We look after your details carefully. We adhere strictly to data protection laws. This policy describes how we collect, use and look after the information you provide us when you enquire about and use our services.

This policy may change from time to time as our processes change over time, which will be reflected in this document.

The information we collect includes:

1. Any personal details you knowingly provide us with through any means including forms and email, such as name, address, telephone number etc.

2. Your marketing preferences.

3. Your email activity.

4. Your IP address, browser type and browsing activity whilst on our website. Your IP address is a string of numbers unique to your computer that is recorded by our web server when you request any page or component on the website.

5. We also store information about you using cookies (files which are sent by us to your computer or other access device) which we can access when you visit our site in future. We do this to recognise you and your preferred settings, and it saves you from re-entering information on return visits to the site. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at the About Cookies website.

We supplement the information we collect from you with publicly available information from 3rd parties to assist with providing services to you – for example this may include additional contact information or geodemographic information.

Any personal information we collect about you will be used in accordance with the data protection laws. The details we collect will be used:

1. To process your enquiry and application and to provide future services.

2. To keep you up to date with the latest information about planning your retirement, product updates and special offers. You can opt-out at any point.

3. To personalise content on our website.

4. To administer competitions and prize draws.

5. To carry out market research.

6. For the collection of case studies about our customers.

7. To tailor our services better to your needs.

If we receive your data from a third party the categories of data that we collect may include, but are not limited to:

• Name
• Address
• Contact Details
• Marital Status
• Date of Birth

How we use your data Lawful basis.

To provide you with the services you have requested.

This is necessary for the performance of the contract to provide the services you have requested.

To manage our relationship with you.

This is in our legitimate interest of keeping you informed of our available products and services and keeping our records up to date and is necessary to comply with the legal and regulatory requirements that apply to us.

To provide you with information about our products and services via post and telephone.

This is in our legitimate interest of keeping you informed of our available products and services You may opt-out at any time.

To provide you with information about our products and services via email and SMS.

This processing is carried out with your consent by providing your email address or SMS number. You may opt-out at any time.

To provide you with a recommendation for any other products and services that may be relevant to your own personal requirements, it may be necessary for us to pass on your details to our partner companies. (only after receiving your specific approval) We may be able to further offer you products and services.

To process and service your Will and/or Lasting Power of Attorney instructions.

This is necessary for the performance of the contract to produce and provide your Will and/or Lasting Power of Attorney.

This is in our legitimate interest to ensure that the documentation remains appropriate for your needs.

Health data will be processed only with your consent. Criminal Convictions data will be processed in our legitimate interest for the prevention of financial crime. This is necessary to comply with our legal obligations.

We use cookies to monitor website usage to improve our online services for you. This is in our legitimate interests to improve our services.

To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning communications, corporate governance. This is in our legitimate interest to fulfil our legal and contractual duties efficiently.

Disclosing your information.

Here’s when we disclose information about you.

• To search the files of external data bureaus in order to verify your identity and contact information. These searches will not affect your credit record.
• To 3rd parties for the purposes of data cleansing or for marketing communications, namely direct mailings, digital display, email, social media. They will never use your personal information for their own purposes.
• When we (or any 3rd party acting on our behalf) are legally compelled to or have a duty to the public to disclose.
• To the intermediary, press partner or other introducer of your business to notify them of the outcome of your enquiry.
• When disclosure is made at your request or consent.

We may also share your personal data with other members of our Group in order to run our business in an efficient manner including for corporate governance or audit purposes.

Any personal data you provide to us during the course of an enquiry where you have not specified that you do not wish to be contacted in future will be retained and processed in order that we can keep you up to date with our services.

If you notify us that you do not wish to be contacted (either at the point of enquiry or subsequently).

Transaction Type Retention Period - Estate Planning following death of customer.

These retention periods also apply to the personal data of third parties acting on behalf of a customer, eligible complainants and beneficiaries, attorneys or related persons for estate planning purposes.

You have the right to:

• request a copy of any information that we currently hold about you and ask us to correct or delete this.
• restrict or object to processing of your information.
• the information we hold in our systems about you to be provided in a machine readable format. Where you have provided consent for us to process your data, you have the right to withdraw the consent.

If you believe that we are not processing your information correctly you should contact our Data Protection Officer.

We are committed to protecting the confidentiality and security of your information. As such any information collected via our website is encrypted and delivered to us through a secure environment and protected using robust security methods. We maintain a comprehensive information security management system which ensures industry standard technical and administrative controls are in place for the protection of customer data.

Please note that there is no guarantee that any email sent will be received, or that the contents of any such email will remain private or unaltered during Internet transmission. For this reason we will not include any of your personal information by email without your prior permission, but will usually respond to your enquiries by telephone or post. If you have any such concerns, you may prefer to telephone or write to us instead. We accept no liability for any damages you or others may suffer as a result of the alteration or loss of confidentiality of any such information.

We reserve the right to monitor the use and content of emails which are sent from and received by us for the purposes of ensuring compliance with our own email policy, and identifying and taking action against unlawful or improper use of our systems, including, but not limited to, spoofing, the transmission of computer viruses and a denial of service attack. This privacy policy only covers this website. Any other websites which may be linked to by our website are subject to their own policy, which may differ from ours.

© Copyright in the pages of this website, in the screens displaying the pages and in the information and material contained therein and their arrangement, is owned by us unless otherwise indicated.

Reproduction of the pages of this website in whole or in part without our prior written consent is strictly prohibited unless carried out for private, non-commercial viewing purposes.

Whilst we take all reasonable steps to ensure this website is always accessible we will not be held liable if, for any reason, the website is unavailable for any period. We may also have to suspend access to the website for routine or emergency updates and maintenance, but we will endeavor to keep any disruption to a minimum. In addition we cannot warrant that this website will be free of viruses or defects of any description and we will not be held responsible for any technical problems you may suffer as a result of your use of this website.

This website may contain links to websites operated by third parties. The responsibility for the operation, content and cookie policies of those websites rests solely with the organisation identified as controlling the third party website and will be governed by separate terms and conditions. Links are provided for convenience and inclusion of any link does not imply endorsement in any way of the site to which it links. We accept no responsibility or liability for the contents of any linked website.