Please note that we require certain personal information to be able to provide you with our services and products. If you do not provide such information, this may limit our ability to do so.

We may ask you to provide information that contains special categories of personal data about you (for example, your health information). In such cases, we will obtain your express consent to process the information.

If you volunteer information to us that contains special categories of personal data, you will be regarded as giving your explicit consent to us processing it. We will always seek to confirm with you that this is the case.

How do we collect personal information?
We will collect personal information from you in a variety of ways, such as:
• Directly from you, through information provided when completing forms, and when the firm is in correspondence with you. This could be in person, by telephone or online.
• From our agents and intermediaries, or other introducers such as financial advisors.
• Credit Reference Agencies (CRAs) or Fraud Prevention Agencies (FPAs) from their records relating to you and other people with whom you are linked financially.
• Any person that provides your information to us (for example, a member of your household in seeking to obtain a product or service from us).
• Publicly available sources, such as Companies House and social media sites.

Where you provide personal information to us about other individuals (for example, members of your family or other dependants) we will also be the data controller of their personal information, and we are responsible for protecting their data and using it appropriately. This notice will therefore apply to those individuals, so please refer them to this so that they can find out more.

We may process personal information relating to criminal convictions or offences as a result of our fraud prevention searches.

We will only use your information if we have your permission, or we have another lawful basis for doing so. This includes meeting our compliance obligations and to provide the service required.

The lawful bases that we rely upon in order to process your personal information are that the processing is necessary:
• for the performance of any contract we enter into with you or to take steps at your request prior to entering into a contract with you.
• in order to comply with our legal and regulatory obligations.
• to fulfil our ‘legitimate interests’. Broadly speaking, this is when we have a business or commercial reason to use your personal information. When doing so, we must ensure it does not conflict unfairly with your own interest. This includes:
• ensuring that we provide you with responsible advice and appropriate services and products.
• seeking to prevent fraud and money laundering.
• providing you with an excellent standard of service, which includes providing you with information about services or products, investment news & opportunities, invitations to seminars & events and publications & newsletters that we feel will be of interest to you.

We may require your consent to communicate by certain channels and we will always make sure we obtain this where we need to (i.e. marketing by email). Where you have provided consent, please note that you may withdraw it at any time by contacting the firm at the details below.

If you do not wish to receive marketing communications from us, you may opt out at any time. You can send an email to info@redmayne.co.uk or write to us at the address below. If you opt out of our use of your personal information for marketing purposes, we will honour such choice once we have had reasonable opportunity to process your request.

Why do we collect personal information?
We process your personal information for a number of reasons connected with providing financial planning, investment management and stockbroking services. These include:
• Verifying your identity and understanding your circumstances before we offer or recommend to you a service, product or course of action.
• Administering and managing any account your hold with us.
• Communicating with you, including to send marketing to you by post and email in respect of services and products which we feel will be of interest to you (unless previously opted out of receiving marketing from us).
• Maintaining and improving the website.
• Reporting to the Financial Conduct Authority (FCA), or any other regulatory or enforcement body or government agency.

Who will we share your personal information with?
When providing our services to you as described above, we many disclose your personal information to the following third parties:
• Regulatory bodies and enforcement agencies.
• Government agencies, such as HMRC, and the London Stock Exchange.
• Credit reference agencies (CRAs) and Fraud Prevention Agencies (FPAs).
• Third parties who we engage to provide services to us (for example, our third party software and service provider).
• Other financial institutions or services whose products we may provide or propose to you (for example, fund managers or payment service providers).
• Companies, organisations or people where you have agreed with us to share your data (for example, your solicitor or accountant).

Redmayne Bentley may utilise LexisNexis to verify your identity when required under Money Laundering Regulations. For information on how LexisNexis process your data, please refer to their privacy notice at https://www.lexisnexis.com/global/privacy/en/privacy-policy-uk.page

We will ensure that data processing agreements are in place where appropriate.

Storage and transfer of your personal data
All information you provide to us is stored on secure servers within the UK. We do not systematically transfer your personal data outside the European Economic Area (EEA).

If you hold shares overseas we may transfer personal information relating to your shareholding to the location in which they are held. We do so on the basis that the transfer is necessary for the performance of the contract that we have with you or is a pre-contractual measure taken at your request.

Should we transfer your personal information outside the EEA in any other ways, we will ensure that there is adequate protection in place in respect of that transfer.

Retention of your personal data
We will retain your personal information for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Privacy Policy, unless we are required to keep it for a longer period by regulation or we have legitimate reasons for doing so.

If you do not have an account with us but you have agreed to receive marketing from us, we will hold your contact details for marketing purposes unless you request otherwise.

What are your data protection rights?
You have specific rights in respect of the personal information that we process about you. If you seek to exercise your rights, we will explain whether or not the right applies to you. Please be aware that if your request is manifestly unfounded or excessive we may refuse to deal with your request or charge a reasonable fee for dealing with it.
Your rights include:
• The right of access to the personal data we hold about you. This can be exercised via a Data Subject Access Request.
• The right to rectify (i.e. correct) your personal data where it is inaccurate or incomplete.
• The right to delete your personal data, but only in specific circumstances, for example where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed. It may not therefore always be possible for us to delete the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
• The right to restrict processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the request.
• The right to data portability which means the right to receive, move, copy or transfer your personal data to another controller. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
• The right to object to processing in cases where processing is based upon our legitimate interests or where processing is for direct marketing purposes (including profiling).

Please contact leedscompliance@redmayne.co.uk if you would like to exercise any of your data protection rights or if you have any queries in respect of your rights.

What are ‘Cookies’ and how do we use them?
Cookies are small pieces of data that websites store on your browser when you visit them. Cookies allow a website to recognise your visit and collect information about how you use that website.

Our cookie policy contains more details on how we use cookies, and this is available at redmayne.co.uk/cookie.

Changes to this Privacy Policy
We may edit or amend this Privacy Policy from time to time in which case we shall publish the amended version on our website.

We will inform you should we process your personal information for a purpose other than the purpose for which it was obtained.

Links to other websites
This Privacy Policy does not extend to your use of, provision of or collection of data on any website to which you may be using the hypertext links within our website.

How to contact us
If you have any questions about our Privacy Policy please contact us at:
Redmayne Bentley LLP, 3 Wellington Place, Leeds LS1 4AP
Telephone: 0113 243 6941
E-mail: info@redmayne.co.uk
Office opening times: 8am - 5pm, Monday to Friday.

Please note that you can complain to our supervisory authority, the ICO by telephoning 0303 123 113 or writing to Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. For further information, the ICO’s website can be accessed at www.ico.org.uk.