This privacy notice explains how Godiva Wealth Management Ltd (‘we’) uses any personal information we collect about you.
What information do we collect about you and why?
Godiva Wealth Management collects and uses personal data on the basis that it is in its legitimate interests to do so, for example, to keep records of transactions and to provide a service to its customers.
From our website: We collect information you provide by filling in one of our online enquiry forms, and we will use this to keep you updated about Godiva Wealth Management’s activities and services. You may withdraw this consent at any time by emailing us at firstname.lastname@example.org or writing to us using the information at the end of this notice
From our clients: We collect information via our account application process and throughout our relationship with you in order to comply with regulation and for the purpose of performing our contract with you. The provision of your personal data is required in order to enter into a contract with us, however the provision of information for marketing purposes is voluntary. We may record and monitor phone calls made to or by us in order to comply with regulatory obligations. Automated decision making may be used in order to comply with our KYC/AML checks or to evidence that Godiva Wealth Management is providing a suitable and appropriate service to its clients.
How long do we keep this information?
If you are not a client of ours, we will keep your information for a year after we last heard from you. If you ask us to remove you from our marketing list, we may keep your personal details on an “opted-out” list in order to ensure that we do not market to you again.
If you are or were a Godiva Wealth Management client, we keep most of your information for 15 years after the closure of your account. Where required by law or regulation, we keep documents relating to pension transfers indefinitely and recordings of telephone conversations with you for 5 years after they took place.
Who do we share your information with?
• Our IT providers and services providers in order to provide and maintain the provision of our services;
• Our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to provide advice;
• Fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
• Providers of investments or services we recommend, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, custodians, insurance products or other such products or services. We may also be required to share information with the auditors appointed by the providers of such products or services;
• The Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure; if required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
• Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
• If tax regulations require us to collect information about tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions;
• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets; or
• If Godiva Wealth Management’s assets are acquired by a third party, in which case personal information held by it about its clients may be one of the transferred assets.
We will not lend or sell your information to third parties.
Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA). Where we do so, we will ensure that we do this in accordance with current data protection legislation by only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
If you agree, we may send you information about our products and services by email and those of other companies in our group which may be of interest to you. Where it is in our legitimate interests, we may send you information about our products and services by post. If you have consented to receive marketing, you may still opt-out at a later date. We may also use your name and address to post to you invitations to events or to introduce you to other Godiva Wealth Management products or services which may reasonably be considered to be of interest to you.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email us at email@example.com or write to us using the information at the end of this notice.
You have certain rights in respect of the data we hold relating to you. Details of these rights can also be found on the Information Commissioner's website. You are entitled to a copy of the information we hold about you in a portable format or otherwise, to request rectification, erasure, or restriction of processing of the information we hold about you, and to object to processing or to automated decision making. Please note that the application of these rights vary according to the legal basis used to process your data. In certain circumstances, we are required to retain copies of the information we hold about you by other regulations. In this instance, we will not be able to erase or modify the data.
In order to exercise these rights or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. You can also contact the ICO in its capacity as Godiva Wealth Management’s supervisory body.
We will endeavour to keep your information accurate however if at any time after giving us this information it becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.
Internet communication, which includes email, is not secure. The protection of data by encryption is possible provided that the encryption method (protocol) used is current and the correct procedure for encryption and decryption is followed at all times. We cannot accept any responsibility for unauthorised access by a third party or for the loss, theft or modification of data while it is being sent to us by email. For security purposes we may monitor emails received or issued by us.
Changes to our Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated in July 2019. We reserve the right to update this privacy notice at any time and we will advise you when we make any substantial update to it.
How to contact us
If you have any questions about our privacy notice or the information we hold about you, please contact us at firstname.lastname@example.org or by post at the address below:
Data Protection Officer
Godiva Wealth Management Ltd
7 Clarendon Place, Royal Leamington Spa, Warwickshire, CV32 5QL