Privacy Policy

www.towerhillassociates.com

At Tower Hill Associates Limited we are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us. This Privacy Policy, together with our terms of use, explains what happens to any personal data that you provide to us, or that we collect from you when you are on this site.
We do update this Policy from time to time so please do return and review this Policy regularly.

Looking after your personal data

We want you to know that we will safeguard your personal data and preserve your privacy. This policy tells you what we do with any information you provide to us or we collect from you.

“Personal data” is the information that relates to you and allows us to identify you, either directly or in combination with other information we hold.

Who to contact about your personal data

The data controller is Tower Hill Associates Limited. The person to contact about your personal data and this policy is John Lang who can be contacted at john@towerhillassociates.com or on 020 3865 2379 or by writing to us at Tower Hill Associates Limited, Oriel House, 26 The Quadrant, Richmond, Surrey TW9 1DL.

The information we collect and what we do with it

We may collect and process the following data about you:

  1. Details of your visits to our website and the resources you access. This is limited to your Internet Protocol (IP) address. This information may be aggregated to provide statistical information about the users of our website. No individual user will be identifiable from such information, which is used to ensure the website reflects the needs of users. Whilst IP addresses may be categorised as personal data, we do not use this data to track your access.
  2. Information that you provide when filling in forms on the website. This information will usually include at least your name, email address and a telephone number. We will use this information to contact you to discuss our services.
  3. Information provided to us when you communicate with us. This information will be dependent on what you choose to provide but may include your name, date of birth, nationality, email address, phone number and an outline of your personal circumstances, including investments, employment and earnings. We will use this information to contact you to discuss our services.

Information about your health

In the provision of our services to you it may be necessary to obtain information about your health. Where this is necessary we will obtain your specific permission to have the data at the time it is requested.

How we use your information

The information we collect and store about you is used to enable us to provide our services to you.

  1. If you are not a client we use the information to discuss the services we could provide to you and we will obtain your agreement to use your personal data at the outset of our initial meeting with you.
  2. If you are a client we use the information to provide our contracted financial advisory services.

Prior to you becoming a client we will also use the information to comply with relevant regulations and obligations including those relating to the prevention of money laundering and funding of terrorism, fraud and crime prevention. This includes carrying out checks to verify your identity.

How we store your information

Data provided to us is stored on our secure servers and we have processes in place to protect the confidentiality, integrity and availability of personal data. Data is backed up to a remote location on a daily basis meaning we are able to restore data in the unlikely event of a technical or physical incident.

We will treat all your personal data as private and confidential and will not process it other than for the purposes set out above. We will take all reasonable steps to safeguard your data against unauthorised or unlawful processing and accidental loss or destruction or damage of that data.

There are inherent risks involved when transmitting personal data by post, email and phone or through our website. We will do everything possible to limit these risks and secure your personal data from unauthorised or unlawful processing or against accidental loss, destruction or damage.

Sharing your information

In order to implement our advice to you we may need to share your personal data with the recommended provider.

On occasion it may be necessary for us to engage the services of an expert consultant to assist us in the provision of our services. There is a contract in place between us and the consultant which includes terms that confirm they have in place processes and procedures to protect your data and enable you to exert your rights in respect of your data. All such consultants are subject to due diligence and annual review which includes consideration of their processes as regards data security.

In both of the above circumstances we will make you aware of our intention to share your information along with the name of the third party.

There may also be circumstances where we are required to provide your information as a consequence of regulatory or legal process.

We do not undertake marketing activities for third parties, nor do we provide information to third parties for their own marketing purposes.

Children

We will only obtain and process personal data in respect of children where one or both parents are an existing client and only for the purpose of providing our contractual services to the parents should they want to make tax efficient investments on behalf of their children (e.g. ISAs and SIPP contributions).

We obtain the permission of the parent before obtaining and processing the data.

When a child reaches 18 we will request that they enter into their own contract with us for the provision of financial planning services.

How long will we keep your information?

For personal data obtained before you are a client we will retain this data until you have decided whether or not our services are suitable for your requirements.

If you do not become a client you have the right to ask us to delete your information. Notwithstanding that right we will delete the information if we have not heard from you within twelve months of the later of our initial contact or proposal document.

If you become a client we will retain your personal data to enable us to fulfil our contractual obligations to you and as required by law and regulation. This may mean that even if you cease to be a client we will still be required to retain the information in order to:

  • Respond to any questions or complaints
  • To demonstrate that you are, or have been, treated fairly
  • To satisfy our record keeping obligations in accordance with applicable
    legislation and regulation

Your rights in respect of your personal data

You have the right to ask us to tell you about your personal data and you can request this information using the contact details set out at the beginning of this policy. We will not charge to process your request. However, if we consider that requests are being made in a frequent, excessive and repetitive manner or on an unfounded basis we reserve the right to charge an administration fee. If you believe that any information we hold about you is incorrect you have the right to ask us to correct that information.

You can ask us to delete your personal data. For the reasons set out above it may not, however be possible for us to meet your request if we are required to retain the information for legal or regulatory reasons. Where this is the case we will explain our reasons for not being able to meet your request.

You can ask us to restrict the ways in which we use your personal data although this may mean we are unable to continue to provide our services to you. Where this is the case we will explain the consequences of any restriction.

Your right to complain

Please let us know if you are unhappy with how we use your personal data by contacting the address at the beginning of this policy.

You also have the right to complain to the Information Commissioner’s Office. Details of how to complain to them can be found on their website – ico.org.uk

Using cookies

We may gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you.

All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies.

Third party links

You might find links to third party websites on our website. We are not responsible for the privacy policies of third party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered via, our website.

Changes to privacy notice

We update this policy from time to time and therefore please consider revisiting it on a regular basis.

May 2018

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