Triangle Paraplanning is committed to privacy for everyone who accesses the site. Under the Data Protection Act 1998, we must comply with certain requirements which are designed to ensure that any data you provide to us is processed with due care and attention We ask that you read this Privacy Policy ('the Policy') carefully as it contains important information about how we will use your personal data.  For the purposes of the Data Protection Act 1998, Finchbrook Limited trading as Triangle Paraplanning ('we' or 'us' or 'our') is the 'data controller' (i.e. the company who is responsible for, and controls the processing of, your personal data).

What personal data is

Personal data is any information that can be used to identify a living person, including names, delivery details, IP addresses, or HR data such as payroll details.

Personal data we may collect about you

We will obtain personal data about you (such as your name, address and contact information whenever you complete an online form.  If you submit any cases to us, we will also obtain information about your clients in order to complete our function.

The collection of personal information is necessary in order to fulfil our contract with you for the provision of services that you have engaged us for.

Sensitive personal data requires individual consent to hold and process.  We do not normally request or process any sensitive personal data but if it is necessary as part of fulfilling our contract with you, any provision of sensitive personal data by you to us will be taken as consent to us using the data to fulfil our contractual obligations with you.

Sensitive personal data includes but is not limited to:

• Biometric Information
• Ethnic origin
• Health
• Religion
• Sexual orientation

Once we have responded to your enquiry your data will be transferred to an encrypted server, located either in the EEA or US. If this is a US based server, this will be covered by the EU-US Privacy Shield. Where communications are ongoing we will store your contact details and use cloud services to share them across our devices to facilitate this.

If you fail to provide personal data

 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform that contract (for example, to provide you with services). In this case, we may have to cancel a service or order you have with us and we will notify you of this at the time.

How we use your personal data

We will not share your data with any other organisation for marketing purposes.

We will use your personal data and your clients' personal data for the purposes of completing any work that we have been contracted for by you.

These purposes include:

• to help us identify you and any accounts you hold with us
• administration
• assisting law enforcement agencies
• fraud prevention and detection
• billing and order fulfilment
• Anti Money Laundering checking
• to notify you of any changes to this website or to our services which may affect you
• Providing our service (where you need to be happy with the terms and conditions you have with your clients allow for this)
• improving our services
• Obtaining additional information from third party providers as is necessary for the completion of our work for you.

Third party links

This 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. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

Marketing and opting out

Unless you have asked us not to do so, we may contact you by mail, telephone, SMS, text/picture/video message, fax, email or through social media about products, services, promotions, special offers, charitable causes which may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights' below.

Disclosure of your personal data

We may disclose your personal data to:

• other companies within our group
• our agents and service providers [(eg providers of web hosting or maintenance services)]
• law enforcement agencies in connection with any investigation to help prevent unlawful activity
• In order to fulfil our obligations under any contract for services we may need to share your data with third party Data Controllers and Data Processors.

Keeping your data secure

Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.

Monitoring

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

Information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his or her personal data
• receive on his/her behalf any data protection notices
• give consent to the transfer of his/her personal data abroad
• give consent to the processing of his or her category or categories of sensitive personal data, eg health information.

Data controllers

This will include:

• Product & service providers in relation to investments, plans and pensions.
• Our compliance services.
• The Financial Conduct Authority.
• The Financial Ombudsman Service.
• Any other regulators where so required.

We also use external Data Processors that will hold information for the following purposes:

• Research
• Secure file sharing
• Data backup
• Communications
• Accounts
• Forecasting
• Record keeping
• Regulatory compliance

All external processors are only permitted to process the data in line with our instructions.

Transfers of data out of the EEA

We may need to transfer your personal data outside the European Economic Area*. Any transfer of your data will be subject to a European Commission approved contract which will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data.

Subject access request

*A 'subject access request' is a request received from a data subject asking for access to personal data which we process about him or her

Your rights

You have the right, subject to the payment of a small fee (currently £10) to request access to personal data which we may possess about you. If you wish to exercise this right you should:

• put your request in writing
• include proof of your identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill)
• attach a cheque in the amount of £10 made payable to Finchbrook Limited and specify the personal data you want access to, including any account or reference numbers where applicable.

You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right you should:

• put your request in writing
• provide us with enough information to identify you (eg account number, username, registration details)
• specify the information that is incorrect and what it should be replaced with.

You also have the right to:

• Require that any personal data that we hold about you is transmitted to another data controller
• To request that we restrict our data processing activities or cease processing your personal data in certain ways, for example because you do not consider it lawful
• To require us not to send you marketing communications
• To withdraw your consent, where we are relying on it to process your personal data
• To object to how we process your personal data, in particular where we are relying on our legitimate interests
• To ask us to erase the personal data we hold about you, for example because it is causing you distress or you believe it to be no longer relevant, or to correct the information if it is incorrect.

If you would like to exercise any of your rights as stated above, you can do so by emailing us at the email address below.

You can find out more about your rights at www.ico.org.uk.

Our contact details

We welcome your feedback and questions. If you wish to contact us, please send an email to admin@triangleparaplanning.com.

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you access this website.

Now that the UK has left the EU

The EU-UK Trade and Cooperation Agreement contains a bridging mechanism that allows the continued free flow of personal data from the EU/EEA to the UK after the transition period until adequacy decisions come into effect, for up to 6 months. EU adequacy decisions for the UK would allow for the ongoing free flow of data from the EEA to the UK.

Use of cookies

We may monitor your use of this website through the use of cookies and similar tracking devices, and this is confirmed in our 'cookie policy' below. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section  below.

Cookie Policy

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies and other online tracking devices such as web beacons, action tags, Local Shared Objects, single-pixel gifs on this website to:

• recognise you whenever you visit this website (this speeds up your access to the site as you do not have to log on each time)
• obtain information about your preferences, online movements and use of the internet
• carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor/customer requirements and interests

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you - but only where you voluntarily provide it (eg by completing an online form) or where you purchase goods or services from us.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (eg to enable you to put items in your shopping basket and use our check-out process).

If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this Privacy Policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies disable cookies completely.

Description of cookies

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How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org

 Last Updated January 2023