Data Protection – Privacy Notice
At LMS Partners Limited (“LMS Partners”), we are aware of the trust you place in us and our responsibility to protect your privacy and keep your personal data secure in accordance with Data Protection legislation.
This privacy notice covers:
Below are two definitions to help you understand this privacy notice: -
‘Independent Financial Adviser’ ‘(IFA)’ means a Qualified Financial Adviser employed by LMS Partners.
‘Provider’ means any third-party company we work with on your behalf that offer financial products or services such as investments, pensions, annuities, life insurance, critical illness cover, income protection, and mortgages.
The Data Controller:
LMS Partners Limited is the Data Controller for the purposes of the Data Protection Act 2018 and in relation to all the personal data provided to us. The primary legal basis for which we process this personal data is for the performance of service contracts we enter into (or may enter) into with you through our Terms of Business;
Why do we collect personal information?
We collect your personal information for any of the following purposes:
Your personal information is only collected and used for the purpose(s) it was provided for, and of which you were aware at the time your information was supplied to us. We will limit the collection of your personal information to only that which is needed in order to satisfy the intended purpose.
It is ultimately your choice as to whether to provide us with your personal data, but please note that if you fail to do so, or you fail to provide us with accurate data, we may not be able to properly provide you with our services.
What information do we collect and how do we collect it?
In order to fulfil the purposes above, we will need to collect your personal information. We collect it from you when you initially provide it to us, every time you contact us during the administration of our relationship with you, and from additional sources such as background checks and/or references. Information is collected when you meet with us, complete forms, correspond with us, telephone us, or send us an email. We may also get your personal information from Providers during the management of any financial products you take out, such as for example, a pension Provider in the case of crystallisation of a pension, or an insurance company in the case of an insurance claim.
This information can include all, or a combination of any of the items listed below depending on the nature of your relationship with us:
Personal information about others:
We may collect information about other members of your household or family e.g. family members on whose life you take out a life insurance policy.
If you give us information about another person, it is your responsibility to ensure and confirm that:
Certain types of personal information are classed as “sensitive” under the Data Protection legislation, or otherwise referred to as “special categories” of data. This includes information about your health, race, ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.
In order to offer advice or find suitable products and/or services, LMS Partners needs to collect special categories of data (such as health data for insurance advice) during the normal course of our business. We must get your separate explicit consent to process and disclose any special categories of data.
Sometimes we may indirectly come across sensitive information. In the event we are likely to (or do) come into possession of your sensitive personal data, we will contact you separately to seek your consent for its processing.
How do we use your personal information?
We store and process the personal information that you (or third parties) have provided to us in any or all of the following ways:
Information you submit through our website may be held and processed by our Internet Service Provider, but it is only held and processed on our behalf and under our strict instruction.
Disclosure of Personal Information:
During the term of your relationship with us we may disclose your personal information to any of the following parties to allow us to properly manage our relationship with you:
Otherwise we will keep all of your personal information confidential unless you give us consent to transfer it to a third party.
It is not normally necessary during the usual course of business to transfer your personal data outside of the Isle of Man or the UK, however, in the event it is necessary, it will be done so in accordance with the requirements of Data Protection legislation. These requirements include the provision that the recipient of your personal data must have the same level of protections in place as you are entitled to on the Isle of Man or in the UK. We will advise you in the event that your personal data is to be transferred in this manner.
The exception to this is, if you as a customer live outside the Isle of Man, UK or the EEA and we are sending your personal information back to you, this will be necessary in order to communicate with you and for providing you with our services. Our e-mails including confidential information are subject to encryption and any sensitive documentation will be sent via registered mail.
Fraud Prevention Agencies:
We may share your personal information with fraud prevention agencies if we feel fraud has been or might be committed. These agencies collect, maintain and share data on known and suspected fraudulent activity for the purposes of fraud prevention. These records may be searched and shared with other organisations by the fraud prevention agencies.
We have a legal obligation to report suspected fraud to law enforcement agencies.
The fraud prevention and law enforcement agencies we share data with are:
Please telephone or write to us at the address stated below if you would like further details of the fraud prevention agencies.
How long do we retain your personal information?
We are permitted by law to retain your information for as long as is necessary in relation to the purposes for which the information was originally provided. This includes our legal requirement to hold information for at least 6 years following the termination of a customer relationship or transaction.
We will therefore hold your personal information, accounting records, client due diligence (CDD) and transaction records for a minimum of six years following the termination of our relationship with you, except in the following circumstances:
If you have been unsuccessful in applying for a job with us, we will retain your information for a maximum of 6 months unless you give us permission to retain it for longer.
Once your information is no longer necessary, it shall be destroyed in accordance with Data Protection legislation.
Under Data Protection legislation you have the following rights free of charge. To exercise these rights, please contact us using any of the methods detailed below.
Access to Personal Data
Subject to exceptions detailed in Data Protection legislation, you have a right of access to all personal data we hold about you. If you wish to exercise this right, or you have any questions regarding your personal data, please write to the Data Protection Officer at the address overleaf. We will respond within one month from receipt of a valid request, and in any event, without undue delay.
Automated Decision Making:
LMS Partners does not use any kind of automated decision-making technology.
You have the right to the rectification of inaccurate data, and to obtain completion of incomplete personal data. To correct or amend your personal data, please contact the Data Protection Officer at the address below with the details. We will make the required changes as soon as possible.
In certain situations, you have the right to request that your personal data is erased, however, there are limitations to this right.
Examples of grounds for exercising your right to erasure include:
Examples of limitations to your right of erasure include:
Restriction of Processing
You have the right to restrict our processing of your personal data in the following circumstances:
If you wish to exercise this right, please contact the Data Protection Officer at the address overleaf with the full details.
You have a right to receive your personal information that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to have this personal data transmitted to another data controller (i.e. another business), where technically feasible.
Right to Object
You have the right to object to us processing your personal data in the following circumstances:
Right to Lodge a Complaint
If you have a complaint regarding the way we are processing your personal data, please address it with us in the first instance in the hopes that we will be able to resolve the matter with you. However, if you do not want to address your concerns to us, or we have failed to satisfactorily respond to your complaint, you have the right to complain to the Data Protection Supervisor. The contact details are below:
First Floor, Prospect House
Isle of Man
Tel: +44(0) 1624 693260
If you wish to receive information about our products or services, please let us know by any of the contact options provided below.
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Online advertising we use
Google analytics & re-marketing
Our websites use Google analytics and Google's re-marketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on Google partner network websites. Likewise, users that are similar to the visitors of our websites can be addressed. The advertising will be displayed through the use of web cookies. Using cookies, the user behaviour on a website can be analysed and subsequently utilised to provide targeted product recommendations and advertising based on the user's interests.
How Google uses data
The Data Protection Officer and Contact Details:
If you have any questions or concerns regarding this notice or you wish to exercise your rights, please contact us, addressing your query to the Data Protection Officer, using any of the following methods:
Writing: LMS Partners Limited, 14 Athol Street, Douglas, Isle of Man, IM1 1JA
Telephone: +44 (0)1624 666888