Customer Privacy Notice
This is the customer privacy notice for WillU Invest Limited, WillU Life Ltd, WillU Insure Limited (‘WillU’ and ‘our Firm’), which are Companies Registered in England and Wales whose Company Registration Number are:
- WillU Invest Limited – 09910112
- WillU Life Limited – 11758858
- WillU FX Limited – 10855534
- WillU Insure Limited – 13166888
Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your investments, finance or insurance requirements Your Personal Data may include:
- Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing investment, finance or insurance products and the terms and conditions relating to these
The basis upon which our firm will deal with Your Personal Data
When we speak with you about your investment, finance and insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance / investments (including ethical investments), in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance and investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment, finance and insurance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do so if we have consent from you, for us, or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to Product Providers and Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investments, finance products or insurance policies you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment providers Finance and Insurance providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, (in each case where we believe this to be required due to your particular circumstances).
- Within the WillU group, when you agree or ask for further information on other services that WillU can provide for you, such as FX services, insurance or investments.
In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investment finance and insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages, it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document or wish to make contact in order to exercise any of your rights set out within it please contact:
Craig Copeland, WillU Invest Limited – email@example.com
If we feel we have a legal right not to deal with your request, or to action it in a different way than how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you become aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
As a valued customer of WillU, we would like to provide you with reassurance that we take your right to privacy in an electronic context seriously.
During the course of providing you with our services, WillU may contact with you through a variety of electronic means, including potentially by telephone, email, SMS and instant messaging services (such as WhatsApp). These means are referred to in this document as E-Marketing.
We would like to take particular care to ensure that any marketing or promotional information that we may send to you, is done so with your prior, express permission. We would like to keep you informed about products or services that we may have access to that may be of interest or suitable for to you within the WillU Group.
In this document, we explain how we would do this, and ask for your consent to receiving such information from us in the future.
How this E-Marketing Consent relates to our Customer Privacy Notice
During the course of dealing with us we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data).
During the course of our initial discussions with you, you will have been provided with a copy of, or been provided with access to, our Customer Privacy Notice. We encourage you to read this document, as it sets out in detail the basis upon which this Firm will process and share Your Personal Data.
Our Customer Privacy Notice does not extend to explaining how we would like to use Your Personal Data for marketing purposes, including to E-Market to you. We are of the view that this is better set out separately, to enable you to be clear and make informed decisions in relation to your right to privacy.
How we will use Your Personal Data in the future
There are a range of reasons why we need to retain Your Personal Data and, when necessary, use it to make contact with you. These include:
- asking your views on the quality of the service we have provided
- responding to your own questions on the product you have taken out
- informing you with regard to any changes to the terms and conditions of your products proposed or made by finance, insurance or investment providers.
Specifically, we would also like to make you aware of products or services that are made available to our firm from time to time that we think may be of interest to you in the future. We propose to do this by any of the E-Marketing means, using the contact information you have provided to us.
Your right to Opt-Out
You have the right to ask us not to contact you for marketing purposes at any time – to Opt-Out – we have included details of how to Opt-Out at the end of this document so that you know what to do.
Opting Out means that we will either remove Your Personal Data from our marketing database or limit our contact with you to the means you specify (for example, by email only), but we reserve the right to retain it for any other purpose explained in this document or as set out separately in our Customer Privacy Notice.