WLS Financial Services is committed to protecting the individual privacy rights and choices of all our clients, and the personal information you share with us.
Who we are
We are WLS Financial Services Limited, a company registered in England & Wales. Company No: 11231054. Registered office: 219-221 Worcester Road, Malvern, Worcestershire WR14 1SU
How to contact us
The Data Protection Officer
WLS Financial Services Limited
219-221 Worcester Road,
Collecting and using your information
Types of information we collect and use
Depending on how you choose to interact with us, the information about you that we collect and use includes:
Information about who you are e.g. your name, date of birth and contact details
Information connected to your product or service with us e.g. your bank account and financial details
Information about your contact with us e.g. meetings, phone calls, emails / letters
Information that is automatically collected e.g. via cookies when you visit one of our websites (please see our section on cookies)
Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the products or services you have requested or to comply with our legal obligations
Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
Demographic information such as postcode, preferences and interests
Other information relevant to customer surveys/and or offers
Where we collect your information
We may collect your personal information directly from you, or from a variety of sources, including:
an application form for a product or service
phone conversations with us
emails or letters you send to us
registering for one of our events e.g. retirement events or webinars
participating in research surveys to help us understand you better and improve our products and services
our online services such as websites, newsletters, social media and mobile device applications (‘Apps’)
If you have a financial adviser, the information we collect and use will most likely have been provided by them on your behalf.
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information that is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
you have given us your permission [consent] to send you information about products and services offered by other parts of The WLS Group and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you, or;
it’s necessary to provide the products or services you have requested e.g. if you wish to take out any of the pensions, investments, mortgages, loans or insurances available through us. Typically to facilitate this we will require personal information including your name, address, date of birth, and bank account details, or;
it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Review Letters or Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud, or;
it’s in the legitimate interests of WLS Financial Services e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you, or;
it’s in the legitimate interests of a third party e.g. sharing information with the providers of products or services you have chosen through us
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party or direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by Contacting us.
Who we may share your information with
We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’
These third parties include:
Companies within The WLS Group
Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you
Our Regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
Law enforcement, credit and identity check agencies for the prevention and detection of crime
HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Processing, protecting and storing your information
Where your information is processed
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, including countries such as the United States, Australia and India.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
Your individual rights
You have several rights in relation to how WLS Financial Services uses your information. They are:
The right to be informed
The right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
The right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
The right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for WLS Financial Services to continue to have it.
The right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
The right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.
The right to object
You can object to WLS Financial Services processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
Rights related to automatic decision making including profiling
You have the right to ask WLS Financial Services to:
give you information about its processing of your personal information
request human intervention or challenge a decision where processing is done solely by automated processes
carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
How to make a complaint
If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are: https://ico.org.uk/