PRIVACY POLICY

At Kingswood we are dedicated to safeguarding and preserving your personal information. This Privacy Policy (“Policy”) explains what happens to any personal information that you provide to us for your records.

At Kingswood we are dedicated to protecting and preserving your personal information. This policy details how we collect, use, disclose and store your personal data. We are responsible for ensuring that we adhere to Data Protection Laws when using your personal data. Under the FCA ‘Consumer Duty’ we also want to ensure our activities put our customers’ needs first by acting in good faith, supporting consumer financial objectives and avoiding foreseeable harm in regards to personal data.

This privacy notice applies to past, potential or current Kingswood clients/intermediaries, it also applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. By continuing your interaction, via the use of any of our services you are acknowledging that you have been made aware of the practices described in this policy and our use of your personal information.

We collect information about you when you engage us for financial planning, financial advice or investment management services. The personal data which we collect and use may include things such as your personal details (i.e. name, email address, phone number) and information which is relevant to us providing any services to you (such as financial circumstances, your bank details and records of communications). We may also collect and use some special categories of personal data such as information about health conditions if this is necessary for the provision of our services.

It is compulsory that we ask you for this information in order to enter into an agreement with you whilst fulfilling our regulatory obligations. Failure to provide the information we ask for could mean that we are unable to provide our services either wholly or in part.

In order to provide our services effectively, we may need to gather information about your close family members and dependants. It is your responsibility to ensure that you have the consent of the people concerned to provide us with the required information. You should refer them to this privacy policy before sharing their information with us.

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The data provided is essential for us to be able to carry out the services that you require effectively. Without this personal data, we’d also be unable to fulfil our legal and regulatory obligations. Where special category data is required, we’ll obtain your explicit consent in order to collect and process this information.

Personal data is necessary for our legitimate business interests. These include enforcing the terms and conditions of any agreement we have with you, assessing the suitability of any wealth planning or investment decision made directly by you or by us and improving customer service and training staff.

We may also use information to develop and test the effectiveness of marketing activities and to improve our services.  In addition, we may use it to provide you with marketing information about services and products we offer which may be of interest to you and to notify you about changes to our services and products. You have the right to request us not to process your information for marketing purposes at any time by contacting us at [email protected]

We collect information about you in order to provide you with the services for which you engage us, this will allow for Kingswood to provide optimal services for you under our agreement.  Data provided will be used to take decisions regarding your account which would include assessing your suitability for certain products and services.  Your data may also be used in the interest of Kingswood for statistical and research purposes.

We may use your personal data for the purposes of conducting credit/identity checks and financial crime and anti-money laundering enquiries or assessments. If we are unable to verify your identity, we will require further information in order to perform these checks. There may also be some instances where this personal information could be used in the need to establish, exercise or defend our legal rights or for the purpose of legal proceedings.

We may share your personal information with any member of Kingswood Group, which means our ultimate holding company and its subsidiaries. We may transfer information outside of the European Economic Area (the “EEA”), but before doing so, we shall endeavour to put in place appropriate transfer agreements and protective measures and take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and General Data Protection Regulation (GDPR).

We may be under a duty to disclose or share your information in order to comply with any legal obligation or regulatory requirements. This includes sharing information with any relevant authority where we are obligated to do so including but not limited to regulators, government and law enforcement or fraud prevention agencies.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes. We may provide information to our appointed auditors and other professional advisers to the extent that they require such information to provide advice.

In the event we sell or buy any business or assets, we may disclose your information to the potential seller or buyer of such business for due diligence purposes. We may share information in order to enforce the terms of any contract a client has with us.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements/notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We take a multi-layered approach to data protection and cyber security, using industry best practices to ensure client data is kept secure. Technical measures include both proactive and reactive technologies to prevent/detect any breaches of data. These technical measures are supported by data usage policies and cyber security training for all staff. We have a strong cyber security culture amongst our management team and regularly review incident response readiness.

During the course of the relationship between the client and Kingswood, we’ll retain personal data which is necessary to provide services to you. Necessary steps will be taken to ensure your personal data is up to date throughout the relationship.

Any personal information that we do obtain from you will be handled in accordance with data protection law. Your personal data will be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of our regulatory retention time frameworks are within our Data Retention Policy which is available upon request.

You have rights under data protection law that relate to the way we process your personal data and you can exercise your rights by contacting us with the details below. More information can be found on the Information Commissioner’s website.

Your rights:

• Access - You have the right to access the personal data we hold about you and request a copy of this information.
• Correction - You have the right to make us rectify any inaccurate data we hold about you.
• Erasure – You have the right to make us erase any personal data we hold about you. Note that in certain circumstances we may be legally entitled to retain your personal information.
• Restrict or object to processing – You have the right (in certain circumstances) to restrict or object to our processing of the personal data we hold about you. There may be circumstances where we are legally entitled to keep your data.
• Data portability - The right to receive personal data you have provided to us in a portable format or otherwise.
• Withdraw – You have the right to withdraw your consent where we are relying on it to use your personal data (e.g. for marketing purposes).
• Complain – You have the right to make a complaint to the data protection regulator.

As stated above, you have a right to request a copy of the information we hold about you. You can submit a “data subject access request” which enables you to receive a copy of some or all of your personal information. We have a responsibility to ensure that your details are accurate and up to date.

If you wish to submit a request, please use the contact details of the Senior Manager in charge of Data Protection ([email protected])

With your consent, where such consent is required under the applicable regulations and data protection laws, we will send you information about products and services of ours and other companies in the Kingswood Group which may be of interest to you. It is your right at any time to stop us from contacting you for marketing purposes – as such, you may withdraw your consent or otherwise opt out of receiving this information at any point. If you would like to do so, please contact our Senior Manager in charge of Data Protection using the details below.

You will still receive service notifications that we need to send you containing important information in relation to the service we are providing to you. In order for us to fulfil any agreement, this is necessary.

We keep our privacy policy under regular review and reserve the right to update this at any time – we would recommend checking back regularly to see if there have been any changes.

KW Wealth Group Limited

KW Investment Management Limited

KW Wealth Planning Limited

Regency Investment Services Limited

Money Matters (North East) Limited

Eurosure Limited

Allotts Financial Services Limited

Joseph R Lamb Independent Financial Advisers Limited

Sterling Trust Professional Limited

Sterling Trust Professional (North East) Limited

Sterling Trust Professional (Sheffield) Limited

Sterling Trust (York) Limited

Metnor Holdings Limited

IBOSS Asset Management Limited

IBOSS Limited

Novus Financial Services Limited

IPN Partners Limited

Barry Fleming and Partners Investments Planning Limited

AIM Independent Limited

Strategic Asset Managers Limited

Employee Benefit Solutions Limited

JCH Investment Management Limited

JFP Financial Services Limited

We hope that you will never have reason to complain about the way we process your personal information or with the way we’ve handled a request by you in relation to your rights. However, if something does go wrong please bring it to our attention as soon as you can and we will try to resolve the matter fairly and quickly. Please contact us on the same email address as above. You also have the right to make a complaint to the Information Commissioner’s Office via the below address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

If you have any questions about this Policy or wish to exercise any of your rights please get in touch with us either at [email protected] or by writing to the Senior  Manager in charge of Data Protection at the following address: ​

Paul Hammick
Kingswood Group
10-11 Austin Friars
London
EC2N 2HG​

Published August 2024