Privacy Policy

Privacy

In order to provide firms with our products and services Risk Tailors Limited will have sight of personal data for the clients using our services. Risk Tailors is committed to protecting and respecting your privacy.
Risk Tailors Limited (also referred to as RiskTailors) are the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection officer by sending an email to compliance@risktailors.com
We reserve the right to update this privacy policy from time to time.

What data do we hold

We hold personal data for Advisors, Directors and Partners at the advisory firms we work with or who have expressed an interest in the services we provide via our contact form, email or telephone. We will also hold data relating to third parties that we currently have or previously have had commercial relationships with. This data will include names, addresses, telephone numbers, email address and general correspondence received via electronic and paper form.
Whilst our client is the financial adviser, we may receive data relating to the end investor. This makes us a data processor rather than a data controller. The information that we may receive from the advisors about their clients may include names, emails, date of birth and investment details such as portfolio numbers, balances, transaction histories.
We also hold data relating to staff members including names, dates-of-birth, addresses, National Insurance Numbers, identification, bank details and general correspondence.
We may collect information such as language, unique device identifier, IP address, geo-location, and the time zone where our website is used so that we can better understand usage habits and improve our products, services, and advertising. This information will always be used in an aggregated form and be used to help us provide more useful information to our users and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non-personal information.
If for any reason we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined and as such be applicable to the terms as outlined in the Automated Decision-Making and Profiling section
Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Where does the data come from

When an adviser registers on our website, they will be asked to provide personal data relating to themselves, their firm and their clients for whom they deem our products suitable. Data may also be received via email, contact forms on our website, telephone and post. We also provide advisers with an online questionnaire to help them provide additional information about which Risk Tailors portfolio may be more suitable for their clients. Risk Tailors will store this data in a secured form for the benefit of the advisers, but we take no responsibility for its accuracy.
We may be provided with data by third parties where there is a genuine need for the information.
We may collect directly from websites and registers such as the FCA register.

Who we share data with

We may pass your information to third party service providers, agents and other associated organisations for the purpose of completing tasks and providing services to you on our behalf. Only personal information that is necessary to deliver the service will be shared and we will have a contract in place that requires them to keep your information secure and not use it for their own direct marketing purposes.
We will not release your information to third parties beyond the firm for them to use for their own direct marketing purposes, unless you have requested us to do so, or where we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crimes.
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We are allowed to disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer.
• We can disclose it to other businesses in our group.
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.

How do we use the data

The data is used for future communications and to ensure we can provide its services to the data subject and for management information purposes, account management and adherence to the terms specified within our agreements.
We may use your data to:

• Act as the basis for any service we provide.
• To carry out our obligations arising from any contract entered by you and us.
• Provide information to platforms for the purpose of arranging investment solutions.
• To establish and administer accounts you set up with us and to fulfil the terms of any agreement you have with us;
• Provide ongoing services to you.
• Meet the regulatory obligations of the services we provide.
• Present site content effectively to you;
• Provide information, products and services that you request, or (with your consent) which we think may interest you;
• To notify you of any changes to our services, products;
• Allow you to use our interactive services if you want to; and
• Tell you our charges.

Our website may collect and use your personal information in order to operate and improve the services it provides. These uses include making the website or service easier to use by eliminating the need for you to repeatedly enter the same information and performing research and analysis aimed at improving our products, services and technologies.
If you are already our customer, we will only contact you electronically about things similar to what was previously provided to you.
If you are a new customer, you will only be contacted if you agree to it.
If you don’t want to be contacted for marketing purposes, please let us know.
In addition, if you don’t want us to use your personal data for any of the other reasons set out above, you can let us know at any time by contacting us at compliance@risktailors.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.

How is data stored and how is this protected?

We may transfer your collected data to storage outside the United Kingdon (UK). It may be processed outside the UK to fulfil our obligations to you under our agreement.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. Careful consideration has been taken to ensure that the information provided is correct but it neither warrants, represents nor guarantees the contents of the information, nor does it accept any responsibility for errors, inaccuracies, omissions or any inconsistencies herein.
If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

Change of details

If any of the information that you have provided to us changes, please let us know the correct details by emailing or telephoning your usual contact at the firm as it is important that the personal data we hold about you is accurate and current.
If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

Your rights

You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at compliance@risktailors.com
Under the UK GDPR, you have the right to:

• request access to, deletion of or correction of, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.

You also have rights with respect to automated decision-making and profiling as set out below.
To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at compliance@risktailors.com

Links to other sites

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Automated Decision-Making and Profiling

In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under UK GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
The right described above does not apply in the following circumstances:

a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.
Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Dispute Resolution

The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.
If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.