your application to join Sandringham including submitting required data to the Financial Conduct Authority;
- deal with any complaints which may arise in the future;
- to provide you with information about services we offer;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
- send you communications which you have requested and that may be of interest to you
How we share your data
We will not share your information with third parties for marketing purposes unless you have given us consent to do so.
Your personal data will be treated as strictly confidential and will be shared only with our service providers for the purposes described in this statement.
Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers for the purposes of completing tasks and providing services to you on our behalf. However, when 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 direct marketing purposes. Please be reassured that we will not release your information to any third parties for them to use for their own direct marketing purposes, unless you have consented 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.
Your data may also be transferred to the Financial Conduct Authority or any other statutory, governmental or regulatory body if required.
To provide services to you we may be required to pass your personal information to product and service providers located outside of the European Economic Area (EEA) in countries that do not have Data Protection Laws equivalent to those in 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 Policy.
To do this we’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
Notwithstanding any terms to the contrary, we may disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or
- to protect the rights, property, or safety of Sandringham Financial Partners, our service, our users and any third party we interact with to provide the Service.
How long we will keep it
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example, our regulator, the Financial Conduct Authority require that records of our advice are kept for certain periods). We will hold your personal information on our systems for the period necessary for the purposes for which the data was collected, or as long as is necessary to fulfil our legal and statutory obligations, whichever is longer.
To opt out of any email communications from us, please click the ‘unsubscribe’ link at the foot of the email in question for an immediate removal from further communications.
If you have previously agreed to us holding or using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com. We will process the restriction of use in our marketing communications or removal of your personal information within 10 days, sometimes sooner.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address above. We may make a small charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
You have the right to ask us to erase the personal data you have provided to us. We will carry out this request where it does not conflict with any legal, regulatory or contractual obligations we may have.
You have the right to withdraw your consent for us to process your personal data however doing so may affect our ability to fulfil our contractual obligations or obtain the products and services requested. We will notify you upon request should this be the case.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking/ticking certain tick boxes we use to collect your data. You can also exercise the right at any time by contacting us using our contact details set out below.
How to complain
Please let us know if you are unhappy with how we have used your personal information. You can contact us at by emailing firstname.lastname@example.org or by writing to Sandringham Financial Partners, 5th Floor, 30 Market Street, Huddersfield, HD1 2HG. Alternatively, you can telephone 01484 504900.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.
How we secure your data
All information you provide to us is stored on our secure servers. Non-sensitive details (your email address etc.) may be transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. We use industry standard physical, technical, and logical security measures to protect your Data. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We do not store credit/debit card details. We process credit/debit card details using an online third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.
Information on Cookies
Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.
Some of the cookies we use:
Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this may restrict the functions that you’re able to carry out on our sites.
These enable you to carry out some essential functions on our sites, they also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.
We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and help us provide a more friendly solution.
Managing your cookies
You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.
Cookies are used on our site to ensure that we give you the best experience on our website. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on our website. Some cookies are essential so you can move around the website and use its features. Without these cookies, some services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.
This policy was last reviewed March 2018.