CARBON FINANCIAL PARTNERS LIMITED (CFPL)

This privacy notice explains how we use any personal information we collect about you.

Carbon Financial Partners Ltd is part of The Progeny Group of companies. ‘Progeny’ is a trading style of The Progeny Group and is used by various companies with the Progeny Group. As part of the Group, we may be required to share your data with Progeny in the circumstances outlined in Who might we share your information with?

What information do we collect about you?

We collect information about you when you engage us for financial planning. This information relates to your personal and financial circumstances and consists only of information you give to us. It may also include special categories of personal data such as data about your health, provided by you, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

We do not collect information about you from third parties.

Why do we need to collect and use your personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations.

Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services, as well as product and platform providers that we use to arrange financial products for you.

We may also share your information with Progeny for good governance, accounting, managing and auditing (both internal and external) of Progeny’s business operations, as well as to comply with requests received from Progeny. This includes sharing data with Progeny for compliance with the Group’s legal and regulatory requirements, requests and related disclosures. When we process any special categories of personal data at your request (e.g. racial or ethnic origin, data concerning health, religious or philosophical beliefs), we may be required to share any special categories of personal data with Progeny. We will not share special category data with Progeny without your consent to do so.

Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

We won’t share your information with other companies for marketing purposes.

How long do we keep hold of your information?

In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. GDPR permits the data to be retained as long as reasonably necessary and, in the case of financial advice, it is necessary to keep a record indefinitely to be able to answer queries or resolve disputes.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can you access the information we hold about you?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

If you agree, we may email you about our products and services which we think may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll inform you of any changes when they occur. This privacy policy was last updated on 25/05/2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you by email at: enquiries@carbonfinancial.co.uk