Information about you that we collect and use includes:
Information about who you are e.g. your name, date of birth and contact details
Children are not able to buy products and services from us. However, a parent or guardian can, and a child can also be named as a beneficiary on some funds. In these cases, we collect and use limited personal information to identify the child (such as their name, age, gender).
Where we collect and use sensitive personal information, this information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.
We may collect your personal information directly from you, from a variety of sources, including:
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
We may share your information with third parties for the reasons outlined in ‘Why we collect and use your information.
We will share your information with:
Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
The majority of your information is processed in the UK and European Economic Area (“EEA”).
However, some of your information may be processed by us or the third parties we work with outside of the EEA.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third-party suppliers and do regular checks to ensure they meet these obligations.
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
To provide you with the service agreed and meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you are a client of ours.
Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.
You have several rights in relation to how Whitehall Capital uses your information. They are:
Right to be informed
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (“DSAR”).
If your personal information is inaccurate or incomplete, you can request that it is
You can ask for your information to be deleted or removed if there is not a compelling reason for Amram to continue to have it.
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your investments to another pension provider.
You can object to Whitehall Capital processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
While we hope that we can resolve any complaints for you, you do have the option to complain to the ICO (whether or not you have exhausted our complaints procedure). The ICO’s contact details are: https://ico.org.uk