Privacy Policy
Who we are
Indaba Wealth Management Limited (“Indaba”, “we”, “us” or “our”) is the data controller of the personal information collected through this website and in the course of providing our services. This policy explains how we collect, use and protect your personal information, and the rights you have in relation to it, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Registered office: Unit 6 Cherry Hall Road, North Kettering Business Park, NN14 1UE
Registered in England and Wales, Company Registration No. 13587663
Authorised and regulated by the Financial Conduct Authority, Firm Reference No. 1032413
Correspondence address: Goodwood House, Hackamore Way, Oakham LE15 7FS
Information Commissioner’s Office (ICO) registration number: ZB830753
This policy applies to visitors to our website and to clients and prospective clients of our financial advice services.
Information we collect when you visit our website
When you use our website, we may collect:
- information you provide to us through our contact or enquiry forms, such as your name, email address, telephone number and the content of your message; and
- technical information collected automatically, such as your IP address, browser type and version, device type and information about how you use our website, collected through cookies and similar technologies (see “Cookies” below).
We use this information to respond to your enquiries, to operate, secure and improve our website and, where you have agreed, to send you information about our services. The legal bases we rely on for this are our legitimate interests in running and promoting our business and responding to enquiries, and your consent in respect of non-essential cookies and marketing communications. You may withdraw your consent at any time.
What information do we collect about you?
We collect information about you when you engage us for financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services. We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required, we will obtain your explicit consent to collect and process this information.
In addition to the performance of our contract – which includes taking steps at your request before you enter into a contract with us, such as gathering information during an initial consultation so that we can advise you – we also process personal data where it is necessary:
- to comply with our legal and regulatory obligations, including those imposed by the Financial Conduct Authority and under anti-money laundering legislation;
- for our legitimate interests, such as administering our business, keeping our records accurate and up to date, and establishing, exercising or defending legal claims; and
- with your consent, which we rely on for the processing of special category data and for direct marketing.
Where we rely on your consent, you may withdraw it at any time by contacting us using the details at the end of this document. Withdrawing consent will not affect the lawfulness of any processing carried out before you withdrew it.
Cookies
Cookies are small text files placed on your device when you visit a website. Our website uses:
- essential cookies, which are necessary for the website to function properly and cannot be switched off; and
- analytics cookies, which help us understand how visitors use our website (for example, which pages are visited most often) so that we can improve it. Analytics information is aggregated and does not directly identify you.
When you first visit our website you will be asked to accept or decline non-essential cookies. You can change your preferences at any time, and most browsers also allow you to block or delete cookies through their settings. Blocking essential cookies may affect how the website functions.
Who might we share your information with?
As part of our commitment to your financial wellbeing, we may email you about using your relevant tax allowances or changes to financial products which we think would be beneficial to you.
We will not share your information for marketing purposes with other companies.
To deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money laundering and other financial crime we may send your details to third party agencies for identity verification purposes. This may leave a soft footprint on your credit file, but will not affect your credit rating.
We may also share information with providers of services that support the operation of our website, such as our website hosting and analytics providers, and with regulators, law enforcement agencies or other authorities where we are required to do so by law.
Do we transfer your information outside the UK?
Your personal data is stored and processed in the United Kingdom wherever possible. If any of the third parties or service providers we use process personal data outside the UK, we will ensure that appropriate safeguards are in place – such as a UK adequacy decision or approved standard contractual clauses – so that your data receives an equivalent level of protection to that which applies in the UK.
How do we protect your information?
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, alteration or disclosure. Access to your information is restricted to those who need it in order to carry out their role, and we require the third parties who process data on our behalf to apply equivalent protections.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than 5 years past the time of your death.
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.
Information submitted through our website contact forms is kept for as long as necessary to deal with your enquiry and for a reasonable period afterwards. Analytics data is retained in accordance with the retention settings of our analytics provider.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
In addition to the rights described above, you also have the right to:
- object to processing carried out on the basis of our legitimate interests, and to object at any time to the use of your personal data for direct marketing;
- restrict the processing of your personal data in certain circumstances, for example while a query about its accuracy is being resolved;
- withdraw any consent you have given, at any time; and
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We do not make decisions of this kind.
There is normally no charge for exercising any of your rights, and we will respond to your request within one month of receiving it. We may need to verify your identity before we are able to deal with your request.
Links to other websites
Our website may contain links to other websites. This policy applies only to our website, and we are not responsible for the privacy practices of other sites. Please check the privacy policy of any other website you visit.
Changes to this policy
We keep this policy under review and may update it from time to time. Any changes will be posted on this page with an updated revision date.
What can you do if you are unhappy with how your personal data is processed?
If you have any concerns about how we use your personal data, please contact us first so that we can try to resolve them.
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113 (local rate)
If you want to contact us to discuss how we hold your information, please contact us by email at:
or write to us at:
Indaba Wealth Management,
Goodwood House
Hackamore Way
Oakham LE15 7FS