1. Overview

Investasure Financial Services Limited has developed this Privacy Notice to explain how we may collect, retain, process, share and transfer your Personal Data when you use our services. Personal Data is defined as any information relating to an identifiable living person who can be directly or indirectly identified in particular by reference to an identifier.

This Privacy Notice is designed to provide you with information about our privacy practices and to help you understand your privacy choices when you use our services. This Privacy Notice may be supplemented with additional notices depending on the services concerned.

Investasure Financial Services Limited is governed under Data Protection legislation of the Isle of Man. If you would like to see the legislation and guidance under which we operate in more detail we would refer you to the website of the Office of the Information Commissioner for the Isle of Man. Their website is www.inforights.im.

Please contact Investasure Financial Services Limited if you have questions about our privacy practices that are not addressed in this Privacy Notice.

Investasure Financial Services Limited

Falcon House

22-24 Ridgeway Street

Douglas

Isle of Man

IM1 1EL

2. What Personal Data Do We Collect?

When you begin to use our services or enquire about establishing a relationship, we will collect Personal Data as necessary to offer and fulfil the services you request and to meet our regulatory and legal obligations. Depending on the services you wish to use, we may require you to provide us with a range of personal information which will include (but is not limited to) your:

2.1 name

2.2 residential address

2.3 date of birth

2.4 gender

2.5 telephone number(s)

2.6 email address

2.7 certified copies (or original) identification information e.g. copies of your passport and utility bills

2.8 personal tax references

2.9 banking details

2.10 nationality

2.11 employment details.

We may require you to provide us with additional Personal Data either directly or from third parties, as you continue to use our services.

In most circumstances we will be required to ensure we have a good understanding of your family and financial situation before we can provide services to you, and this will be updated as your circumstances change. We may collect information on you and other individuals connected to you when providing you with services. This may result in us holding information on other people connected to you. Please ensure all relevant individuals you have provided us with information on have been made aware of this Privacy Notice, and the individual rights and information it sets out. If you, or anyone else on your behalf, has provided or provides personal information on an individual connected to your application to us, you, or they, must ensure that you, or they, have the authority to do so.

3. What Is The Legal Basis For Processing Date

We will rely on the following legal grounds to process personal information about you:

• the processing is necessary to perform our contract with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we have a legal or regulatory obligation to use such personal information, and it is necessary to process your personal information to comply with such;
• where the use is necessary to establish, exercise or defend our legal rights;
• where you have provided your explicit consent to our use of your personal information.

4. IP Addresses & Cookies

If you communicate with us by computer, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration.

Our website may place and access certain Cookies on your computer. A Cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. We do this to improve your experience of using the Website and to improve our range of services. These Cookies have been carefully chosen and we have taken steps to ensure your privacy is protected and respected at all times. Any Cookie we use will be in accordance with current UK and EU Cookie law.

5. What Do We Do With The Information We Collect?

Depending on the circumstances and services you want us to provide, we are usually required to get a good understanding of you, your family and/or financial situation before we can provide services to you. We may collect and hold information on you and other individuals connected to you when providing you with services.

Any information you give us will be retained by Investasure Financial Services Limited. The information we collect will be used to ensure we meet our legal and regulatory obligations, and so that we can provide appropriate services to you.

6. Passing Of Information To A Third Party

As Investasure Financial Services Limited is distributor for St. James's Place plc and other parts of the St. James's Place Group as well as third parties who provide products services to support our service to you, we will be passing some of your information to members of the Group as part of the services we provide, either to obtain quotations/illustrations, or as part of the application process for a product or service. By approaching us and asking us to provide financial advice you are consenting to us passing this information on.

All companies we act as distributor for are covered by equivalent legislation, either in the Isle of Man, UK or Ireland (or another EU/EEA jurisdiction).

There are certain circumstances when we are required to provide information to third parties under regulatory, or legal duty.

Please note: Investasure Financial Services Limited cannot be held responsible for the confidentiality of the Personal Data once provided to a third party.

7. How Do We Store Your Data?

All Personal Data we hold is stored securely in accordance with the principles of the Isle of Man Data Protection Act 2002.

Security of information is of great importance to Investasure Financial Services Limited. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure Personal Data stored physically in our office or electronically on our system. We also ensure the off-site backup of our electronic data is secure and appropriately protected. All of our external off-site back-ups are held within the EEA, and comply with international standards.

Our data recovery plan is tested at least once each year, as required by our regulator, and any failings identified within the plan are remediated at once.

8.How Long Will We Retain Your Data?

We will hold your data for at least the minimum time necessary to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.

As a guide, if you are a Client of Investasure Financial Services Limited we are normally required to keep your Personal Data for a minimum 6 years after the date of you cease to be a client of ours, however, we may legally be required to continue to hold your Personal Data for significantly longer periods depending on circumstances.

9. Sensitive Personal Information

We may also, as part of our service, need hold information defined as ‘Sensitive Personal Information’. Sensitive Personal Information is personal data which the GDPR says is more sensitive, and so needs more protection for example details of your medical history. We must have a lawful basis for processing this information, and that will usually include obtaining consent from yourself.

10. Children

For certain services we may be required to obtain and hold information on children. We undertake that personal data in respect of children will only be held where there is a legitimate interest or grounds for processing.

Where it has been deemed necessary to hold information in respect of children we will not undertake any marketing, creating personality profiles or offer any services to such child without the express permission of the holder of parental responsibility.

For the purposes of Investasure Financial Services Limited and this Notice a child is deemed to be an individual who has not yet attained 16 years.

11. Accessing Your Own Data

You have the right to ask for a copy of any of your Personal Data held by Investasure Financial Services Limited. We do not charge for this.

12. Accuracy

We are required to ensure that all Personal Data we hold is accurate, complete and up to date. If you become aware of anything which is not accurate, or is incomplete or out of date in the Personal Data we hold you should notify us and we will rectify it.

13. Right To Erasure

You have the right to make a request to have your Personal Data erased, where, for example, there is no legitimate reason for us retaining that data. Investasure Financial Services Limited have the right to retain all Personal Data where we still have a legitimate reason for doing so.

14. Right To Object

In certain circumstances you may have a right to object to the processing of your Personal Data. If you wish to object to our processing your Personal Data at any time you should in the first instance contact our Data Protection Officer whose details are set out below. Investasure Financial Services Limited have the right to process any Personal Data where we can demonstrate we have a legitimate reason for doing so.

15. Consent

Where you have provided consent, you are entitled to withdraw this consent at any time and can do so by contacting Investasure Financial Services Limited and, if necessary, our Data Protection Officer as set out below. However, withdrawing your consent may impact the relevance of the financial advice provided.

16. Automated Decision Making

Investasure Financial Services Limited will not use automated decision making or profiling based on the information you provide.

17. Selling or Buying Personal Data

Investasure Financial Services Limited will not sell your Personal Data to any third party, nor will it buy in Personal Data on other persons.

18. Request for Transmission

You may request some or all of your Personal Data to be transmitted to another organisation. Should you require this undertaking you should contact the Data Protection Officer.

19. Breaches of Security

A Personal Data Breach is an incident defined as "accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed". If we suffer a breach we are required to notify the breach to the supervisory authority without undue delay. If the breach is likely to result in a high risk to your rights and/or freedoms we will also communicate details to you.

20. Right To Lodge A Complaint and Compensation

You may make a complaint to the Isle of Man Information Commissioner if you believe that you have been directly affected by any processing of your personal data by a business or organisation in the Isle of Man. The Commissioner cannot award compensation, but if you think that you have suffered damage, or damage and distress, you have a right to take an action for compensation against the data controller via the court.

21. Data Protection Officer

Investasure Financial Services Limited has appointed Mr Martin Corkish to be the Data Protection Officer. Mr Martin Corkish can be contacted at

Investasure Financial Services Limited

Falcon House

22-24 Ridgeway Street

Douglas

Isle of Man

IM1 1EL

Tel: 01624 615751

Email: martin.investasure@sjpp.co.uk

22. Changes To This Notice

Investasure Financial Services Limited reserves the right to change this Notice as we may deem necessary from time to time or as may be required by law.