Date of last update: August 2023
The UK General Data Protection Regulation, which applies from 25th May 2018, gives people more control over how their personal data is used. The Regulation sets out your rights as an individual regarding how your personal data is collected, used and stored, including your rights to have data corrected or removed.
We take the privacy and security of your personal information very seriously and are committed to protecting and respecting your privacy.
This notice sets out the purpose for which personal data that Holtram TLPI and any entity listed below collects from you, or that you provide to us, will be processed by us. This applies whether your personal data was obtained directly by us or provided to us from other sources. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.
References to “we” or “us” are to Holtram TLPI Ltd as appropriate. Holtram TLPI Limited company number 12775174, whose registered address is 42 Lytton Road, Barnet, EN5 5BY.
For the purposes of Intellectual Property Rights, Tax and Accounting Advice, Holtram TLPI operates as a trading style of Protero Tax Limited, an accountancy company registered in England and Wales under company number 12780422 and registered with the ICAEW whose registered address is 42 Lytton Road, Barnet, EN5 5BY. Advice to establish a SSAS pension will be provided by Protero Tax Ltd.
YOUR PERSONAL INFORMATION
You may give us personal data about yourself in various ways, for example by completing forms, using our website or corresponding with us by phone, email, in writing or otherwise.
The information you give us which we will hold and process may include (for example) your name, date of birth, address, email address and other contact information, together with financial information about you.
When you access our website we may also collect details of your visits to our websites and technical information about your device and connection (including your IP address).
When you open an email from us we may collect technical information about your device and connection and information about your interaction with that email, such as whether you open that email, choose to click a link in that email or unsubscribe.
Personal Information From Other Sources
We may receive information about you from third party service providers such as pension providers, Trustees, or Financial Advisors. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out in this Privacy Notice (depending on the types of information we receive).
Deciding Whether To Provide Us With Personal Information
Depending on the nature of our interactions with you, there may be certain essential personal information that we have to collect from you so that we can provide you with the information or services that you have requested. This will vary depending on the relationship we have with you.
We will always aim to make clear which personal data it is necessary for you to provide and which personal data is optional. However, if you are unsure as to whether you are required to provide us with any particular piece of personal data please ask us.
How We Use Personal information
We may periodically send emails or SMS about new products, learning content, reminders, or other information which we think you may find interesting using the email address or SMS contact details which you have provided.
We may use the information we hold about you in the following ways. to provide services to you under our contract with you, including:
To support your application to establish a new scheme.
To send you regular information and updates.
When you request information about investments in property and property bonds.
To notify you about updates or changes to our services.
Where you have expressly consented to us doing so, including to respond to your request for literature or information or to other enquiries you make to us.
Where it is necessary to comply with a legal obligation, including:
Complying with any legal obligations to provide you with certain information or documentation.
Carrying out checks to prevent money laundering.
Where we otherwise have a legitimate interest in doing so, including:
As part of our efforts to keep our sites safe and secure, prevent fraud and detect crime, to protect us from dishonest or malicious activity.
To conduct data analysis, testing, research and surveys to help us better understand customer requirements, service our customers better and win new customers.
To measure and understand the effectiveness of the content we serve to you and others so that we can ensure that the information we provide to you and others is relevant and therefore provide a better customer experience.
Sharing And Disclosure Of Your Personal Information
We will never sell, trade, or rent your personal information to third parties.
We will only share your data with a third party in the following circumstances:
To entities that we are required to disclose the data to in connection with the performance of our contract with you, for example your Corporate Pension Trustee or Financial Advisor.
To providers of outsourced services, such as hosting and IT support or maintenance services (to the extent necessary for the provider to provide those outsourced services to us).
To our mailing provider for the delivery of information.
To a prospective seller or buyer of any business or assets if we sell or buy any business or assets.
We may also share your data with third parties if we are under a duty to share your data in order to comply with any legal or regulatory obligation, in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purpose of fraud prevention and the detection of financial and other crime.
How We Keep Your Personal Information Secure
We will only collect and use personal information in accordance with this Privacy Notice where and to the extent permitted by applicable law. We will maintain appropriate safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided. In addition, we will take reasonable steps to ensure that third parties to whom we transfer any personal information provide sufficient protection of that information.
Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into our site will be encrypted to ensure its safety. Any sensitive data transmitted will be protected by password.
However, you should be aware that the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential.
How Long We Keep Your Personal Information For
If you are a client of TLPI, we will generally retain your data for a minimum of 6 years after the end of your contract with us and thereafter for so long as we can lawfully justify holding your data. The period for which we will hold non-client data will vary depending on the type of information and the reason why we collected it from you.
Once your data is no longer required it will be destroyed. We retain the right to hold archived data if we believe this is required to exercise or defend legal claims.
Your Rights In Respect Of Your Personal Information
You have the right to request a copy of the personal information we hold about you at any time.
Right To Rectification
If at any time you believe that the data we hold for you is inaccurate or incomplete you may ask us to correct or remove it. We will be happy to review, update or remove information as appropriate, but please be aware we may need to retain your information on our files to resolve disputes, or for technical and legal requirements. If for any reason we are not taking action to your request for rectification we will explain to you the reason why and what rights you have at that time.
If we have disclosed your personal data to a third party we will also contact them to inform them of the rectification.
Withdrawing Your Consent
Where we are processing your personal data because you have consented to us doing so, you have a right to withdraw your consent to us processing your data at any time. Please note, however, that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent.
Objecting To Processing
Where we are processing your personal data because we have a legitimate interest in doing so, you have a right to object to that processing.
You have a right to “block” or suppress the processing of personal data requiring us to restrict the processing of personal data:
Where you contest the accuracy of the personal data we hold, we will restrict the processing until we have verified the accuracy of the personal data.
Where the processing is unlawful and you oppose erasure.
If we no longer need the data but you require the data to establish, exercise or defend a legal claim.
If you have objected to our processing of your personal data.
If we have disclosed your personal data to third parties we will contact each recipient and inform them of the restriction on processing, unless this proves impossible.
We will inform you if and when we decide to lift a restriction on processing.
Right Of Erasure
This is also known as “right to be forgotten”. You have the right to request us to erase all personal data about you, such as where the data is no longer necessary for the purposes for which it was originally collected and there is no compelling reason for retaining it. We reserve the right to retain your personal data if we have a valid reason to do so, such as the exercise or defense of legal claims or to comply with a legal obligation.
Although we do not currently process any of your personal data using automated means, in the event that we commence doing so, we will inform you and you will have the right to obtain and reuse your personal data for your own purposes across different services to enable you to move, copy or transfer personal data easily in a safe and secure way. This portability only applies to personal data you have provided to us and which we process on the basis of your consent or in relation to the performance of a contract with you.
Making And Responding To Requests
Where you want to exercise any of your rights described in this Privacy Notice, you may contact us using the details provided at the end of this Privacy Notice.
We will respond to your request within 7 working days, and aim to comply with your request within one month, but this may take longer where the request is complex. If we are not able to comply we will explain why and inform you of your right to complain.
Please note that if, as a result of complying with your request, we do not have the data we need or we are unable to process it, we may be unable to supply you with the services you asked us to provide.
USING OUR WEBSITE
Our website may use “cookies” to keep track of your visit to our website and give you a better browsing experience.
Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our website.
Social Media Platforms And Applications
Our website may include functionality to enable sharing via third-party social media applications, such as Facebook and Linked-in. These social media applications may collect and use information regarding your use of our site. Any personal information that you provide via such social media applications may be collected and used by that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
Links To External Websites And Shortened Social Media Links
Our site may, from time to time, contain links to and from the websites of our partner networks or other business links. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your data. Please check these policies before you submit any personal data to these websites.
If you are not satisfied how we have handled your personal data – if it is wrong, it has been lost or we have disclosed it to someone else without your agreement, then you can complain to the Information Commissioner’s Office or by telephoning 0303 123 1113.
We reserve the right to revise or supplement this Privacy Notice from time to time. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Privacy Notice and so you are aware of what information we collect, how we use it and under what circumstances we disclose it. You can determine when this Privacy Notice was last revised by checking the “Date of last update” legend at the top of this Privacy Notice.
If you have any queries regarding privacy issues, you can email us, write to us at Holtram TLPI Ltd, Trident House, Trident Business Park, Basil Hill Road, Didcot, Oxfordshire, OX11 7HJ or call us on 01235 426666.