How Lighthouse Group companies use your personal information
Your information will be held by Lighthouse Epsom and Lighthouse Advisory Services Limited, which are part of Lighthouse Group Plc.
How we use your personal information
This privacy notice is to let you know how companies within the Group promise 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 explains how we do this and tells you about your privacy rights and how the law protects you.
How the law protects you;
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 Lighthouse Group Plc. 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.
A legitimate interest is when we have a business or commercial reason to use your information. Even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
|What we use your personal information for:||Our reasons||Our legitimate interests|
|Primarily, we use your data and data about you and your family to provide financial advice to you and complete transactions on your behalf.|
We analyse and assess your data to maintain and develop our relationship with you.
We may use your data to make checks with credit rating agencies to authenticate and verify your identity and credit status
To detect, investigate, report, and seek to prevent financial crime.
To manage risk for us and our customers.
Our legitimate interests.
Our legal duty
|Providing you with financial advice.
Keeping our records up to date, working out which of our products and services may interest you and telling you about them. |
Defining types of customers for new products or services.
Seeking your consent when we need it to contact you.
Being efficient about how we fulfil our legal duties.
Complying with regulations that apply to us.
Sensitive (Special types) Data;
there are additional provisions relating to the processing of ‘sensitive personal data’. Sensitive personal data will not be disclosed to a third party without your explicit consent.
We will only collect and use these types of data if the law allows us to do so:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Trade union membership
- Genetic and bio-metric data
- Health data including gender
- Criminal convictions and offences
to help provide financial advice it is necessary to ask about your health. We appreciate that this is sensitive information however, it may be necessary that we share this with third parties such as product providers. For example, if you require life assurance, the provider will need the information to provide an indication of costs and at retirement, health information may improve annuity rates
Whom we share your personal information with;
some services are provided to our firm by third parties such as processing business or obtaining compliance or regulatory advice, which warrant the disclosure of more than just your basic contact details. Personal information held by ourselves may be disclosed on a confidential basis, and in accordance with relevant data protection law.
Depending on the instructions we receive from you, we may pass your data to other professional advisers to enable us to provide advice most suited to your circumstances. Usually, this would be referrals to accountants, solicitors, tax advisers and sometimes to specialist advisers in the financial and insurance industry where you may benefit from the expertise of such third parties. We, and any third-party specialist advisers to whom we introduce to you, will pass your data to product providers, lenders and investment managers when you agree to make an investment, purchase or amend policies, or mortgages.
We may also share your personal information if the make-up of Lighthouse Group Plc changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private.
- If a change to our Group happens, then other parties may use your data in the same way as set out in this notice.
Product providers, lenders and investment managers may administer your policies, including any existing policies you may have with them, and provide other services from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of Data Protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the relevant Data Protection law even when your personal information is processed outside Europe
If we do transfer information to investment or insurance companies outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We will use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
- For data sent to the USA, transfer it only to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU. It makes sure those standards are similar to what is used within the EEA.
If you choose not to give personal information;
we may need to collect personal information by law, or under the terms of a contract, we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a service you have with us.
Any data collection that is optional would be made clear at the point of collection.
Third Party information;
where you provide any information about a third party such as spouse or dependants who are not party to this agreement, then we will probably have to issue them with a privacy notice to ensure they are aware of their rights because we are holding personal information about them, even if only their name.
we keep records of all your transactions. You, or your appointed agent, have the right to inspect the records at a mutually convenient time. As we treat all our client records as confidential, we reserve the right to give you copies of your records where in certain circumstances releasing the original would compromise other clients’ confidentiality. Unless you tell us otherwise, where we arrange products for couples or joint parties we will assume that information can be passed freely between us and those parties involved with the contract.
How long will you keep my data?
We will keep your data for as long as necessary, normally this is until you die. Data is required to allow us, where agreed, to provide an on-going service and to allow us, if required, to undertake future reviews and fulfil our obligations to regulators.
Your right to a copy of your personal information;
under current data protection law you have a right to get a copy of the personal information that we hold about you.
If you believe that any information we hold is incorrect or incomplete, we will promptly amend any information that is incorrect or incomplete. There is no fee.
If you want copies of your records or us to amend information, you should contact the Client Liaison Team at Lighthouse Advisory Services on 0800 0858593 or in writing to Client Liaison Team, Lighthouse Advisory Services Limited at Highbank House, Exchange Street, Stockport, SK3 0ET.
Letting us know if your personal information is incorrect;
you have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to 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 object’ and ‘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. However, 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. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
It is not accurate.
It has been used unlawfully but you do not 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 continue using it.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us.
How to withdraw your consent;
you have the right at any time to contact us at the address shown above to withdraw your consent to collecting future personal data or us holding existing data. Please be aware that, because of FCA requirements, we are required to hold records in respect of advice and guidance for a statutory period.
How to complain?
Please let us know if you are unhappy with how we have used your personal information. Please refer to the contact details for our Customer Liaison Team shown above.
You also have the right to complain to the Information Commissioner’s Office. Find out how on their website https://ico.org.uk/concerns/ or call their helpline on 0303 123 1113.
we may use your personal information to tell you about relevant products and offers. 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 unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
Whatever you choose, you will still receive statements, and other important information such as changes to your existing products and services.
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 update your choices at any time by contacting us.