Your privacy is important to us. It is our interest to respect
your privacy and your right to deal with the information about you.
This Privacy Policy helps you to understand how we use your personal information, who we share it with
and the rights that you have.
We change the terms of this Privacy Policy from time to time and you should check it regularly. The last
updated date is shown at the end of this document. If we make any material changes, we will take steps
to bring it to your attention.
The legal rules about dealing with personal data are strictly followed by us.
WHO WE ARE
- We are Supreme Financial Solutions Ltd is an appointed representative of The Openwork Partnership, a
trading style of Openwork Limited which is authorised and regulated by the Financial Conduct
Authority.
- Supreme Financial Solutions Ltd provide financial planning solutions and advice through experienced
and qualified advisers based in the UK.
- Currently Supreme Financial Solutions Ltd and Openwork Partnership jointly determine the purposes
and means of processing personal client data relating to giving advice. This means we are joint data
controllers for this core advice giving activities and therefore responsible for managing this client
data and ensuring compliance.
- When we use information about you, we take all reasonable efforts to do so fairly and lawfully. We
will use it with care, and it will only be shared in the ways explained here, or if we are required to
by Law or the Financial Conduct Authority (FCA). We never use information about you unless it is
lawful for us to do so and we have a clearly defined need or purpose.
- We try not to keep your information for longer than we need it and we ensure that the records we
have about you are managed properly and deleted promptly and securely when we no longer need them.
THE LAWFUL BASES WE USE TO PROCESS DATA
- We will only ever process your data if we have a lawful basis to do so. The lawful bases we rely on
are:
- Contract – This is where we process your data to fulfil a contractual arrangement, we have made
with you or because you have asked us to carry out a service before entering into a contract.
- Consent – This is where we have asked you to provide permission to process your data for a
particular purpose.
- Legitimate Interests – This is where we rely on our interests as a basis for processing.
- Legal Obligation –This is where we have a statutory or other legal obligation to process the data,
such as to comply with regulatory requirements and/or requests.
- Vital interests –This is where the processing of personal data is necessary to protect someone’s
life.
⦁ YOUR RIGHTS
- ⦁ You have a number of “Data Subject Rights”, we have explained below what they are and how you can
exercise them. You can read more about these rights on the UK Information Commissioner's Office
website athttps://ico.org.uk/for-the-public/.
- Right of access –You have the right to request a copy of the personal data that we hold about you.
- Right to rectification –If you think any of your personal data that we hold is inaccurate, you
have the right to request it is updated. We may ask you for evidence to show it is inaccurate.
- Right to erasure– (also known as the right to be forgotten) – You have the right to request that
we delete your personal data that we hold.
-
Right to restriction of processing –You have the right to request we restrict or suppress the
personal data we hold about you.
- Right to data portability –You have the right to ask us to electronically transfer your personal
data to another organisation in certain circumstances.
- Rights with regards to automated decision making, including profiling – You have the right not to
be subject to a decision that is based solely on automated processing if the decision affects your
legal rights or other equally important matters and to object to profiling in certain situations,
including for direct marketing.
- Right to withdraw Consent – Where we are relying on your consent for processing you can withdraw
or change your consent at any time.
- The above rights may be limited in some circumstances, for example, if fulfilling your request would
reveal personal data about another person, if you ask us to delete data which we are required to have
by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the
case and will then only use your data for these purposes. You may also be unable to continue using our
services if you want us to stop processing your personal data
- We encourage you to get in touch if you have any concerns with how we collect or use your personal
data. You have the right to lodge a complaint directly with a Data Protection Authority. The Data
Protection Authority in the UK, where we are based, is the Information Commissioner's Office (ICO),
you can contact the ICO here: ico.org.uk/make-a-complaint.
WHAT INFORMATIONDO WE COLLECT ABOUT YOU
- The information we collect about you may vary based on what service we provide to you. Typically, we
need details like:
- Your name and address so we know who you are and what services you need from us.
- Your contact details like phone number or email so that we can keep in touch with you about our
services.
- Your bank account or other financial details so we can manage your payment for our services.
-
Your employment information.
- Your assets and liabilities.
- Some financial services products may require us to collect information about your health. This is
regarded as sensitive personal data. Your adviser will have access to your medical details unless you
prefer to complete a medical statement of health in private. We do need your explicit consent to
collect and process your health details, which of course you may withdraw at any time.
- If you apply for a mortgage your information will be passed to the lender, who will carry out a
credit check. You will also have to provide details of any criminal convictions you may have had.
These details will be passed to the lender to carry out any necessary checks.
⦁ WHAT DO WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU
- We use your information in various ways, such as to:
-
To confirm your identity.
- Provide you with the services you want.
- Meet the purposes that you provided your information for.
- Prevent fraud, money laundering and financial crime.
- Credit scoring and assessment, and credit management (where applicable).
- Comply with any legal or regulatory obligations we may have.
WHO DO WE SHARE YOUR INFORMATION WITH?
- We only share your information where we are permitted or required to by law, or where you have
requested us to do so. We may share your information with, for example:
-
Any of your family, associates, or someone who represents you, where you have asked us to do so.
- Our employees who provide you with our services.
- Carefully selected organisations and specialists to help us provide you with our services.
-
Credit reference and fraud prevention agencies in order to help prevent and detect fraud as part of
our due diligence process.
- Any person, organisation, or regulator where we are required to because of a court order,
regulatory responsibility, legal duty or statutory obligation.
COOKIES
- We use cookies on our website.
- When viewing the Online Service websites “cookie” files are used, which are small text files
recorded in the Customer’s target device in connection with using the Online Service. They are used to
improve the experience with the Online Service websites.
- The “cookie” files used by the Controller are safe for the Customer’s devices. In particular, it is
not possible for viruses or other unwanted or malicious software to enter the Customer’s devices in
that way. Those files allow to identify the software used by the Customer and to adjust the Online
Service to each Customer individually. “Cookie” files sometimes contain information about the domain
name of their origin, how long they are kept in the device and the ascribed value.
- Due to the purpose of collecting cookies, we distinguish the following Cookies:
-
necessary Cookies: necessary for the proper functioning of the service - files processed on the
basis of the legitimate interest of the controller.
- statistics Cookies: they allow us to study website traffic, learn about our users' preferences,
analyse their behaviour on the site and enable interactions with external networks and platforms -
files processed based on the user's voluntary consent.
-
marketing Cookies: they allow us to tailor the advertising and content displayed to our users'
preferences and to conduct personalized marketing campaigns - files processed based on the user's
voluntary consent.
- “Cookie” files may be used by advertisement networks, in particular by the Google network, in order
to display advertisements adjusted to the way the Customer uses the Online Service. To that end, the
information may be retained about the Customer’s navigation path, or the time spent on the given
website.
- As regards the information about the Customer’s preferences collected by the advertising network
Google, the Customer may view and edit the information related to cookie files by means of the
following tool: https://www.google.com/ads/preferences/.
- The Customer may, by himself and at any time, change the “cookie” files settings, specifying the
conditions of their storing and of their access to the Customer’s device. The settings referred to in
the previous sentence may be changed by the Customer through the web browser settings or through
configuration of the service. Those settings may be changed in particular so as to block automatic
support for “cookie” files in the web browser settings or to inform each time they are introduced to
the Customer’s device. Detailed information about the possibilities and ways of supporting cookie
files is available in the software (web browser) settings.
- To learn how to manage cookies, including how to disable them in your browser, you can use the help
section of your browser. You can learn more about this by pressing the F1 key while in your browser.
In addition, you will find appropriate tips on the following pages, depending on the browser you are
using: br
Firefox
Chrome
Safari
Internet Explorer / Microsoft Edge
- The Customer may remove “cookie” files at any time, using the functions available in the web browser
he uses.
- Limitation of the “cookie” files application may affect some functionalities available on the Online
Service website.
- We use the services of: Google Analytics 4, Google ADS,
Last updated date: 29.04.2024