Privacy Policy & Cookies – Westbrook Advisers

Your Personal Data and Westbrook Advisers

Westbrook Advisers Limited (“we” or “us” or “our”) understands that the information you trust us with is important to you and is committed to protecting and respecting your privacy.

This document (our “Privacy Policy”) sets out how, when and why we collect your personal data; how it is used; under what circumstances it may be disclosed; and what rights you have in relation to us controlling and processing your data.

All personal information provided by you and/or you will be treated in accordance with (a) the Data Protection Directive 95/46/EC and ePrivacy Directive 2002/58/EC as implemented by countries within the EEA, (b) the General Data Protection Regulation, and/or (c) other laws that are similar, equivalent to or that are intended to implement, amend, or replace, the laws that are identified in (a) and (b) above (the “Data Protection Legislation”).

Personal data is information which directly or indirectly identifies you. We are committed to processing your personal data in accordance with Data Protection Legislation. For the purposes of the Data Protection Legislation, Westbrook Advisers Limited is the Data Controller.

It may be necessary for you to give us personal data so that we can provide you with the requested services, fulfil any contractual relationship with you, inform you of our services, comply with applicable laws, regulations and/or codes of practice and for the other purposes as set out in this notice where in our legitimate interests.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may hold the following personal information about you and use it as we describe in the next section:

your name, address, telephone numbers, email address(es), date of birth, place of birth, nationality, tax/residency status, passport, driving licence, utility bills, employment, banking and financial details
demographic and lifestyle information
any other information (including where obtained from third parties) which we reasonably need to provide services to you, make decisions about you or fulfil our legal, contractual or regulatory obligations.

You may also provide us with information about other people connected to you (such as your dependents, joint account holders or business and/or financial associates). Please ensure that you know they agree for this information to be shared with us, or that you are otherwise allowed to give us this information and direct them to our Privacy Policy. We will provide them with a copy of this Privacy Policy on request.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will process the information we collect about you to allow us to enter into and perform a contract with you, to meet our legal and regulatory obligations, for the purpose of our legitimate interests (as detailed at the end of the next section) or where you have given us your consent. We will use it:

to process and complete your requests for services
for security and ID verification
to detect and prevent criminal activity and fraudulent transactions
to maintain and update your records with us
to develop and improve our services
to protect ourselves against harm to our rights and interests
to provide specific information to our regulators and other government bodies to adhere to our regulatory, legal and compliance obligations.

Marketing messages

We will NOT send to you or your family information about products and services which we think may be of interest to you.
We will NOT send you or your family information from select organisations which we think may be of interest to you.

Cookies

Our website makes use of cookies to improve your browsing experience. A cookie is a small text file which is stored on your computer by your web browser which enables a website to remember certain information about you, for example, if you are logged in or what items are in your shopping basket.

Cookies are a widely used method of storing information and can do no harm to your device, they are generally used by websites to track how you interact with them and gather data to help enhance your experience. We recommend that you do not disable cookies when browsing as you may not be able to make full use of our website. We do not store any personally identifiable information in our cookies and do not share any information with third party advertisers.

You can read more about cookies at the following websites, the About Cookies website also contains information on how to manage and delete your cookies:
• About Cookies
• Wikipedia

If you have any concerns about our cookie use or how we use your data in general, please contact us. The cookies we use on our website fall into the following area:

Session Cookie
This is a cookie which is set for the length of your browsing session, it expires once you close your browser. We use this to track basic information within your visit to our website, e.g. if you have logged in, if there’s anything in your shopping basket or any information that will need to be remembered from page to page. Session cookies are not shared with other websites.

WHEN IS YOUR PERSONAL INFORMATION DISCLOSED AND TO WHOM DO WE DISCLOSE IT?

People who support services we provide

to third parties who are bound to keep such information secure and confidential, such as our suppliers, contractors, agents, and business partners (and their sub-contractors) who help us provide our services to you
to organisations or agencies who host or maintain data centres, service platforms and other infrastructure and systems on our behalf, where your personal information is processed and/or stored; or to our professional advisers.

People we have obligations to give it to

to UK and overseas regulators and authorities in connection with their duties
when we are required to comply with (i) a court order, (ii) a request from a law enforcement agency or (iii) other legal obligations
when there is a public duty to disclose information
to comply with anti-money laundering legislation
when it is necessary to prevent bribery, fraud, terrorist financing and money laundering;
to meet our obligations under the sanctions compliance regime
to reduce credit risk or recover any money you owe to us
when we may be required to share information about your accounts with the UK or relevant tax authorities, either directly or via the local tax authority who may share that information with the appropriate tax authorities abroad.

People you want us to give it to

to your other advisers (such as accountants, lawyers, financial or other professional advisers) if you have authorised anyone like this to represent you, or any other person you have told us is authorised to give instructions or to use the account or services on your behalf (such as an attorney under a power of attorney)
to a guarantor, where appropriate
when you have provided consent.

Our legitimate interests

in the event that we sell or buy any of our business or assets, in which case we may disclose your personal information (as a client) to the prospective seller or buyer of such business or assets, or to anyone funding the sale or purchase of such business or assets regardless of whether the sale or purchase is completed
to protect our rights, property, or safety of our employees, clients or others including in order to enforce our terms of use and other agreements.

TRANSFERRING YOUR DATA OUTSIDE OF THE EEA

We, or third parties acting on our behalf, may transfer your personal information outside the European Economic Area (EEA). We will protect your personal information in accordance with the standards set out under the Data Protection Laws. We do this by including strong undertakings in the contracts we put in place with those relevant parties. Additionally, we and other organisations we work with may access and use information recorded by fraud prevention agencies from other countries.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

Once your relationship with us ends, we will keep your information for a period no longer than is required by law or regulation. If you decide not to go ahead before becoming our client, we will keep your information for no longer than a period of 6 months.

YOUR RIGHTS

Access to your information – You have the right to request a copy of the personal information about you that we hold.

Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – You have the right to ask us to delete personal information about you where:
You consider that we no longer require the information for the purposes for which it was obtained
We are using that information with your consent and you have withdrawn your consent
You have validly objected to our use of your personal information
Our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information.

Restricting how we may use your information – In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information, but you don’t want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

CONTACTING US

You may contact us, as the data controller, at the address below FAO Andrew Sandars (DPO), or by calling us on +44 7718 660230.

24 May 2018

Westbrook Advisers Limited is regulated by the Solicitors Regulation Authority and is incorporated in England and Wales (company number 10248657) with its registered address at Westbrook Farm House, Boxford, Newbury, RG20 8DL