Our Privacy Notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. We hold such information as Data Controllers in accordance with the requirements of the Data Protection Act 2018 and the UK General Data Protection Regulation (“GDPR”), together referred to as the ‘Regulations’. We are committed to collecting and using such data fairly and in accordance with the requirements of the GDPR.
‘Personal data’ is any information that relates to an identified or identifiable natural person (rather than to a legal entity, such as a company).
We take your privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information.
When we say ‘Jarrovian’, ‘we’, ‘our’, or ‘us’ in this Privacy Notice, we are generally referring to the separate and distinct legal entities that make up the Jarrovian Group and the below act as controller for the personal information you provide to us. These include:
It also includes any other businesses we add to this group in the future.
You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use. In addition, you have a right to complain to us and to the data protection regulator. Contact details are shown here.
We need to obtain information about you, so that we can provide the financial advice you require, including:
This information is normally obtained directly from clients in a face to face meeting. It may also be obtained by telephone, post or other means. We may also obtain some personal information from recording calls or meetings or by making contemporaneous notes of calls or meetings.
In some cases, we collect this information from other organisations such as investment/pension/insurance providers, where you have provided authority for them to share information relating to your existing plans, public registers, public administration or other third-party sources, such as wealth screening services, fraud prevention agencies, and intermediaries that facilitate data portability.
If relevant, we will also collect information about your additional account holders, business partners (including other shareholders or beneficial owners), dependants or family members, representatives, and agents. Before providing us with this information, you should provide a copy of this notice to those individuals.
The legal basis on which the information that you provide will be collected and processed with your explicit consent. Where you have given us consent, you have the right to withdraw it at any time.
Depending on the purpose of the processing activity, the processing of your personal data will be one of the following:
To the extent Jarrovian has obtained your consent to process ordinary personal data in the past in any product-specific terms and conditions for the purposes of data protection law only, Jarrovian will no longer rely on such consent, but instead will rely on lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this notice), and Jarrovian’ ability to rely on that consent is hereby waived or extinguished.
Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this personal data there is a possibility we may be unable to take you as a client or provide products or services to you (in which case we will inform you accordingly).
Purposes of processing
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for the following purposes:
You have the right to see what personal information we hold about you and you can ask us to correct inaccuracies, delete or restrict personal information or ask for some of your personal information to be provided to someone else. You have the right to object to how we use your personal information. If you need to contact us in relation to any of your rights or wish to make a complaint about how we have used your personal information directly to us or to the Information Commissioner’s Office, you can use the contact details indicated on the section ‘Your Rights’.
We take security measures to protect your information including:
As complete data security cannot be guaranteed for communication via e-mails, instant messaging and similar means of communication, we would recommend sending any particularly confidential information by an alternative secure means.
Jarrovian will not retain your personal information longer than necessary. We will hold onto the information you provide either while your account is in existence, or as needed to be able to provide the product and services to you, or for as long as is necessary to provide support-related reporting and trend analysis only.
If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, or it is no longer needed to provide the product and services to you.
We are concerned to protect the privacy of children aged 13 or under. If you are aged 13 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Category Personal Data.
As part of the product and services offered to you, the information which you provide to us may be transferred to countries outside the European Union (“EU”). These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Notice.
If you use our products and services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
At the end of the Brexit transition period, EU GDPR was kept in UK law as the UK GDPR.
The Data Protection Act 2018 and Privacy and Electronic Communications Regulation (PECR) will continue to apply alongside the UK GDPR. This means that in practice there is little change to the core data protection principles, rights and obligations found in the UK GDPR.
Following the new trade deal with the EU at the end of the Brexit transition period, the UK Government legislated so that UK firms could continue to lawfully send personal data from the UK to the EEA and 13 other countries deemed by the EU as ensuring an adequate level of protection of personal data.
On 28 June 2021, the EU Commission confirmed that the UK’s data protection laws are robust enough to ensure data can safely flow to the UK from the EU without firms having to make changes to their data protection practices. These decisions are expected to last until 27 June 2025.
The Information Commissioner’s Office (ICO) is the regulator for data protection issues in the UK. The ICO continually updates its guidance to reflect the agreed provisions and we will ensure our business remains fully compliant.
This Privacy Notice was updated in October 2022. This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on relevant websites to notify you of any significant changes to our Privacy Notice and indicate at the top of the Notice when it was most recently updated. If we update our Privacy Notice, in certain circumstances, we may seek your consent.
If you have any questions or comments about our Privacy Notice, Jarrovian’s privacy practices or if you would like us to update information or preferences you provided to us, you may write or e-mail us at:
Jarrovian Group Ltd
Chief Information Officer
25 City Road
Phone: 0330 0585 000
For a no-obligation consultation with one of our Financial Planners, please call 0330 058 5000