Privacy Policy
INTRODUCTION
The EB Partnership London Limited (“The EB Partnership”) is dedicated to protecting the confidentiality and privacy of information entrusted to us. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.
This notice applies to any personal data provided to us, whether from a client or otherwise. In this notice “you” refers to your company. “Personal data” refers to any personal information provided to us to hold or process (i.e employee data or other corporate contacts).
This notice is governed by the EU General Data Protection Regulation (the “GDPR”).
WHO WE ARE
This Privacy Notice applies to The EB Partnership. This Privacy Notice explains to you what decisions we have taken in relation to Personal Data that we hold.
The EB Partnership London Limited is an Appointed Representative of Bond Wealth Ltd, which is authorised and regulated by the Financial Conduct Authority. The EB Partnership is registered, and operates, in England & Wales: registered number 08977367.
WHO CAN YOU CONTACT FOR PRIVACY QUESTIONS OR CONCERNS?
If you have you have questions or comments about this Privacy Policy or how we handle personal data, please direct your correspondence to: Data Protection Manager, The EB Partnership, Apsley House, 176 Upper Richmond Road, London, SW15 2SH or email enquiries@theebpartnership.co.uk. We aim to respond within 30 days from the date we receive privacy-related communications.
You may contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.
LAWFUL BASIS FOR PROCESSING PERSONAL DATA
We may rely on the following lawful reasons when we collect and process personal data to operate our business and provide our products and services.
To fulfil a contract we have with you;
You have provided your consent for the processing of data;
When it is in our legitimate interests - we may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced, including delivering the professional services our clients have engaged us to provide; or
To comply with legal and regulatory obligations.
WHAT INFORMATION DO WE COLLECT?
We may collect and process the following categories of personal data about you and your employees:
Financial : financial position, status and history.
Contact : name, where you live and how to contact you, as well as emergency contact details.
Socio-Demographic : gender, marital status, nationality, education.
Transactional : Details about payments to and from your accounts with us and third parties.
Contractual : Details about the products or services we provide to you.
Behavioural : Details about how you use products and services from us and other organisations.
Communications : What we learn about you from letters and emails you write to us, meetings and other communication between us, including telephone calls which may be recorded.
Family and beneficiary : Marital status, dependants, and other relationships, including names and dates of birth
Know Your Client : Details about you that are we may gain access to via a third party provider to verify your identity.
National Identifier : A number or code given to you by a government to identify who you are, such as a National Insurance or social security number, or Tax Identification Number (TIN).
Documentary Data : Details about you that are stored in documents in different formats, or copies of them.
Special categories of data : The law and other regulations treat some types of personal information as special, including health data, which we may use in the context of advising on insurance, pensions and similar products.
Consents : Any consents that you may give us and the data provided with your consent e.g., testimonials published on our website.
HOW DO WE COLLECT PERSONAL DATA?
Directly. We obtain personal data directly from companies and individuals in a variety of ways, including data provided on the application forms for the various services we offer; when you talk to us on the phone, including recorded calls and notes we make; or via other correspondence.
Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including the following:
Business clients -- you may provide personal data to us in order for us to deliver our services to you;
Service providers - this will include pension and other providers that we conduct business with on your behalf or your existing / previous providers that you have provided consent for us to contact;
Other third party providers – this may include credit reference agencies to verify your identity; product providers where you have appointed us as advisers or as an authorised point of contact to deal with your pensions, insurances and investments on your behalf; cloud-based service providers relating to the administration and management of employee benefits or personal finances.
You do not have to supply any personal information to us but our services may not be operable in practice without providing data to us.
WHAT WE USE PERSONAL DATA FOR
We use personal information for the purpose for which it has been provided to us, or to fulfil legal or regulatory requirements if necessary. We have a legitimate interest in holding and processing information provided to us in order to provide our services and up-to-date advice, as well as manage our relationship with you.
SHARING PERSONAL DATA
We will share personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We may share personal data with certain suppliers or other group companies who are assisting us with the management of employee benefits or IT services.
We will share personal data with other entities in our group i.e., Bond Wealth Ltd, as part of our regular reporting activities on company performance and to enable them to assess if we are conducting our business in line with the requirement of the Financial Conduct Authority.
Where we do supply personal data to a third party, they will only be authorised to process it for specified purposes and not for use for their own purposes.
SECURITY
We have put in place appropriate measures to protect the security of personal data, including the provision of annual training and testing for all our employees.
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
We will retain personal data for so long as the purpose you have provided it for still exists, unless a longer retention period is required or permitted by law, including:
To respond to a question or complaint, or to show whether we gave you fair treatment.
To obey rules that apply to us about keeping records, generally 3-10 years.
We may also keep personal data for longer than 10 years if we cannot delete it for other legal, regulatory or technical reasons. As an example, in some circumstances we may be required to hold pension transfer information indefinitely.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
We will only use personal data for those purposes and will make sure that employees’ privacy is protected at all times.
PRIVACY RIGHTS
The GDPR gives data subjects the following rights in respect of personal data we hold:
The right of access : Data subjects (eg employees) have the right to see personal data that is held about them and the right to a copy.
The right to correction : If at any point data subjects believe that the personal data we hold about them is inaccurate, they can ask to have it corrected.
The right to erasure (the ‘right to be forgotten’) : Data subjects may ask us to delete or remove personal data if there is no good reason for us continuing to process it. They also have the right to ask us to delete or remove personal data where they have successfully exercised their right to object to processing (see below), if we may have processed their information unlawfully or if we are required to delete personal data to comply with local law.
We may not always be able to comply with their request of erasure for specific legal reasons which will be notified to them, if applicable, at the time of their request.
The right to object to processing : Unless we have overriding legitimate grounds for such processing, data subjects may object to us using personal data if they feel their fundamental rights and freedoms are impacted.
The right to restrict processing : Data subjects can request that we no longer process personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability : Data subjects can request the transfer of personal information to another party (where technically possible).
Right to withdraw consent : If we are relying on their consent as the basis on which we are processing personal data, data subjects have the right to withdraw their consent at any time.
If they would like to exercise any of their above rights, please contact the Data Protection Manager in writing (or email) as detailed above.
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of requests).
DATA BREACHES
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and our Data Protection Manager.
If a breach is likely to result in a risk to you or data subjects, their data rights and freedoms, we will notify you and the data subjects as soon as possible.
OTHER WEBSITES
Our websites may contain links and references to other websites. Please be aware that this notice does not apply to those websites. Please review the destination websites’ privacy policies before submitting personal data on those sites. In addition, if you came to us via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site.
TRANSFERRING PERSONAL DATA OUTSIDE EUROPE
We store personal data on servers located in the European Economic Area (EEA) and transfer data to other parties within the EEA. There are certain cases where you may request we transfer personal data to another company in contract with them or within their group of companies that is situated outside the EEA. We carry out these requests on the understanding that you in your capacity as the “data controller”, can provide “sufficient guarantees” that the requirements of the GDPR will be met and that your rights will be protected.
NOTIFICATION OF CHANGES TO THE CONTENTS OF THIS NOTICE
We will post details of any changes to our policy to our website, to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
POLICY TOWARDS CHILDREN
Our services are not intended for and should not be accessed by individuals under 16. Our policy is not to intentionally or knowingly collect, process, maintain or use personal information from any individual under the age of 16.
HYPERLINKING
You may link to this Site provided you link to theebpartnership.co.uk home page in a new browser window. You may not deep-link nor frame this Site. The Site may contain hyperlinks to websites provided by third parties outside of The EB Partnership. The EB Partnership is not responsible for the availability or content of such sites. Links to third party sites are provided solely as a convenience to you and do not constitute any endorsement, authorisation, sponsorship, affiliation or publication by The EB Partnership of such site, its owners or providers.
GENERAL
There are risks in using any information, software or products on the Internet and The EB Partnership cautions you to make sure you completely understand these before retrieving, using or relying upon or purchasing anything via the Internet. It is your responsibility to verify any information before relying on it.
The EB Partnership reserves the right to make changes to any part of the Site and these terms.
These terms shall be governed by, and construed in accordance with, English law. You irrevocably agree that the courts of England shall (subject to the paragraph below) have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with these terms or the relationship established by them.
For the exclusive benefit of The EB Partnership, The EB Partnership shall retain the right to bring proceedings as to the substance of the matter or otherwise in the courts of the country of your residence or, where these terms are entered into in the course or your business, the country of your principal place of business.
If any provision of these terms is found to be invalid by any court having competent jurisdiction, the invalidity of that provision will not affect the validity of the remaining provisions which shall remain in full force and effect.
Failure by The EB Partnership to exercise any right or remedy under these terms does not constitute a waiver of that right or remedy. Headings in these terms are for convenience only and shall have no legal meaning or effect.
THE EB PARTNERSHIP COPYRIGHT NOTICE
All copyright, database right and other intellectual property rights in the Content belong to The EB Partnership London Ltd. Except as expressly set out, nothing herein shall be construed as conferring any licence or other right in relation to the Content.
You may retrieve and view the Content on-screen and print on paper (but not photocopy) or store in electronic form on a local hard disk or WAP enabled device (but not on any server or other device connected to a network) a reasonable amount of the Content for your personal and non-commercial use only.
You may not otherwise modify, copy, distribute, transmit, display, perform, reproduce, publish, licence or create derivative works from the Content.
Requests to republish or redistribute the content should be addressed by contacting enquiries@theebpartnership.co.uk.
The EB Partnership London Ltd registered office is Apsley House, 176 Upper Richmond Road, London SW15 2SH.
THE EB PARTNERSHIP LEGAL NOTICE
The EB Partnership is a trading style of The EB Partnership London Ltd who is an appointed representative of Bond Wealth Limited which is directly authorised and regulated by the Financial Conduct Authority. Bond Wealth Limited is registered in England & Wales at 8th Floor Cannon Green, 27 Bush Lane, London, EC4R 0AA Registered Number: 08587349 and entered on the FCA Register No 778835 (www.fca.gov.uk/register). The information contained within this site is subject to the UK regulatory regime and is therefore targeted primarily at consumers based in the UK. Please read our Privacy Policy before completing any enquiry form or before sending an email to us.
You must read the important disclaimers which follow as they affect your use of the Site.
NO WARRANTIES
BECAUSE OF THE NATURE OF THE INTERNET THE EB PARTNERSHIP DOES NOT GIVE ANY WARRANTIES IN RESPECT OF THE SITE (INCLUDING THE CONTENT AND ANY SOFTWARE OR SERVICES AVAILABLE THROUGH IT). AND (TO THE FULLEST EXTENT ALLOWED BY LAW) DISCLAIMS ALL WARRANTIES, CONDITIONS OR DUTIES OF EVERY NATURE WHATSOEVER, INCLUDING WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF SATISFACTORY QUALITY OR OF FITNESS FOR A PARTICULAR PURPOSE, ANY EXPRESS OR STATUTORY WARRANTIES, AND ANY WARRANTIES OR DUTIES REGARDING ACCURACY, TIMELINESS, COMPLETENESS OR PERFORMANCE. THE EB PARTNERSHIP DOES NOT WARRANT OR REPRESENT THAT THE SITE IS CURRENT OR FREE FROM INFECTION BY VIRUSES, TROJAN HORSES OR WORMS OR ANYTHING ELSE THAT HAS CONTAMINATING OR DESTRUCTIVE PROPERTIES.
DAMAGES
YOU AGREE THAT (TO THE FULLEST EXTENT ALLOWED BY LAW) THE EB PARTNERSHIP LONDON LTD WILL NOT BE LIABLE TO YOU AND/OR ANY THIRD PARTY FOR ANY DAMAGES (INCLUDING, WITHOUT LIMITATION, DAMAGES FOR ANY INDIRECT OR CONSEQUENTIAL LOSS, LOSS OF BUSINESS OPPORTUNITIES OR PROJECTS, OR LOSS OF PROFITS) HOWSOEVER ARISING EVEN IF THE EB PARTNERSHIP LONDON LTD HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IN THE EVENT OF FAULT, TORT (INCLUDING NEGLIGENCE, STRICT LIABILITY OR OTHERWISE). NOTHING IN THE FORGOING SHALL HOWEVER EXCLUDE OR LIMIT LIABILITY FOR DEATH OR PERSONAL INJURY CAUSED BY THE EB PARTNERSHIP LONDON LTD’S NEGLIGENCE NOR LIABILITY FOR ANY CLAIM RESULTING FROM ANY FRAUDULENT ACT(S) (INCLUDING THEFT AND CONVERSION) BY THE EB PARTNERSHIP LONDON LTD.