Our Privacy Notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).

We take your privacy seriously and this notice provides information about your privacy rights and how we gather, use and share your personal information.

Summary

Who we are

Portland Financial Management Limited of 29 Portland Terrace, Newcastle upon Tyne, NE2 1QS acts as controller for the personal information you provide to us.

Your rights

You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use. In addition, you have a right to complain to us and to the data protection regulator. Contact details are shown here:

 

• Portland Financial Management: write to us at the address shown above or email us at email@pfm-uk-com.stormpr.uk.
• Information Commissioner: ico.org.uk/global/contact-us

Your privacy rights are detailed more fully on the following pages.

How we gather and use personal information

We need to obtain information about you, so that we can provide the financial advice you require. This information is normally obtained directly from clients in a face to face meeting. It may also be obtained by telephone, post or other means. We hold such information as Data Controllers in accordance with the requirements of the EU General Data Protection Regulation and any equivalent legislation that is adopted in England and Wales, together referred to as the ‘Regulations’. We use this information to analyse your current and future financial needs so that we can ensure that any subsequent advice takes due account of, and is suitable to, your circumstances. We will not share your information with any other party except as indicated in this Privacy Statement or where required to do so by any statutory, governmental or regulatory body for legitimate purposes.

Sharing and transferring personal information

Where necessary to the provision of our service, we may share your personal information with third parties. The categories of third party are listed later in this notice. We will confirm the actual third parties with whom we might/will share your information when we have identified the product/service providers that we recommend you use. This will usually be done in the suitability report in which we detail our recommendations to you.

Until you have been informed of the actual third parties with whom we might share your information, and have not withdrawn your consent to that sharing, we will only share in a way that does not enable the third party to identify you. Sometimes we transfer personal information to other countries outside the UK for these purposes.

Keeping personal information

We keep your personal information securely for as long as we need to for the purpose of providing you with financial advice under the terms of our service/fee agreement (contract) or for as long as we are required to by relevant regulations.

Legal basis for collecting/processing information

The legal basis on which most of the information that you provide will be collected and processed is to enable us to provide the financial advice that we have agreed you require. However, some types of information require your explicit consent.  In particular, in relation to any adverse health history you might have. We will seek your consent if required. Where you have given us consent, you have the right to withdraw it at any time.

Full Privacy Notice

Introduction

We take your privacy seriously and you can find out more below about your privacy rights and how we gather, use and share your personal information.

Your Privacy Rights

You have the right to see what personal information we hold about you and you can ask us to correct inaccuracies, delete or restrict personal information or ask for some of your personal information to be provided to someone else. You have the right to object to how we use your personal information. If you need to contact us in relation to any of your rights or wish to make a complaint about how we have used your personal information directly to us or to the Information Commissioner’s Office, you can use the contact details indicated on the first page of this notice.

• Right to withdraw consent: Where you have given us your consent to use personal information, you can withdraw your consent at any time.
• Access to your personal information: You can request access to a copy of your personal information.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a commonly used electronic form.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Note that we might be required by regulations to retain your information even if you want it to be deleted.
• Right to object: You can object to our processing of your personal information.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

Legal basis for collecting/processing information

The legal basis on which most of the information that you provide will be collected and processed is to enable us to provide the financial advice that we have agreed you require.

However, some types of information require your explicit consent.  In particular, where we identify that it is relevant to obtain details from you in relation to any adverse health history you might have, we will seek your explicit consent.

Where you have given us consent, you have the right to withdraw it at any time.

What kinds of personal information we use

We use information relating to your personal situation and financial position.

How we gather your personal information

We obtain personal information:

• directly from you, usually in a face to face meeting but potentially also by telephone or other means;
• from other organisations such as investment/pension/insurance providers, where you have provided authority for them to share information relating to your existing plans;
• from your professional advisers, where you have provided authority for them to share information.
• We may also obtain some personal information from recording calls or meetings or by making contemporaneous notes of calls or meetings.

How we use your personal information

We hold your personal information as Data Controllers in accordance with the requirements of the EU General Data Protection Regulation and any equivalent legislation that is adopted in England and Wales, together referred to as the ‘Regulations’.

We use this information to analyse your current and future financial needs so that we can ensure that any subsequent advice takes due account of, and is suitable to, your circumstances.

We will not share your information with any other party except as indicated in this Privacy Statement or where required to do so by any statutory, governmental or regulatory body for legitimate purposes.

Sharing and transferring personal information

Where necessary to the provision of our service, we may share your personal information with third parties. The categories of third party are listed below.

• Life, Pension and investment Product Providers, Platform Providers
• Investment Management Service Providers
• Compliance Advisers
• Legal Advisers
• Back Office Systems Providers
• Third Party Software Providers
• Our affiliates
• Our regulators, Supervisory Authority, and insurers
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

As we are fully independent, we use a diverse range of providers when researching investment recommendations and arranging and managing investments. Please see Annex 1 for the current list of providers with whom we might share your information.

We will confirm the actual third parties with whom we might/will share your information when we have identified the product/service providers that we recommend you use. This will usually be done in our suitability report in which we will detail our recommendations to you.

Until you have been informed of the actual third parties with whom we might share your information, and have not withdrawn your consent to that sharing, we will only share in a way that does not enable the third party to identify you.

Where necessary to implement the service that you require, your personal information might be transferred to other countries outside the UK, ensuring that your rights are protected as detailed in the GDPR. Where data is transferred, technological security measures will be implemented to protect the data, however due to the data being transmitted across the internet no guarantees can be made.

Keeping personal information

We keep your personal information securely for as long as we need to for the purpose of providing you with financial advice under the terms of our service/fee agreement (contract) or for as long as we are required to by relevant regulations.

Cookie Statement

What exactly are cookies?

In order to collect the information including personal data as described in this Notice, we may use cookies and similar technology on our website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. Cookies can be first party, i.e. cookies that the website you are visiting places on your device, or third party cookies, i.e. cookies placed on your device through the website but by third parties, such as, Google. For more information please visit www.allaboutcookies.org.

The cookies placed on our website.

We use the following cookies on our website:

1. Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, the Website and related services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
2. Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first party cookies.
3. Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
4. Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
5. Social Media cookies. These cookies allow you to connect with social media networks such as Facebook, twitter, LinkedIn and Google+. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

We may combine information from these types of cookies and technologies with information about you from other sources.

Cookie consent and opting out.

By using our Website, we assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Website and related services.

If you are based in Europe and cookies are active, when you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit.  If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings.

You may also opt-out from third party cookies by selecting appropriate options on http://www.youronlinechoices.com/uk/.