DJ Alexander Financial Services Privacy Statement

Updated on 02 August 2018

The purpose of this Notice

When we provide our services to you, we will collect personal information about you and we want to be open and transparent as to the types of information we collect, why we collect it, how we use it and who we may share it with.

The data controller of your personal information is DJ Alexander Financial Services Limited, a limited liability company registered at 1-3 Wemyss Place, Edinburgh, United Kingdom, EH3 6DH with company number SC568296 ("we", or "us", or "our").

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the 'How to contact us' section.

What type of personal information will be processed and why?

We may ask you to provide personal information by filling in forms and documents or by corresponding with us by phone, e-mail or in person.

Types of personal information	Why we collect it
Identity details including your name and date of birth. We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.	To carry out money laundering and financial checks and for fraud and crime prevention and detection purposes. We will only ever use copies of identity documents for this purpose. We collect and process this personal information in order to comply with our legal and regulatory requirements.
Your contact details including your name, postal, phone and email address(es) and other personal details about you including your title, job title, marital status and date of birth.	To contact you in order for us to manage, administer and provide our services to you. To respond to any correspondence and service-related enquiries you send to us in respect of our services. To discuss products or services for which you apply or may be interested in applying for. To manage any applications you make for products or services. To communicate any updates to you including any changes to our services, the terms and conditions of any services which we have provided to you, any changes to this Notice and to our websites. To contact you in order to receive your feedback on our services and to participate in related surveys.
Financial information relating to you, including pension contributions and current value, salary, bank account balances, credit card balances details of investments and payment card details.	To evaluate your eligibility for products, including making credit searches with credit reference agencies and fraud searches with fraud prevention agencies. To enable us to advise you on your financial circumstances and the appropriateness of specific courses of action and products. We collect and process this personal information for our legitimate business interests. To enable you to make payments for our services. We collect and process this personal information as is necessary for the entry into and performance of any agreements between us (i.e. to assess whether you are eligible for products, and once an agreement has been entered into between you and us, so that we can collect payments from your payment card).
Details of your dependents (name, address and date of birth)	To enable us to provide you with services that you have requested that would involve, or have an impact on, your dependents (who may be adults or minors). Where those dependents are adults, please make sure that you have their permission to provide us with their personal information.
Details of contact that we have had with you such as meetings with you, fact-finding discussions and documentation, recommendations, referrals and quotes.	To allow us to provide a professional service to you and to contact you with information about other services of ours that we think you may be interested in). We collect and process this personal information for our legitimate business interests.
Details of services you have received.
Client experience and other feedback and information you provide to us.	To review your feedback and experience with us so that we can improve our products and services for you and for our other clients. We collect and process this personal information for our legitimate business interests (and we record calls both for quality and training purposes and to comply with our legal and regulatory obligations). Please see section below entitled "When we record communications" for more information.
Information about complaints and incidents.
Recordings of calls we receive or make.
All of the personal information described above.	We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you (including law enforcement agencies and tax authorities). We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties. We collect and process this personal information for our legitimate business interests including to carry out our own internal business planning, compliance, training, audit and quality assurance purposes.

Depending upon the types of products and services you require, we may also need to collect information from and about you which the law considers to be sensitive, such as data about your physical or mental health, which we refer to as "special category personal data". The special category personal data that we may ask you to provide, and the reasons why we ask you to provide it, are as follows:

Types of special category personal data	Why we collect it
Information about your physical or mental health or condition.	Certain products and services that you request may require this information. Specifically, in order for us to advise you on and to submit applications for health or life insurance products and services, we will need to collect information relating to your physical and mental health in order to obtain accurate quotes and to advise on the suitability of products (as insurance premiums and eligibility for products will in part depend on your physical and mental health). We will usually collect this information in the course of meetings with you, on specific questionnaires or in the process of completing an application form for such products and services.
Information about your sex life or sexual orientation.	Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.
Information about your racial or ethnic origin	Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.

We will only process the special category personal data listed above with your explicit consent. You may choose not to provide us with this consent. However, please note that if you do not provide us with your consent to collect and process the information listed in the table above:

we may not be able to advise you fully in respect of certain products and services which require this information (in particular those relating to health or life insurance).;
your application may be rejected by the providers of products and services which require this information; or
the quotes for such products and services may be higher than would be the case if this information were provided.

In some circumstances, we may receive information about you from third parties. In particular, we will receive information about you from Credit Reference Agencies and Fraud Prevention Agencies. This may include details of the products and services you have applied for, those lenders, finance and credit organisations with whom you have (and have had) an agreement with, the amounts advanced, the amount and frequency of repayments and whether you have made your repayments on time and in full. This will help us make the best possible assessment of your financial situation before we decide whether we can provide you with our services and/or recommend any specific products and services. It is in our legitimate interests to process your personal information for this purpose. We may also ask you to provide Letters of Authority to allow us to receive information about you from providers.

When we record communications

We may record and/or monitor communications (including telephone conversations and emails) between our staff and you. We only record communications between us in order to comply with our legal and regulatory requirements - as an authorised intermediary, the law requires us to record these communications.

Who might my personal information be shared with?

We may disclose your personal information to the following categories of recipients:

to providers of insurance - in order for us to submit applications on your behalf and to receive updates from such providers, and for us to provide our services to you throughout the lifetime of our relationship with you;
to our suppliers and partners - in order for them to help us provide our services to you, this includes:
- our IT systems providers to assist us with providing you with an efficient, modern and professional service;
- our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
- our accountants, solicitors, insurer(s) and insurance broker(s) and any other provider of professional services to us;
to other entities within the DJ Alexander Group - we will only pass your information internally if you request us to do so. You may, for example, wish to find out more about the following services we can provide:
- DJ Alexander Lettings - If you are a tenant or landlord and wish to find out more about renting or our property management service.
- DJ Alexander Sales - If you wish to buy or sell a property with us
- DJ Alexander Legal - We can provide a range of conveyancing and other legal services
to Credit Reference Agencies and Fraud Prevention Agencies to help us make the best possible assessment of your financial situation before we decide whether we can provide you with services. We are also required to provide information to such agencies so that they can update the information which they hold about you and which they may share with other organisations;

For further details about how Credit Reference Agencies use your personal data, see: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice
to other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary
1. as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC),
2. to exercise, establish or defend our legal rights, or
3. to protect your vital interests of those of any other person; and
to any other person with your consent to the disclosure or where we are permitted to do so by law.

Google Analytics

We use Google Analytics to provide us with information about how you use our websites. This data, along with the use of cookies, allows us to tailor our websites in a way which will provide you with a more user-friendly experience. We only use this data for statistical analysis and is deleted from our systems in line with our retention policy.

For more information on Google Analytics and the data which it collects, please visit:

https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

Our legal basis for processing personal information

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the 'What type of personal information will be processed and why?' section above.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" heading below.

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with our own standards, this Notice and applicable law. These ensures your data will only be shared once you have confirmed you are happy to proceed with the relevant mortgage, protection and/or insurance product.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "How to contact us" heading below;
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the details provided below.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the e-mails we send you.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent, please see the "Your consent to us processing your special category personal data" heading below.
You have the right to complain if you consider that we have processed your personal data in violation of applicable law. If after contacting us you feel that we have failed to remedy the violation, you may also lodge a complaint to the relevant supervisory authority (e.g. the Information Commissioner in the UK).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate need to do so, for example:

to provide you with a product or service you have requested us to provide,
to perform our contractual obligations to you;
to comply with applicable legal, tax or accounting requirements;
to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims. This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or ombudsman.

We will retain your personal information only for the period necessary to fulfil the purposes outlined in this Notice. After which your information will be deleted.

Updates to this Notice

We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. If we make any material changes to this Notice, we will notify you by sending an email to the email address you most recently provided us or by posting notice of the changes on this site.

How to contact us

If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please contact us directly at financialservices@djalexander.co.uk