CUSTOMER PRIVACY

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This privacy notice explains:

In this document, “We”, “Us” and refers to Mortgages for Yacht Crew, Quilter Financial Planning and its subsidiary companies.

Who we are

At Mortgages for Yacht Crew we respect your privacy and the confidentiality of your personal information.

Mortgages for Yacht Crew is an appointed representative of Quilter Financial Services Limited {and Quilter Mortgage Planning Limited}

Mortgages for Yacht Crew provide financial planning solutions and advice through experienced and qualified advisers based in the UK.

Currently, Mortgages for Yacht Crew and Quilter Financial Planning (Quilter) jointly determine the purposes and means of processing personal client data relating to giving advice. This means we’re joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.

However, Mortgages for Yacht Crew is solely responsible for some activities, for example any direct marketing that we undertake.

We will comply with relevant data protection law. Such laws require that the personal information we hold about you must be:

Your rights

We try to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below

You have the right to ask us:

In certain circumstances you also have the right to:

Exercising your rights

For information about your individual rights, including how to correct, restrict, delete, make changes to your personal information or if you wish to request a copy of the personal information we hold about you, please contact us by emailing us at QFPDataGuardian@quilter.com.

More information about your data protection rights can be found on the Information Commissioner’s Office (ICO) website.as well as on other regulators’ websites.

If you would like to write to us, our postal address for data protection matters is:

The Office of Data Protection
Quilter Financial Planning
Senator House
85 Queen Victoria Street
London
EC4V 4AB

However, we have adopted a flexible model for working so please note that written communications will take longer to respond to.

Further information

This privacy notice was drafted with brevity and clarity in mind, however further information can be obtained by contacting us using the details in the "How to contact us" section. More information about your data protection rights can be found via:

What personal information we collect

Personal data means information by which you may be personally identified directly or indirectly.

We collect certain personal information about you, this includes your name, address, or phone number and other information. We collect this information about you when you:

The type of personal information we collect will depend on the purpose for which it is collected and may include:

We collect personal information directly from you. For example, we ask for personal information at the start of our relationship (e.g. when you apply for a policy or service) and in subsequent communications in order to manage our relationship.

If we provide a service to your employees or a scheme, then personal data in relation to those employees or members of the scheme isn’t processed by Us as part of the standard corporate advice process. This information is normally provided directly to the product provider.

In limited circumstances, we may need to collect employee personal data, and where we do, we act as data processer and it’s therefore provided to Us by yourself, with the knowledge and consent of your employees.

Where we provide our services to trusts, we collect the personal information listed for the settler, beneficiaries and trustees of that trust. Where we provide our services to companies we may collect personal information for Directors, Shareholders and Beneficial Owners of the company. Where we provide our services to charities, we may collect personal information about the trustees or directors of that charity.

We may also collect information about you from other sources such as:

Data Retention

We keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information will be securely disposed of when it is no longer required in accordance with our Personal Data Retention Standard.

Advice data is retained for 50 years to meet our regulatory requirements.

Special category data and criminal conviction data

We may also gather more sensitive personal data, called special category data, for example, as part of recruitment. This type of data can include racial or ethnic origin, genetic or health information or sexual orientation. The processing of some of this data is necessary for us to fulfil the obligations on us. In such cases, we will always explain this during the process and explain what information we require and why it is needed. Where we do require it, we will always seek your consent. Special category data will always be processed and stored securely.

Where it is necessary, we may also collect information relating to an individual's criminal convictions. If this is the case we will explain what information we require, why it is needed and where required, will ask you for consent.

Cookies

We also collect information about you from other sources. For example, our website automatically collects information from your computer using “cookies” which provides us with limited personal information. Cookies are small text files that are placed on your computer by websites that you visit. They’re widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners.

More information about the cookies we use on our website can be found here: https://www.quilterfinancialadvisers.co.uk/cookie-notice/.

How we use your personal information

We process your information for the following purposes.

We may also process your personal data as part of an acquisition or sale. Should this happen, you’ll be notified about any change to processing or data controller arising as a result of this activity.

You have the right to object to us processing your personal information for some of the business purposes listed above but, if you do so, this may impact on our ability to provide some or all of our services to you.

We won’t process your employee’s data for the business purposes above. Our contractual relationship is with you and therefore any processing of data for business purposes will be undertaken with your data, not your employee’s.

Profiling

Profiling involves the use of basic identifiers about you such as your name and address and matching this with information from Experian Marketing Services to create demographics and infer customer ‘types’. This helps us define groups based on factors like interests, age, location and more so we can better understand our customers to adapt and improve our products and services. If you would like to know more about the information we get from Experian Marketing Services, you can visit their Consumer Information Portal which explains who Experian Marketing Services are, what they do and why.

Lawful basis

We operate under a number of legal bases as required under the regulations. These include:

Who we share your information with and why

We share your information with trusted third parties and service providers who perform tasks for us and help us to provide our products and/or services to you, and with other agencies where required by law, court order or regulation. These may include:

If you would like further information regarding the specific named recipients that we share data with, please contact us using the information in the “How to contact us” section.

How we keep your information secure

We’re committed to ensuring the confidentiality of the personal information that we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure and prevented from unauthorised or accidental access, processing, copying, modification, erasure, loss or use.

If we work with third parties in countries outside the United Kingdom, we ensure these are countries that the UK Government and the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards and agrees to treat your information with the same level of protection as we would.

We also utilise UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the United Kingdom or European Economic Area.

In limited circumstances, data may be accessed outside of the UK i.e. by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.

How to manage your marketing consents

You may give and withdraw consent to the receipt of marketing information at any time. If you wish to change your preferences regarding the receipt of marketing or other communications from us, the simplest way is to use the ‘unsubscribe’ link at the bottom of any marketing communication.

Alternatively, you can contact us using any of the mechanisms included in the ‘How to contact us” section of this notice.

How to contact us

If you have questions about this notice, or need further information about our privacy practices, or wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection team who will investigate the matter.

Quilter Financial Planning
The Office of Data Protection
Quilter Financial Planning
85 Queen Victoria Street
London
EC4V 4AB

Email: qfpdataguardian@quilter.com