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Bromige Financial is committed to protecting your personal information.
Angela Vaughan - Data Protection Officer
3 Riverview Business Park
Station Road, Forest Row, East Sussex, RH18 5FS
Information about you that we collect and use includes:
information about who you are, e.g. your name, date of birth and contact details
information connected to products or services recommended by us, e.g. your bank account details
information about your contact with us, e.g. meetings, phone calls, emails, letters
information that is automatically collected, e.g. via cookies when you visit our website
information classified as ‘sensitive’ personal information, e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it is needed to provide you with products or services for which we are making recommendations or to comply with our legal obligations
information you may provide us about other people, e.g. joint applicants or beneficiaries for products
information on children, e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
A cookie is a small file – it’s saved onto your computer or other device when you visit our website.
Cookies store small pieces of information. For example - they will remember you have visited our website or performed a certain action.
Cookies also let us know which pages of our website you visited; they help us develop and market products and services.
persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
session cookies - these expire when you close your web browser
When someone visits www.bromige.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
We may collect your personal information directly from you, from a variety of sources, including:
an application form for a product or service
telephone conversations with us
emails or letters you send to us
meetings with one of our financial advisers
participating in research surveys to help us understand you better and improve our service
online services, such as our website
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources, e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
you have given us your permission [consent] to send you information about products and services recommended by ourselves and/or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
it is necessary to provide the product or service recommended to you, e.g. if you wish to invest in a pension or savings product, we will require some personal information including your name, address, date of birth, bank account details
it is necessary for us to meet our legal or regulatory obligations, e.g. to tell you about changes to our terms and conditions or for the detection and prevention of fraud
it is in the legitimate interests of Bromige Financial, e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from recommended products or services; where we need to process your information to better understand you and your needs so we can send you more relevant communications about recommended products and services you have with us; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
it is in the legitimate interests of a third party, e.g. sharing information with a product provider to enable an application for a product to be completed and accepted
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with recommended products or services.Who we may share your in
We may share your information with with third parties for the reasons outlined in 'What we collect and use your information for.'
These third parties include:
companies with common directors, e.g. Bromige Services (UK) Limited
product providers, e.g. investment, protection, pension, mortgage, insurance providers
companies we have chosen to support us in securely maintaining your data electronically, e.g. Bluecoat Software, Autotask Workplace
companies we have chosen to support us in delivering compliant files, e.g. Millen Compliance Limited, Trust Paraplanning
companies we have chosen to support us in delivering professional advice, e.g. accountants, solicitors
our regulators and supervisory authority, e.g. Financial Conduct Authority (FCA), Information Commissioner’s Office for the UK (ICO)
law enforcement, credit and identity check agencies for the prevention and detection of crime
HM Revenue & Customs (HMRC) e.g. for prevention of tax avoidance
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
We will keep your personal information only where it is necessary to provide you with recommended products or services while you are a client.
We may also keep your information after this period, but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
You have several rights in relation to how Bromige Financial uses your information. They are:
Right to be informed
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our privacy notice.
Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Bromige Financial to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we do not use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were looking to move to another adviser.
Right to object
You can object to Bromige Financial processing your personal information where: it is based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our privacy notice, please write to Angela Vaughan - Data Protection Officer at Bromige Financial, 3 Riverview Business Park, Station Road, Forest Row, East Sussex RH18 5FS or email her at firstname.lastname@example.org
We will do our utmost to make things right.
If you are still unhappy, you can complain to our supervisory authority at www.ico.org.uk