We are committed to protecting and respecting your privacy.
This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting the website you are accepting and consenting to the practices described in this policy.
For the purpose of the General Data Protection Regulation (EU) 2016/679 (the Act), we are what is known as the 'controller' of personal data we gather and use. When we say 'we' or 'us' in this notice, we mean EBS Pensions Limited and Liberty Trustees Limited of The Exchange, Bank Street, Bury, BL9 0DN
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 and we will only use your personal data where there is a legal obligation and where it is permitted by the laws that protect your privacy rights.
The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we'd also be unable to fulfil our legal and regulatory obligations.
We do not need your consent to use your personal data where the law otherwise allows us to use it but in limited circumstances, we may approach you for your consent to allow us to process particularly sensitive personal data. In the context of the administration of your SIPP this will primarily be information about your health status.
If we request this information, we will provide you with full details of the information that we would like and the reason we need it, so that you can consider whether you with to consent. You have no obligation to give consent if you are asked for it, and if you do give consent you may withdraw it at any time.
In some cases, if you fail to provide information when requested, we may not be able to perform the contract we have entered into with you fully (such as providing benefits), or we may be prevented from complying with our legal obligations (such as to comply with our regulatory requirements).
How do we collect information about you?
We will obtain your data in different ways;
directly from you, for example when you fill out an application or input information into our website, contact us by email or telephone;
during the application process for one of our products (including the online identification and money laundering checks);
with your consent, i.e. from a provider of occupational health services;
Information collected on an aggregate basis using 'Cookies' as you and others browse our website.
What are Cookies?
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that website's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
You also have choices with respect to cookies. By modifying your browser preferences, you also have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. However, please note that if you reject some or all cookies, your experience at this and on other sites throughout the Internet may not be complete or may not benefit from some of the time-saving or customisable features.
For further information visit http://www.allaboutcookies.org/ . This website will give you detailed step-by-step guidance on how to control and delete cookies depending on your browser type. You can adjust your browser settings to your preferred level of protection.
Google analytics & re-marketing
Our websites use Google analytics and Google's re-marketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on Google partner network websites. Likewise, users that are similar to the visitors of our websites can be addressed. The advertising will be displayed through the use of web cookies. Using cookies, the user behaviour on a website can be analysed and subsequently utilised to provide targeted product recommendations and advertising based on the user's interests.
What information do we collect about you?
In the course of our relationship with you, we will collect, store, and use the following categories of personal data about you:
Information you give us
Personal information, not limited to your name, contact details, financial information and other information collected when you apply for one of our products ("Information"). 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.
On each of your visits to the website we may automatically collect the following information using cookies:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Information we receive from other sources
You may have authorised a third party to contact us on your behalf and entitled them to provide us with information about you or the services you have with them. If this is the case, we will always undertake a security clearance before any information about your account with Liberty SIPP is divulged by us.
How do we use information about you?
We use information held about you in the following ways:
Information you give us
We will use this information:
to process your SIPP application;
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to comply with our legal and regulatory obligations;
to notify you about changes to our products or services;
to ensure that content from the website is presented in the most effective manner for you and for your computer.
Information we collect via cookies
We will use this information:
to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the website to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep the website safe and secure;
Information we share with third parties
We do not share or otherwise disclose any personal information, including your name, address, or e-mail addresses with other organisations (other than where you have indicated your consent for us to do so). Only Liberty SIPP staff and our authorised agents have access to personally identifiable information provided by visitors to our Website.
We will share your personal data with third parties where required by law, or where it is necessary to fulfil our contract with you or where we or the third party has a legitimate interest and it is fair and reasonable in the circumstances to share the information. We will only share your personal data to the extent needed for those purposes.
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.
As we develop our business, we may seek investment, restructure our business, or sell assets, shares or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or any dissolution.
We may also disclose your Information to third parties if we are under a duty to disclose or share your personal data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights or property of Liberty SIPP, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
Where third parties are involved in processing your data we'll 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.
How do we protect your information?
The security and confidentiality of your information is extremely important to us.
We use technical, administrative, and physical security measures to seek to protect your information from unauthorised access and improper use. We may update our security measures from time to-time to ensure we are using new technology and safety methods. However, the internet is an open medium and we cannot guarantee that any information you send to us by email or via our sites will not be intercepted or tampered with; any transmission is at your own risk.
You also have a responsibility to protect against unauthorised access to your user name and password to your account and to your computer. You must not disclose your username and password to anyone else and you shall be personally responsible for any activity on the site which relates to your login details. Always sign off when completing any activity on your account and when finished using a shared computer.
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.
What about other websites linked to our website?
We are not responsible for the practices employed by websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Website or are submitted by other Registered Users of the Website.
Where do we store your personal information?
You have various rights in respect of the personal data we hold about you -- these are set out in more detail below:
Right to object: You can object to our processing of your personal data where we are relying on a legitimate interest (or the legitimate interests of a third party) to process your personal data and there is something about your particular situation which makes you want to object to processing on this ground.
Access to your personal data: You can request access to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for. You can make a request for access free of charge.
Consent: Most of the time, we won't need your consent to use your personal data as we will be using it only to fulfil our obligations to you. There are limited circumstances where we may ask for your consent to process your information. Where you have given us your consent to use personal data, you can withdraw your consent at any time.
Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
Erasure: You have the right to request deletion of your personal data, also known as the right to be forgotten.
Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred to you or a third party.
- Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
How can you access and correct your information?
You have the right to request a copy of the information that we hold about you free of charge. If you'd like a copy of some or all of your personal information, please email or write to us using the contact details noted below and we will respond within 30 days.
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 using the contact details below.
How long do we keep hold of your information?
In principle, your personal data shouldn't be held for longer than is required under the terms of our contract for services with you. However, we're subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. Please note that in the event of a pension transfer we are required to hold your record indefinitely.
We will not retain your personal data for longer than 7 years beyond the date of your SIPP being paid out on your death.
In all other cases we will hold records for a minimum of 7 years after the end of our relationship with you and longer where necessary in the event of active or potential legal proceedings, or to resolve or defend potential claims.
You have the right to request deletion of your personal data and we will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
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
Please send any questions or comments about this policy to:
EBS Pensions Limited
Deakins Business Park
Or email us at email@example.com