What We Collect | Information you give us
If you express interest in us and our services, we may ask you for basic contact information such as your name, email address, telephone number, postal address.
When you apply for an account with us we will ask you for information that shall include: your name; contact information including email address, mobile phone number, and address; National Insurance Number; bank account details; information about your financial situation; and copies of personal identification documents (such as your passport or driving licence) and photographs of your likeness.
If you use Intelligent Siloing you will also provide your online banking login credentials (such as username and password) so that your bank account statement can be viewed on a read only basis to calculate additional amounts that you could afford to save. Using Intelligent Siloing is optional.
Before you submit any information, we will notify you as to why we are asking for it and it is up to you whether or not you provide it. The majority of the information is necessary to us being able to provide our services and/or fulfil our legal obligations and we won’t be able to open or maintain an account for you if you choose not to provide it.
What We Collect | Information we collect about you
We collect information from you about the computers, phones or other devices you use where you install or access our site or app. We may use this information to help us provide consistent experience across your devices. Here are some examples of the information that we collect:
- Device attributes such as the operating system, hardware version and geographic location based on your internet service provider
- Connection information such as the name of your mobile operator or internet service provider, browser type, language and time zone
- Behaviour such as viewing a specific page, opening a statement or downloading a document.
When you telephone us, calls are recorded and your phone number will be searchable within our call recording system.
Correspondence with you will be stored in our prospect/customer database.
Uses made of the information | We use information we collect about you in the following ways
We must have a good reason, known as a “lawful basis” to use your information. Below explains more about the type of information we collect, how we use it and why, and the lawful basis for doing so.
Information that includes your name, where you live and how we contact you. We use it to manage our relationship with you and to identify you. Our legal basis for doing so is consent, a contract with you, our legal duty or our legitimate interests.
Information that includes the balance of your Silo Account and your financial situation (income, cash savings, bank statement information where you have connected your bank account to the app). We use it to provide you with accurate information about your Silo Account; to assess the suitability of investments we may recommend or buy/sell on your behalf; to calculated Intelligent Silos where you have switched this functionality on in the app. Our legal basis for doing so is a contract with you or our legal duty.
Attitude to investment risk
Information that includes your answers to questions about how you are likely to react in relation to your investments under different circumstances. We use it to automatically determine which of our investment strategies is suitable for you. Our legal basis for doing so is a contract with you.
Information that includes your age. We use it to ensure you are eligible to use our services. To take your age into account when automatically determining which of our investment strategies is suitable for you. Our legal basis for doing so is a contract with you or our legal duty.
Information that includes details about payments to and from your Silo Account and trading within it. We use it to provide you with accurate information about your Silo Account; to manage fraud and other financial crime risks. Our legal basis for doing so is a contract with you or our legal duty.
Information that includes details about the products and services we provide to you. We use it to ensure we know what products (general investment account or ISA) you have signed up for and that we deliver the service to you. Our legal basis for doing so is a contract with you.
Information that includes data about where you are located which may come from your IP address and/or mobile phone when you browse our Site or App. We use it to understand regional differences in the way clients interact with our service, which may help us develop new services or regional client events. Our legal basis for doing so is our legitimate interests.
Information that includes your family and dependents. We use it to be able to take into consideration your family situation when automatically determining which of our investment strategies is suitable for you. Our legal basis for doing so is a contract with you.
Information within letters, emails, and telephone conversations we have with you. We use it to manage our relationship with you. Our legal basis for doing so is our legitimate interests.
Information that includes how you use our products and services, sites and App. We use it to deliver our service, personalise content and make suggestions and to understand how you use our services and interact with us and the things you are interested in. Our legal basis for doing so is our legitimate interests.
Special categories of data
Special protection is given to certain types of information which is deemed to be sensitive in nature. This can include details of your racial or ethnic origin, religious or philosophical beliefs, any trade union membership, your genetic and bio-metric data, data about your health, any criminal convictions and offences. We use it as part of our identity verification checks, we may ask you to provide biometric data in the form of a photograph of you. Where this is the case we will always ask for additional consent, this is referred to as your explicit consent. Our legal basis for doing so is your explicit consent
Information that includes details of the consent you gave us to send you marketing materials. We use it to carry out marketing campaigns. Our legal basis for doing so is your consent
Information that includes your national insurance number. We use it to identify you and provide tax efficient wrappers as part of our investment services. Our legal basis for doing so is a contract with you or our legal duty
Where the stated lawful basis for processing your data is “our legitimate interests,” this may be for the purpose of:
- Keeping in contact with you if you have expressed an interest in our services
- Marketing other services to current clients
- Prevention of fraud and financial crime
- Ensuring network and information security
- Inter-group transfers
- Monitoring our services for regulatory compliance, customer satisfaction and complaints and future business strategy
As detailed above, we use some of your information to reach an automated decision about which of our five investment strategies is suitable for you. The automated decision is based on a numerical score that attaches to certain information you have provided and the answers given to a series of questions about risk. The automated decision making process has been carefully designed to choose a suitable investment strategy. We also carry out regular reviews of the results of the automated decision-making to ensure it is working correctly. If you have queries or concerns about the investment strategy that has been selected for you, please contact email@example.com
Disclosure of your information | You agree that we have the right to share your personal information with
- Group companies
Killik & Co LLP, Killik & Co Trustees Limited, Killik Intelligent Savings Limited
- Data Processors
Carefully selected third parties necessary in providing the services, e.g. ID verification services, payment services, bank account aggregation services etc.
- Analytics Services
Services that assist with optimisation of our site or App and help us to understand how visitors use/navigate our site or App
- Business Acquirer
Prospective or actual acquirer of some or all of our business in the event that any part of our business were to be sold (information about clients and prospects will be a business asset)
To comply with legal obligations; to enforce our legal agreements; to protect our rights, property or safety and that of our clients and others. This could include exchanging information with other companies for fraud prevention purposes.
Security and where we store your personal data
We are committed to ensuring that your information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place strict procedures and security features around the App, our sites and our internal systems and databases. All information you provide to us is stored on our secure servers and payment transactions will be encrypted using SSL technology. Where you use Intelligent Siloing and provide us with your bank login details, these are stored encrypted. Where you have chosen a PIN which enables you to access our site or App, you are responsible for keeping the PIN confidential. We ask you not to share your login details with anyone.
You should remember that transmission of information via the internet is not completely secure. We may use encryption as way of protecting attachments to emails that may contain your personal information. However, we cannot guarantee the security of information that you transmit to us via our sites or by email. Any transmission is at your own risk.
If we need to share your information with others (Data Processors) in order to provide our services, we make sure that they have appropriate technical and organisational security measures in place to keep your information safe and that they have undertaken to comply with data protection law and regulations.
Typically, the data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. If for any reason we need to transfer and store your data outside the EEA, we will do so only where we have assessed that equivalent data protection measures are in place. By providing us with your personal information, you agree to this transfer, storing or processing.
How long we keep your personal data
We will retain your personal data for the duration of our contract with you and for a reasonable period of time afterwards. We are bound by financial regulation to keep our records for set periods of time and will also wish to retain enough information where we have a legitimate interest in doing so.
Links to other websites
Controlling your personal information | You may choose to restrict the collection or use of your personal information in the following ways
If you have previously agreed to us using your personal information for our own marketing purposes, you may change your mind and withdraw this consent at any time
You may request details of the personal information which we hold about you. We must provide this to you free of charge within 30 calendar days of your request
If you believe that any information we are holding about you is incorrect or incomplete, please tell us as soon as possible. We will promptly correct any information found to be incorrect
- Objection, Restriction or Deletion
You may have the right to object to the way in which we process your data, you may ask us to restrict the processing of your data, or you may ask us to delete it.
Please direct all enquiries concerning your control over your personal information to firstname.lastname@example.org
The supervisory authority for data protection in the UK is the Information Commissioners Office. You have the right to complain to them about the way in which we process your data and their helpline number is 0303 123 1113
See also Appendix 1 for details on how you can manage the way that Cookies use and store information about you.
We may change this policy from time to time by updating this page. You should check this page periodically for any changes.
Conflicts of Interest Policy
If you wish to read our conflicts of interest policy, you can find it here
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