Proposito Financial Planning Limited is a company registered in England & wales (collectively referred to as Propostio Financial Planning, “we” or “us” in this policy).
This policy applies when you visit and interact with our website at https://proposito.co.uk/ and to the financial services that we provide to you. It contains information about:
– how we use your data;
– what personal data we collect;
– how we ensure your privacy is maintained; and
– your legal rights relating to your personal data.
More details are below
Purpose of this privacy notice
Our full details are:
Name: Proposito Financial Planning Limited
Email address: firstname.lastname@example.org
Postal address: 4 Dollar Street, Cirencester, GL7 2AJ
Telephone number: 01285 708444
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 16th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with certain services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
2. Providing your name, telephone number and email address in the ‘Request a callback’ function on the Website
3. When you contact us via email by clicking on the email address links or ‘get in touch’ links on the Website
Marketing and Communications
(b) Asking you to leave a review or take a survey
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We use the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us by completing forms or submitting an enquiry via our website.
We will share your personal data with our marketing agency for marketing purposes.
You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions or in accordance with applicable laws.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.
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“I have worked with Russell Haworth of Proposito for 12 years now, and during that time I have been given very good and professional advice.
We have regular face to face meetings including the use of their bespoke computer system showing my current and future financial positions, which I find very helpful in explaining the different scenarios for my forward planning. I have always been keen to have a low risk strategy for my portfolio, and this has always been managed to my complete satisfaction.
Russell is always ready to listen and to come up with constructive solutions for any questions that I may put to him. Proposito is a company of a size that makes it easy to speak to someone directly and, get quick answers, unlike other larger organisations.
In conclusion I would recommend anyone looking to make sound and safe investment decisions to look no further than Proposito.”
“I needed a financial advisor as I was finding that my funds were just being left in bank accounts, and whilst very safe I was not achieving any growth. I do not have the personal knowledge on investment, and wanted to be able to work with a small team where I could get one on one service. I have had Financial Advisors previously from larger companies and found that staff kept changing so I never had a consistent relationship, and also they were very keen to sell me new policies to start with and then the level of service dropped off.
Russell Haworth was known to me and I liked the way he presented his recommendations. He has made me think about the investments and made me feel much more in control of my overall finances. Sitting down and actually working out how much you spend each year makes you think what you will need in the future. The computer programme which shows your income and costs year by year is brilliant, and allows you to ask the “what if” questions and get almost immediate answers.
It is great to be able to openly discuss your future plans, and it makes you think about things properly. I have been very reassured about my future, and in the event there is an unplanned change I feel confident that my finances are in safe hands.”
“Due to the bewildering amount of financial legislation and financial planning options that seemed to be available to us when searching online we felt like we needed some guidance. For 14 years now Huw has done a fantastic job of highlighting the issues we have needed to consider (be they in relation to pensions, forward planning, investment or taxation) and presenting our various options in streamlined and coherent way. As a result of Huw’s advice we now feel on top of our finances with a secure financial future and a plan in place that is regularly revisited and revised.
Huw has also been very diligent assessing our attitudes to risk over the years and has taken that into consideration at all times when advising.
He (& Proposito) have always provided an efficient service, the staff are personable and helplful and queries are dealt with impressively quickly.”