Octagon Consultancy Ltd
PRIVACY AND COOKIES POLICY
Your rights, your information and how we use it
Octagon Consultancy Ltd is committed to protecting and respecting your privacy.
We process data in line with the General Data Protection Regulation (GDPR) applicable in the UK (the Data Protection Laws).
Please read the following carefully to understand our views and practices regarding the use of your personal data and how we use it.
Who we are
Octagon Consultancy Ltd is a Chartered Financial Planning Firm and, as such, is the data controller.
If you have any queries regarding this policy, please:
write to: Octagon Consultancy Ltd, 2 Hurle Road, Clifton, Bristol BS8 2SY, or
What information do we collect from you?
Octagon Consultancy Ltd will collect information about you when you engage us for financial planning and advice.
The information we collect may include:
your name, company information and your primary role or title,
your date of birth,
your address and contact details,
account information relating to products, services or banking,
data in relation to your financial circumstances,
personal data about your health, if this is necessary for the provision of our services,
details of meetings, phone calls, emails and letters,
documentation verifying your address and name,
feedback or client surveys you have voluntarily provided,
data collated via cookies when you visit our website,
details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access,
we may also collect data from professional introducers, such as solicitors and accountants or
from your employer, where they contract our services.
Information about connected individuals
How will we use the information we collect about you?
We use personal and other data we may collect from you to provide the services for which you have engaged Octagon Consultancy Ltd. Without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations.
In addition to the above, we may use your information to notify you about goods or services which may be of interest to you. Where we do this, we will contact you only if you have consented to such communication. If you do not want us to use your data in this way, please contact 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 efficiently and effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations.
Who might we share this information with?
We will keep your personal information confidential, but we may share it with:
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.
The representatives of a potential buyer, transferee, merger partner or seller if we wish to buy, sell, transfer or merge part or all our business or assets.
Your advisers or anyone you have confirmed has your permission to deal with your accounts.
Owners of other linked accounts.
Law enforcement agencies and other authorities to comply with legal obligations.
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.
How we protect your information
We take appropriate measures to ensure that any personal data are kept securely, including measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We restrict access to your personal data to those who have a genuine business need to know. Staff processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach, where we are legally required to do so.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to help prevent unauthorised access.
How long we keep your personal data
We will hold personal data (eg name, address, date of birth and contact details) as set out by our regulator, in order to meet our legal obligations. This is currently a minimum of 5 years for investment business and indefinitely for occupational pension transfer or opt-out business.
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 is in our legitimate interest to do so.
Where we store your personal data
The majority of your information is processed in the UK and European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with outside of the EEA, such as the United States.
Where your information is being processed outside of the EEA, we take steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws.
Under the General Data Protection Regulation you have a number of important rights, which are free of charge. In summary, these include rights to:
Access your personal data and to certain other supplementary information that this Policy is already designed to address.
Request we correct any mistakes in your information which we hold.
Request the erasure of personal data concerning you in certain situations.
Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit thisto a third party in certain situations.
Object at any time to processing of personal data concerning you for direct marketing.
Object in certain other situations to our continued processing of your personal data.
Otherwise restrict our processing of your personal data in certain circumstances.
Claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the
If you would like to exercise any of those rights, please contact us.
How to make a complaint
If you are still unhappy, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at:
Information Commissioner's Office
Tel: 0303 123 1113
You can obtain more information about the ICO via their website: https://ico.org.uk/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
We may collect information about your mobile phone, computer or other device from which you access the website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties’ affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you to track your usage of our services.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies we use include:
“Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
“Strictly necessary” cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
“Functionality” cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
“Targeting” cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.