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This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for financial planning services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information about connected individuals

We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

We have a contractual obligation

This is the primary legal basis that we intend to use for processing your data. The personal information that we collect about you is essential for us to be able to effectively carry out the services that we have agreed to deliver to you.

We have a legal obligation

Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For example, UK anti money laundering legislation may require us to collect personal information to verify your identity.

We will obtain your consent

Special category data, such as that relating to health matters, is often required to provide our services. When this is required, we will obtain your explicit consent to collect and process this information.

You may withdraw your consent at any time by notifying us at our main business address.

We have a legitimate interest

We rely on legitimate interest to retain relevant data for the purposes of assessing the appropriateness of our services, defending future complaints, and meeting our Professional Indemnity Insurer’s expectations.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may email you about other products or services that we think may be of interest to you. We won’t share your information for marketing purposes with other companies.

In order to deliver our services to you effectively we may send your details to 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.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. For example we may use password protection or encryption of data.

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.

We may share your information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who are stakeholders or investors in our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this notice.

How long do we keep hold of your information?

During the course of our relationship with you, we will retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

• Five years for investment business
• Indefinitely for pension transfers and opt-out business
• Three years for insurance 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's in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 7 years after our relationship with you has ended.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below. When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

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 contact us by email or post.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity.

For further information visit: www.allaboutcookies.org*

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.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Changes to our privacy policy

We keep our privacy policy under regular review, and we will place any updates on this web page (or inform you of any changes when they occur). This privacy policy was last updated on 02/12/2024.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

• By email at info@336fm.co.uk
• Or write to us at: 336 Financial Management, 21-23 Thistle St, Edinburgh, EH2 1DF

This Privacy & Cookies Policy (the “Policy”) has been prepared to meet the requirements of the UK’s Data Protection Act 1998 and The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011, (the “Acts”). It relates to the collection, protection, disclosure and use of personal data belonging to individuals who visit www.bloomsburywealth.co.uk (our “Site”) and also refers in detail to the “Cookies” we use, what they are and their purpose. By clicking the “Dismiss” button on the box that appears on the first page you enter on our Site, you signify your acceptance of our Cookies Policy. If you wish subsequently to decline your acceptance of them we set out in Clause 4 of the Policy how you may do so. Please note that the box relating to “Cookies” will only appear the first time you enter our Site.

Your privacy and security is important to us. This Policy sets out how we will treat any personal information we obtain from you and it is intended to help you understand how we deal with it and how you may remove it. By providing your personal information to us, you agree that we may collect and use the personal information you provide in the ways described in this Policy. If you do not agree with the terms of this Policy, please do not provide any personal details to us.

We will use your personal information only for the purposes set out below.

Please note that we may need to update this Policy from time to time to reflect changes in the law. We recommend that you check this page regularly to ensure that you have read the most recent version and that you are happy with any changes.

This Policy was last revised on: 10th March 2014.

1. Information we may collect from you

1.1 It is your choice to provide us with personal information. We may provide you with the option to select whether you would like to receive information from us or from trusted third parties by opting in or out of receiving promotional offers. In some circumstances, you will not have the option to opt out, for example, when we are administering a transaction requested by you, or if we are satisfying a legal requirement.

1.2 Ways in which you may be providing us with personal information include, for example,

1.2.1 contacting us with an enquiry;

1.2.2 completing a survey which contains your personal information;

1.2.3 submitting your CV and/or covering letter to us; and/ or

1.2.4 reporting a problem.

1.3 The information we will collect from you includes, but is not limited to data concerning traffic on our Site, location data, weblogs and other communication data, (whether this is required for our billing purposes or otherwise) and the resources that you access.

1.4 By providing any personal information to us, you fully understand and clearly consent to the transfer, collection and processing of such personal information. Such transfer, collection and processing will comply with the terms of this Policy.

2. IP addresses and cookies

2.1 Like many other websites, we use “cookies” to help us gather and store information about visitors to our Site.

2.2 We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our Site users’ browsing actions and patterns, and does not identify you as an individual.

2.3 A “cookie” is a small text file that is downloaded on to your computer’s hard disk when you access certain websites. Cookies allow the website to recognise your computer. A cookie can identify the pages that are being viewed and this can assist us to select the pages that the visitor sees.

2.4 “Session” cookies only exist whilst visitors are online on a particular occasion. These are temporary cookies that aid your journey around the site and remember the preferences you have selected during your “session”.

2.5 “Persistent” cookies, which are not session-based, remain on a visitor’s computer, so that you can be recognised as a previous visitor when you next visit our Site. This allows us to collect information about your browsing habits whilst on our site, and this can be useful in assisting us to monitor and improve our services.

2.6 We do not store sensitive information such as account numbers or passwords in “persistent” cookies, and cookies in themselves, do not contain enough information to identify you. You will only become personally identifiable in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined in Section 1.2 above.

2.7 In addition to using cookies, we might also use GIFs and other web tools, such as Google Analytics, to collect information about your browsing activities whilst on our site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.

2.8 Any information that we acquire about you using cookies, GIFs, or other web tools is subject to the same restrictions and conditions as any other information we collect about you, as outlined in this Policy.

2.9 Some of our advertisers may also use cookies, GIFs, or other web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements relate. We do not have access to any information that might be collected in this way, and, if you are concerned, you should contact the advertiser for more information.

3. How to disable/enable cookies

3.1 You have the ability to accept or decline cookies by modifying the settings in your browser or by not clicking the “dismiss” button on the box that appears on the first page you see on our Site. For example, in Internet Explorer, you can go to Tools and Internet Options, where there is the option to change your settings to disable cookies. However, you may not be able to use all the interactive features of our site if the cookies are disabled.

3.2 You also have the ability to delete cookies that have been installed in the cookie folder of your browser and should search for “cookies” in your “Help” function for information on where to find your cookie folder.

3.3 To delete only the cookies set by our Site in Internet Explorer, you must do the following:-

1. In Internet Explorer, click the Tools button, and then click Internet Options.

2. On the General tab, under Browsing history, click Settings.

3. Click the View files button.

4. Click the Name column heading to sort all the files alphabetically, and then scroll down until you see files that begin with the prefix Cookie:. All cookies will have that prefix, and they usually contain the name of the website that created the cookie.

5. Right-click the cookie you want to delete, click Delete, and then click Yes.

6. Close the window that contains the list of files, and then click OK twice to return to Internet Explorer.

You should note that some websites store your member name, password, or other information about you in a cookie. If you delete that cookie, you might need to re-enter your personal information again the next time you visit the Site.

3.4 To delete only the cookies set by our Site, for example in Firefox, you must do the following:-

1. At the top of the Firefox window, click on the Firefox button and then click Options

2. Select the Privacy panel.

3. Set Firefox to Use custom settings for history.

4. Click Show Cookies…. The Cookies window will appear.

5. In the Search field, type the name of the site whose cookies you want to remove. The cookies that match your search will be displayed.

6. Select the cookie(s) in the list to remove and click Remove Cookie

7. Select the first cookie and press Shift + End to select all the cookies in the list.

8. Click Close to close the Cookies window.

3.5 Unless you have adjusted your browser settings so that it will refuse cookies, our Site will issue cookies when you log on to our Site.

3.6 To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On by clicking on this link – tools.google.com/dlpage/gaoptout* and following the instructions.

4. Where we store your personal data

4.1 All information you provide to us is stored on our secure servers.

4.2 The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

4.3 Unfortunately, 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 our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

5. Uses made of the information by us

5.1 We may use personal information collected from you to provide specific services that you request and to provide additional services that may be of interest. We may use your personal information in the following ways:

5.1.1 Ease of Use – To ensure that content from our site is presented in the most effective manner for you and for your computer.

5.1.2 Transactional Purposes – To carry out our obligations arising from any contracts entered into between you and us and to respond to your queries and requests.

5.1.3 Communication – To notify you about changes to our service.

5.1.4 Provision of Information – To assess your eligibility, and if eligible, provide you with information.

5.1.5 Marketing Communications and Analysis – To communicate with you about our products and services and for our own internal marketing analysis, for example, to measure the amount of traffic to our Site.

6. Uses made of the information by third parties

6.1 We may also use your data, or permit selected third parties to use your data, to provide you with data about goods and services which may be of interest to you, and we or they may contact you about these by post or e-mail.

6.2 If you are an existing customer, we will only contact you by email with information about goods and services similar to those, which were the subject of a previous sale to you.

6.3 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you be electronic means only if you have consented to this.

6.4 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please email us at enquiries@336fm.co.uk or write to us at 336 Financial Management, 1 St Colmes Street, Edinburgh EH3 6AA, Scotland.

6.5 Please note that we will not, under any circumstances, sell your personal information to anyone else.

6.6 Any information or statistics relating to our business that we disclose to others will not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our Site in order to measure interest in the various areas of our site and to inform advertisers as to how many consumers have “clicked” on their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not contain personal information about you.

7. Links to other websites

This Policy only covers this Site. If you follow a link from this Site to another website, you must refer to and read the privacy statement on that other website which you visit. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. Disclosure of your information

8.1 We may disclose your personal information:

8.1.1 To third parties to whom you have provided your consent in order that they will be able to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions or in the provision of any of our services to you.

8.1.2 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.

8.1.3 If 336 Financial Management, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

8.1.4 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of Bloomsbury, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

9. Interactive areas of our site/blogs

9.1 Information that you post via social networking (including but not limited to Facebook and Twitter) is generally accessible to, and may be collected by, others and may result in unwelcome communications. For your own safety and security you should not provide information about yourself on the aforementioned areas of our Site or via social networking.

9.2 If you disclose any information via social networking, we do not accept any responsibility or liability for any breach of privacy, loss, damage, effect on your reputation or otherwise whatsoever.

10. Your rights

10.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you, before collecting your data, if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right at any time to prevent such processing by emailing us at enquiries@336fm.co.uk or write to us at 336 Financial Management, 1 St Colmes Street, Edinburgh EH3 6AA, Scotland.

11. Access to information

The Acts give you the right to access information we hold about you. Any access request will be subject to a fee of £10 to meet our costs in providing you with such information. If you would like a copy of this information, please write to us at the address below.

12. Contact

12.1 Questions, comments and requests regarding this Policy are welcomed and should be addressed to enquiries@336fm.co.uk or write to us at 336 Financial Management, 21-23 Thistle Street, Edinburgh, EH2 1DF