- You are looking for sound retirement advice and want to secure your financial future. -
This privacy policy describes our policies and procedures for collecting, using and disclosing your information when you use the Service and tells you about your privacy rights and how the law protects you.
We use Your Personal Data to provide and improve the Service. By using the Service, you consent to the collection and use of information in accordance with this Privacy Policy.
Words whose initial letter is capitalised have meanings defined under the following conditions. The following definitions have the same meaning whether they appear in singular or plural.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Business, for the purposes of the California Consumer Privacy Act (CCPA), refers to the company as the legal entity that collects consumers' personal information and determines the purposes and means of processing consumers' personal information, or on whose behalf such information is collected and that alone, or jointly with others, determines the purposes and means of processing consumers' personal information, doing business in the state of California.
Company (referred to in this Agreement as "the Company", "We", "Us" or "Our") refers to Website, 110 Gloucester Ave., London NW1 8HX, United Kingdom
For the purposes of the AVG, the company is the data controller.
Consumer, for the purposes of the California Consumer Privacy Act (CCPA), means a natural person who is a resident of California. A resident, as defined in the Act, includes (1) any individual who is in the US for other than a temporary or transient purpose, and (2) any individual domiciled in the US who is outside the US for a temporary or transient purpose.
Cookies are small files placed on your computer, mobile device or other device by a website that contain details of your browsing history on that website among its many uses.
Country refers to: 110 Gloucester Ave., London NW1 8HX, United Kingdom
Data Controller, for the purposes of the AVG (General Data Protection Regulation), refers to the company as the legal entity that alone or jointly with others determines the purposes and means of processing Personal Data.
Device means any device that can access the Service, such as a computer, a mobile phone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulators, particularly the US Federal Trade Commission (FTC), for the internet industry to develop and implement a mechanism for internet users to manage the tracking of their online activities across different websites.
Personal data is any information relating to an identified or identifiable person.
For the purposes of the AVG, Personal Data means any information relating to You, such as a name, an identification number, location data, online identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or can be associated with you, or can reasonably be linked to you directly or indirectly.
Sale, for the purposes of the California Consumer Privacy Act (CCPA), means selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise orally, in writing, or by electronic or other means, a consumer's personal information to another company or a third party for monetary or other valuable consideration.
Service refers to the Website.
Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to external companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purposes of the AVG, service providers are considered data processors.
Third-party social media services refer to any website or social networking site that allows a user to log in or create an account to use the service.
Usage data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g. the duration of a page visit).
Website accessible from Website
You means the person accessing or using the Service, or the company or other legal entity on whose behalf such person accesses or uses the Service, if applicable.
Under GDPR (General Data Protection Regulation), you may be referred to as the Data Subject or as the User, as you are the person using the Service.
In the course of using our Service, we may ask you to provide us with certain personally identifiable information that may be used to contact or identify you. Personally identifiable information may include, but is not limited to:
Usage data is automatically collected when using the Service.
Usage data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service you visit, the time and date of your visit, time spent on them, unique device IDs and other diagnostic data.
When you access the Service through or via a mobile device, we may automatically collect certain information, including, but not limited to, the type of mobile device you use, your mobile device's unique ID, your mobile phone device's IP address, your mobile operating system, the type of mobile internet browser you use, unique device IDs and other diagnostic data.
We may also collect information your browser sends when you visit our service or when you access the service through or via a mobile device.
The Company allows You to create an account and log in to use the Service through the following third-party Social Media Services:
If you decide to register through or otherwise provide us with access to a third-party social media service, we may collect personal data already associated with your third-party social media service account, such as your name, your e-mail address, your activities or your contact list associated with that account.
You may also have the option to share additional information with the Company through your external social media service account. If you choose to provide such information and personal data, during registration or otherwise, you authorise the Company to use, share and store it in a manner consistent with this privacy policy.
We use cookies and similar tracking technologies to track activity on Our Service and store certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse Our Service. The technologies we use may include the following:
Cookies can be "permanent" or "session" cookies. Permanent cookies remain on your PC or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
We use both session cookies and persistent cookies for the purposes set out below:
Necessary/essential cookies
Type: Session cookies
Managed by: Us
Purpose: These cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you have requested cannot be provided and we only use these cookies to provide you with those services.
Cookie policy / Cookie acceptance notice
Type: Permanent cookies
Managed by: Us
Purpose: These cookies identify whether users have accepted the use of cookies on the website.
Functional cookies
Type: Permanent cookies
Managed by: Us
Purpose: These cookies allow us to remember choices you make when you use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personalised experience and to avoid having to re-enter your preferences every time you use the website.
Tracking and performance cookies
Type: Permanent cookies
Managed by: Third Party
Purpose: These cookies are used to track information about traffic to the website and how users use the website. The information collected through these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is usually linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to introduce new pages, features or new functionality of the Website to see how our users respond to them.
Targeting and advertising cookies
Type: Permanent cookies
Managed by: Third Party
Purpose: These cookies track your browsing behaviour to enable us to show ads likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information and with our consent, third-party advertisers may set cookies to enable them to display ads that we think are relevant to your interests while you are on third-party websites.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy or the Cookies section of our Privacy Policy.
The Company may use Personal Data for the following purposes:
We may share your personal data in the following situations:
The Company will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we need to retain your data to comply with applicable law), resolve disputes and enforce our legal agreements and policies.
The Company also retains usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when it is used to enhance security or functionality of our Service, or We are required by law to retain it for a longer period.
Your information, including Personal Data, is processed at the operational offices of the Company and at any other places where the parties involved in the processing are located. It means that this information may be transferred to - and maintained on - computers outside your state, province, country or other governmental jurisdiction where data protection laws may differ from those of your jurisdiction.
Your agreement to this privacy policy followed by your submission of such information indicates your consent to that transfer.
The company will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this privacy policy and that your personal data is not transferred to any organisation or country unless adequate controls are in place, including the security of your data and other personal information.
If the company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will notify you before your personal data is transferred and becomes subject to a different privacy policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests from public authorities (e.g. a court or government agency).
The company may disclose your personal data in the good faith belief that such action is necessary to:
The security of your Personal Data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to transfer your Personal Data, we cannot guarantee its absolute security.
The service providers we use may have access to your personal data. These third-party vendors collect, store, use, process and transfer information about your activity on our service in accordance with their privacy policies.
We may use third-party service providers to monitor and analyse the use of our service.
Google Analytics
Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualise and personalise the advertisements of its own advertising network.
You can opt out of making your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.
For more information on Google's privacy practices, visit Google's Privacy and Terms of Service webpage: https://policies.google.com/privacy
We may provide paid products and/or services within the Service. In this case, we may use third-party services to process payments (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policies. These payment processors adhere to PCI-DSS standards as administered by the PCI Security Standards Council, a joint effort between brands such as Visa, Mastercard, American Express and Discover. PCI-DSS requirements help the secure handling of payment information.
Transfer
Authorize.net
Their privacy policy can be viewed at https://www.authorize.net/company/privacy/
PayPal
Their privacy policy can be viewed at https://www.paypal.com/myaccount/privacy/privacyhub
In-app payments from Google Play
Their privacy policy can be viewed athttps://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice
We may process Personal Data under the following conditions:
In any case, the Company will be happy to help clarify the specific legal basis applicable to the processing, and in particular whether the provision of Personal Data is a legal or contractual requirement, or a requirement necessary to enter into a contract.
The Company undertakes to respect the confidentiality of Your Personal Data and to ensure that You can exercise Your rights.
You have the right under this Privacy Policy, and under the law if you are located within the EU, to:
You can exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as soon as possible.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, if you are located in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
This privacy notice for California residents supplements the information in our privacy policy and applies only to all visitors, users and others residing in the state of California.
We collect information that identifies, relates to, describes, refers to, can be associated with, or can reasonably be linked, directly or indirectly, to a particular consumer or device. The following is a list of categories of personal information that we may collect or may have collected from California residents in the past twelve (12) months.
Please note that the categories and examples in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information have in fact been collected by us, but reflects our good faith belief to the best of our knowledge that some of that information can and may have been collected from the applicable category. For example, certain categories of personal information will only be collected if you provide such personal information directly to us.
Category A: Identifiers.
Examples: a real name, alias, postal address, unique personal id, online id, internet protocol address, email address, account name, driving licence number, passport number or other similar identifiers.
Collected: Yes.
Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: a name, signature, citizen service number, physical characteristics or description, address, telephone number, passport number, driver's licence or state identification card number, insurance policy number, education, Work, employment history, bank account number, credit card number, bank card number or other financial information, medical information or health insurance information. Some personal information contained herein category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under Californian or federal law.
Examples: age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or belief, marital status, medical condition, physical or mental disability, gender (including sex, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
Category E: Biometric information.
Examples: genetic, physiological, behavioural and biological characteristics or activity patterns used to extract a template or other id or identifying information, such as fingerprints, facial and voice prints, iris or retinal scans, keystroke, gait or other physical patterns and sleep, health or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interacting with our Service or ad.
Collected: Yes.
Category G: Geolocation data.
Examples: Estimated physical location.
Collected: No.
Category H: Sensory data.
Examples: audio, electronic, visual, thermal, olfactory or similar information.
Collected: No.
Category I: Occupational or work-related information.
Examples: current or previous job history or performance evaluations.
Collected: No.
Category J: Non-public educational information (under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student timetables, student identification codes, student financial information or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, disposition, behaviour, attitudes, intelligence, skills and aptitudes.
Collected: No.
Under CCPA, personal information does not include:
We obtain the above categories of personal information from the following categories of sources:
We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), including the following examples:
Please note that the above examples are illustrative and not intended to be exhaustive. For more information on how we use this information, please refer to the "Use of your personal data" section.
If we decide to collect additional categories of personal information or use the personal information we have collected for substantially different, unrelated or incompatible purposes, we will update this privacy policy.
We may use or disclose the following categories of personal information and may have used or disclosed it for business or commercial purposes in the past twelve (12) months:
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information have in fact been disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category can and may have been disclosed.
When we disclose personal information for a business or commercial purpose, we enter into a contract that describes the purpose and requires the recipient to keep that personal information confidential and not to use it for any purpose other than performing the contract.
We may share your personal information identified in the above categories with the following categories of third parties:
The CCPA provides California residents with specific rights regarding their personal information. If you are a California resident, you have the following rights:
To exercise your rights under the CCPA and if you are a California resident, please contact us:
By email: [email protected]
Only you, or a person registered with the California Secretary of State and authorised by you to act on your behalf, can make a verifiable request regarding your personal data.
Your request to us must:
We cannot respond to your request or provide you with the required information if we do not:
We will disclose and provide the required information free of charge within 45 days of receiving your verifiable request. The period for providing the required information may be extended once for another 45 days when reasonably necessary and with prior notice.
All disclosures we provide only cover the 12-month period prior to the receipt of the verifiable request.
For data portability requests, we will select a format to provide your personal information that is easily usable and should allow you to transmit the information from one entity to another without hindrance.
Under Section 1798 of the California Civil Code (California's Shine the Light law), California residents with an established business relationship with us may request information once a year about the sharing of their Personal Data with third parties for third-party direct marketing purposes.
If you would like to request more information under the California Shine the Light law and if you are a California resident, please contact us using the contact details below.
California Business and Professions Code section 22581 allows California residents under 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request deletion of such data, and if you are a California resident, please contact us using the contact details below and include the email address associated with your account.
Please note that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not allow or require removal in certain circumstances.
Our Service may contain links to other websites not operated by Us. If you click on a third-party link, you will be redirected to that third-party site. We strongly encourage you to read the privacy policy of each site you visit.
We have no control over and accept no responsibility for the content, privacy policies or practices of any third-party sites or services.
We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page.
We will let you know via email and/or a prominent notice on our service before the change takes effect and update the "Last updated" date at the top of this privacy policy.
You are advised to check this Privacy Policy regularly for any changes. Changes to this Privacy Policy are effective when posted on this page.
If you have any questions about this privacy policy, please contact us:
By email: [email protected]