Privacy Policy

How we use your personal information

Your information will be held by Profile Financial Solutions Limited, trading as Profile Pensions. This privacy notice is to let you know how Profile promises to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice also tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

To keep your data safe and private.
Not to sell your data.
To give you ways to manage and review your marketing choices at any time.

Personal information and the law

This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.

Who we are

This section gives you the legal name of the company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.

Profile Financial Solutions Limited trades as Profile Pensions. You can find out more about us at https://www.profilepensions.co.uk.

Please use these details to contact us about any of the topics set out in this Privacy notice.

If you have any questions, or want more details about how we use your personal information, you can ask us as follows:

By telephone: 01772 804 404

By e-mail: [email protected]

By post: Profile Pensions

Norwest Court

Guildhall Street

Preston

PR1 3NU

Lines are open from:

9.00am to 8.00pm – Monday to Thursday
9.00am to 5.00pm – Friday
Closed – Saturday and Sunday

Calls will be monitored or recorded.

If you are not satisfied with our response, you can contact our Data Protection Officer.

How the law protects you.

This section sets out the legal reasons we rely on, for each of the ways we may use your personal information.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Profile Pensions. The law says we must have one or more of these reasons:

To fulfil a contract we have with you, or
When it is our legal duty, or
When it is in our legitimate interest, or
When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

For reasons of substantial public interest, or
To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

How we use your personal information	The legal basis for doing so	Our legitimate interests
Serving you as a customer
To provide, manage and personalise our services to you To develop and carry out marketing activities To study how our customers use our services To communicate with you about our services	Your consent Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Developing our services and what we charge for them Seeking your consent when we need it to contact you Being efficient about how we fulfil our legal and contractual duties
To manage complaints and respond to queries	Fulfilling contracts Our legal duty Our legitimate interests	Investigating complaints efficiently and reaching the right outcome Liaising with the Financial Ombudsman Service Learning from such investigations to prevent complaints arising in the future
Business improvement
To test new ways of delivering our services To manage how we work with other companies that provide services to us and our customers To develop new ways to meet our customers’ needs and to grow our business	Fulfilling contracts Our legitimate interests Our legal duty	Developing our service and what we charge for them Making sure we offer our services to the right types of customers Being efficient about how we fulfil our legal and contractual duties
Managing our operations
To deliver services to our customers To work with product providers and fund managers to deliver the products and funds that suit our customers’ needs	Fulfilling contracts Our legitimate interests Our legal duty	Being efficient in fulfilling our legal and contractual duties Complying with rules and guidance from regulators
To record and monitor all communications with our customers	Our legal duty Our legitimate interests	To develop and improve our systems and processes To train our staff To provide our customers with a high standard of service
Managing security risk and crime prevention
To detect, investigate, report and try to prevent financial crime To manage risk for us and our customers To obey applicable laws and regulations To verify your identity before we provide services to you and discuss your personal information with you	Fulfilling contracts Our legitimate interests Our legal duty	Developing and improving ways of dealing with financial crime, and meeting our legal duties Complying with rules and guidance from regulators Being efficient in fulfilling our legal and contractual duties
Business management
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, developing and testing systems and processes, managing communications, corporate governance and audit.	Our legitimate interests Our legal duty	Complying with rules and guidance from regulators Being efficient in fulfilling our legal and contractual obligations
To exercise our rights set out in agreements or contracts	Fulfilling contracts
Marketing activities
To contact you with information on the services we can offer, unless you have opted out of marketing or we are otherwise prevented by law from doing so	Our legitimate interests Consent	Where it is in our legitimate interests to provide you with information about our services In relation to direct electronic marketing, where we have your consent to contact you in this way
Processing special categories of personal data
Substantial public interest	Using criminal records information to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour
Responding to regulatory requirements	Ensuring we have delivered services to our customers in a compliant way Providing information to the regulator should they request it
Legal claims	Using any special categories of data as necessary to establish, pursue or defend legal claims
Consent	Telling you that we need your consent to process special categories of personal data, when we rely on your consent to do so

Groups of Personal Information

This explains what all the different types of personal information mean, that are covered by data protection law.

We use many different kinds of personal information. They are grouped together like this. The groups are all listed here so that you can see what we may know about you. We don’t use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.

Type of personal information	Description
Financial	Your financial position
Contact	Your name, where you live and how to contact you
Socio-demographic	This includes details about your work or profession, nationality, education and where you fit into general social or income groupings
Transactional	Details about payments you make into, and withdrawals from your pension
Contractual	Details about the services we provide to you and the products we arrange for you
Locational	Data we get about you. This may come from your mobile phone or the place where you connect a computer to the internet.
Behavioural	Details about how you use our services and the products we arrange for you
Technical	Details about the devices and technology you use
Communications	What we learn about you from the letters, e-mails and telephone conversations between us
Social relationships	Your family, friends and other relationships
Open data and public records	Details about you that are in public records, such as the Electoral Register, and information that is openly available about you on the internet
Usage data	Data about how you use our services and the products we arrange for you
Documentary data	Details about you that are stored in documents or copies of them. This could include things like your passport, drivers licence or birth certificate
Special types of data	The law and other regulations treat certain types of personal information as special. We will only collect and use these types of data if the law allows us to do so: Racial or ethnic origin Religious, political or philosophical beliefs Trade union membership Genetic and biometric data Health data Lifestyle information Criminal records of convictions and offences Allegations of criminal offences You can read about how we may use special types of data in the table “How the law protects you”
Consents	Any consents, permissions or preferences you give us. This includes how you want us to contact you
National identifier	A number or code given to you by a government to identify who you are, such as a National Insurance number or social security number, or Tax Identification Number

Where we collect personal information from

This section lists all the places where we get data that forms part of your personal information.

We may collect personal information about you from any of these sources:

Data you give to us

When you use our services and we arrange products for you
When you talk to us on the phone, including recorded calls and notes we make
When you use our websites, mobile device apps or web chat
In emails and letters
In financial reviews
In customer surveys

Data we collect when you use our services

This covers two things: details about how and where you access our services and transactions you make on the products we arrange for you.

Payment and transaction data
This includes the amount, frequency, type, location, origin and recipients.
Profile and usage data
This includes the security details you create and use to access our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our internet. We also use cookies and other internet tracking software to collect data while you are using our website or mobile apps.

Data from outside organisations

Companies that introduce you to us
Financial advisers
Credit reference agencies such as Equifax
Insurers
Retailers
Comparison websites
Social networks (for instance, when you click on one of our Facebook or Google ads)
Fraud prevention agencies
Other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
Public information sources such as the Electoral Register or Companies House
Agents, suppliers, sub-contractors and advisers
These can be types of firm we use to help us run accounts and services. They can also be specialist companies who advise us on ways to develop and improve our business.
Market researchers (who combine data from many sources to produce market trend reports and advice.)
Government and law enforcement agencies

We want to ensure that the products, services and offers we display to you when you visit our websites are as relevant as possible and are personalised to you and your likely financial profile.

To enable us to do this we will share some of the information you provide to us (which may include your name and address and/or email address details) with Experian. Once Experian have this information, they will use it to associate the device on which you are visiting our website with the information they hold about your credit status, lifestyle, likely characteristics and otherwise. Experian will use this information to return to us, an indicator of your likely credit profile and characteristics so that we can make use of this to make more informed decisions about what content you see when you visit our website. We will do this to make sure that you see information about products and services you are more likely to be interested in and eligible for.

We and Experian may also use the link between your name, address and device to ensure that the advertising and other content you see on other websites is as relevant as possible to you.

In order to enable this process Experian uses cookies placed on your device and information about the kind of device you are using, the IP address you are accessing the internet from and other information such as your location. By using our website, you agree to Experian collecting and using this information for the purposes described above. You can find out more about how this process works by visiting Experian’s information page at

https://www.experian.co.uk/marketing-services/consumer-information-portal/

You have a choice about whether or not you want your information to be used in this way and you can set your preferences by visiting this page. This won’t stop you from seeing information about our products and services when you visit our website, but it will mean that the information you do see may not be as relevant to you and your circumstances. Equally, if you choose not to have your information shared with Experian, you will still see advertising on other websites but the adverts you see might be of less interest or relevance to you.

How long we keep your personal information

This section explains how long we may keep your information for and why

We will keep your personal information for as long as you are a customer of Profile Pensions.

We may keep your data for up to 10 years after you stop being a customer. The reasons we may do this are:

To respond to a question or complaint, or to show whether we gave you fair treatment
To study customer data as part of our own internal research
To obey rules that apply to us about keeping records

We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. As an example, we have to hold pension transfer information indefinitely.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

If you choose not to give personal information

You can choose not to give us personal information. In this section we explain the effects this may have.

We may need to collect personal information by law, or to enter into or fulfil a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from delivering our services to you, or doing what we must do by law. It may also mean that we cannot manage your pension. It could mean that we cancel a service you have with us.

We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won't affect the products or services you have with us.

Cookies

This section contains a link to our Cookies Policy

Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.

How to complain

This section gives details of how to contact us to make a complaint about data privacy. It also shows you where you can get in touch with the government regulator.

Please let us know if you are unhappy with how we have used your personal information.

You can contact us on [email protected]. You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.

In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern .

How to withdraw your consent

This section explains what to do if you no longer want us to hold or use your personal information.

You can withdraw your consent at any time. Please contact us on [email protected] if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent. See the section 'Your Rights' about more generally restricting use of your information.

If you withdraw your consent, we may not be able to provide our services to you. If this is so, we will tell you.

Letting us know if your personal information is incorrect

Here you can find out how to contact us if you think the information we hold for you is wrong, incomplete or out of date.

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

If you want to do this, please contact us on [email protected].

Lines are open from:

9.00am to 8.00pm – Monday to Thursday
9.00am to 5.00om – Friday
Closed – Saturday and Sunday

Calls will be monitored or recorded.

How to get a copy of your personal information

This section tells you where to write to us to get a copy of your personal information, and how to ask for a digital file you can use yourself or share easily with others. You can do this online or by writing to us.

You can get a copy of all the personal information we hold about you on [email protected] or by writing to us at this address:

The Data Protection Officer

Norwest Court

Guildhall Street

Preston

PR1 3NU

When you want to share your data with outside companies

You also have the right to get certain personal information from us as a digital file, so you can keep and use it yourself, and give it to other organisations if you choose to.

If you wish, we will provide it to you in an electronic format that can be easily re-used, or you can ask us to pass it on to other organisations for you. If you want to do this, please contact us on [email protected].

Your rights

What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.

You can object to us keeping or using your personal information. This is known as the ‘right to object’.

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.

You can ask us to restrict the use of your personal information if:

It is not accurate
It has been used unlawfully but you don’t want us to delete it
It is not relevant any more, but you want us to keep it for use in legal claims
You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us on [insert DPO contact details].

Or you can call us on 01772 804 404.

Calls are monitored or recorded.

How personal information is used

Who we share your personal information with

We may share your personal information with outside organisations such as insurers, regulators or tax authorities. This is so that we can provide you with our services, arrange products for you, run our business, and obey rules that apply to us. Here we list all the types of organisation that we may share your personal information with.

Authorities
This means official bodies that include:

Central and local government
HM Revenue & Customs, regulators and other tax authorities
UK Financial Services Compensation Scheme
Law enforcement and fraud prevention agencies.

Financial services product providers, such as pension providers

Outside companies we work with to provide services to you and to run our business.

Agents, suppliers, sub-contractors and advisers
These are types of firm that we use to help us run our services.
Credit reference agencies (such as Equifax)
Other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
Independent Financial Advisors.
This could be someone who advises you on your pensions or life assurance. We won’t share any personal information unless they have your consent to ask us for it.
Price comparison websites and similar companies.

General business
Outside companies we use to help grow and improve our business.

Organisations that introduce you to us
This might be a price comparison website.
Market researchers
We send data which these firms combine with data from other sources to produce market trend reports and advice.
Advisers who help us to come up with new ways of doing business.
This might be a legal firm, IT supplier or consultancy.

How we work out what marketing you receive

We use marketing to let you know about services that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in.

We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organisations we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal information this way.

If you allow it, we may show or send you marketing material online (on our own and other websites including social media), in our app, or by email, mobile phone or post.

What you get will depend on marketing choices that you set. You can change these at any time and tell us to stop sending you marketing.

You can also tell us not to collect data while you are using our websites or mobile apps. If you do, you will still see some marketing but it will not be tailored to you. See our Cookies Policy for details about how we use this data to improve our websites and mobile apps.

Whatever you choose, you'll still receive statements and other important information such as changes to your existing products and services.

We do not sell the information we have about you to outside organisations.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can contact us to update your choices at any time.

For more information on how we might use your personal data in our marketing activities, please refer to the section headed ‘Data we collect when you use our services’.

How we use your information to make automated decisions

Fraud prevention agencies

This section deals with information we share outside our group to help fight financial crime. This includes crimes such as fraud, money-laundering and terrorist financing.

We may need to confirm your identity before we provide products or services to you or your business. This may include carrying out fraud checks at the point of sale.

Once you have become a customer of ours, we will share your personal information as needed to help combat fraud and other financial crime. The organisations we share data with are:

Registered Fraud Prevention Agencies (FPAs)
Other agencies and bodies acting for the same purpose
Industry databases used for this purpose
Insurers

Throughout our relationship with you, we and these organisations exchange data between us to help prevent, deter, detect and investigate fraud and money-laundering.

None of us can use your personal information unless we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

We will use the information to:

Confirm identities
Help prevent fraud and / or money-laundering
Fulfil any contracts you or your business has with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to prevent, detect, investigate and prosecute crime.

These other organisations can keep personal information for different lengths of time, up to six years.

The information we use

These are some of the kinds of personal information that we use:

Name
Date of birth
Residential address
History of where you have lived
Contact details, such as email addresses and phone numbers
Financial data
Whether you have been a victim of fraud
Data about insurance claims you have made
Data relating to your products or services
Employment details
Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

Automated decisions for fraud prevention

The information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We and other organisations acting to prevent fraud may process your personal information in systems that look for fraud by studying patterns in the data. We may find that a pension policy is being used in ways that fraudsters work. Or we may notice that a pension is being used in a way that is unusual for you or your business. Either of these could indicate a risk that fraud or money-laundering may be carried out against a customer, the pension provider.

How this can affect you

If we, a product provider or an FPA decide there is a risk of fraud, we may stop activity on the pension or block access to it. FPAs and cross-industry organisations may also keep a record of the risk that you may pose.

This may result in other organisations refusing to provide you with products or services, or to employ you.

Data transfers out of the EEA

FPAs and other organisations we share data with for these purposes may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Sending data outside the EEA

This section tells you about the safeguards that keep your personal information safe and private, if it is sent outside the EEA.

We will only send your data outside of the European Economic Area (‘EEA’) to:

Follow your instructions
Comply with a legal duty
Work with our partners who help us to run your accounts and services.

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:

Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website.
Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

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