Privacy and Cookie Policy

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

LifeAssureOnline is a trading style of AFH Independent Financial Services Limited, which is authorised and regulated by the Financial Conduct Authority. www.fca.org.uk/register. Financial Services Register no. 216704. Registered in England and Wales. Company no. 04049180. Registered Office: AFH House, Buntsford Drive, Stoke Heath, Bromsgrove, Worcestershire, B60 4JE.

AFH Independent Financial Services Limited is a wholly-owned subsidiary of AFH Financial Group Plc (company no: 07638831).

AFH Financial Group Plc collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.

AFH Financial Group Plc, a company registered in England and Wales (company number 07638831) whose registered office is at:

AFH House,
Buntsford Drive,
Stoke Heath,
Bromsgrove,
Worcestershire,
B60 4JE

The personal data we collect and use

In the course of providing our service to you we may collect the below personal data when you provide it to us. For clients who join us through an acquisition this information may be provided by the vendor:

contact information
identity information
financial information
product details
employment status
lifestyle information
health information
data about criminal convictions or offences
details of any vulnerability
details of your dependents and/or beneficiaries under a policy – If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below

Information collected from other sources

We also obtain personal data from other sources in the course of providing our services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

The personal data we obtain from other sources may include the following:

From lenders and/or product providers:
- product details
From identification and verification checking agencies:
- identity information
- sanction check information

How we use your personal data

The below table sets out how we use your personal data. In each of these instances we have determined that consent and legitimate interest form the lawful basis of collecting and using personal data.

Rationale/Reason for Processing	Lawful Basis for Processing
Provision of services Adviser engagement To manage client’s accounts with us To complete transactions on client’s behalf To provide clients with information on advice, products and services provided To process any payments Product selection In order to carry out the above we may routinely share personal data with product providers where necessary.	Consent/Legitimate Interests
Anti-Money Laundering Requirements To verify identify of clients To verify address of clients	Legitimate Interests
Marketing To contact clients with details of services offered by the AFH Group of companies To write to clients about third party products or services that we may believe would be of interest	Consent
Monitoring of your personal data To monitor activities where we are required to do so by law To fulfil our regulatory obligation to record certain types of telephone calls	Legitimate Interests
Legal and regulatory requirements	Legitimate Interest

How we store your personal data

We hold your personal data in electronic format in secure server drives. We also hold personal data in a secure web-based back office system. We may also keep paper copies of personal data where necessary. For full details on storage locations please contact our Data Protection Officer

Special category data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

We may process:

Health information and lifestyle information when providing services in relation to a protection insurance product; and/or annuity products

In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.

Marketing

We may use personal data we hold about you to provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and will do so in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:

By phone: 01527 577 775

By email: privacy@afhgroup.com

By Post: AFH House,

Buntsford Drive,

Stoke Heath,

Bromsgrove,

Worcestershire,

B60 4JE

Cookies

When you visit the LifeAssureOnline website we may use a short text file called a ‘cookie’ which is downloaded to your computer. Many websites do this, because cookies facilitate useful features such as the ability to identify whether a user has successfully logged into the site or to find out whether the computer (and probably its user) has visited the website before.

During the course of your visit, we (and our service providers) may use cookies and other technologies to automatically collect the following information:

Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;

Information about your visit, including the websites you visit before our website and the components of our website you viewed during your visit; the number of visits, length of visits to certain pages, pages viewed, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page; and similar information for additional content that can be accessed from website pages, such as opening or printing pages or documents.

Your personal information is important to us and will be used solely by us. Under no circumstances will your personal informational be sold or used by any other organisation.

Whether information has to be provided by you, and if so why

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, you must provide your personal data in order for us to provide you with our services.

How long your personal data will be kept

We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.

We will usually retain your information for a period of up to 9 years from the point at which AFH are no longer deemed to be your servicing agent, dependent upon the type of product you have been advised upon.

If you are unsure of who your servicing agent is, you can contact us or alternatively speak to your provider.

Where we have provided you with advice or srvices relating to pensions transfers, conversions, opt-outs of Free-Standing Additional Voluntary Contribution Schemes, we may retain your information indefinitely in order to comply with our legal and regulatory obligations in relation to these products.

Transfer of your information out of the EEA

There are certain suppliers we deal with as part of the services we offer to you which are outside the EEA. If we provide you with advice relating to such suppliers your data may be transferred outside the EEA.

Such countries do not have the same data protection laws as the United Kingdom and EEA and we will therefore conduct due diligence on such suppliers to ensure your privacy rights are protected.

You have a right to ask us for more information about the suppliers and safeguards we have put in place as mentioned above. To learn more, please see ‘Your rights’ below.

Your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

To access personal data
To correct / erase personal data
To restrict how we use personal data
To object to how we use personal data
To ask us to transfer personal data to another organisation
To object to automated decisions
To understand how we protect information transferred outside Europe
To find out more about how we use personal data

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We will not ask for a fee other than in exceptional circumstances.

We aim to respond to all valid requests as quickly as possible. We will always let you know if we think a response will take an extended period of time. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example

where you think the information is inaccurate and we need to verify it;
where our use of your personal data is not lawful but you do not want us to erase it;
where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

To obtain a copy of our safety measures for transfers outside of Europe

You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the European Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position, or create a security risk.

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.

If you would like to exercise any of the above rights, please:

email or write to our Data Protection Officer at: privacy@afhgroup.com or; AFH House, Buntsford Drive, Stoke Heath, Bromsgrove, Worcestershire, B60 4JE
let us have enough information to identify you, e.g. name, address, date of birth;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us

Please contact our Data Protection Officer if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact our Data Protection Officer, please send an email to privacy@afhgroup.com or write to: