We take the privacy and security of your personal information very seriously. We are committed to protecting and respecting your privacy. We ask that you read this notice carefully as it contains important information.
Under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), we are required to give you certain information about the way your personal information is used. This notice (“Privacy Notice”) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Under data protection law, we can only use your personal information if we have a proper reason for doing so. A proper reason could be when:
- we have your consent
- it is necessary to enter into or perform a contract
- it is necessary to comply with a legal obligation
- it is in our legitimate interests
Who we are
When we mention “IMS”, “IMS Wealth”, “Independent Money Solutions”, “we”, “us” or “our” we are referring to IMS Wealth Ltd. IMS Wealth Ltd collects, uses, processes your personal information and interacts with you.
IMS Wealth Ltd is a company registered in England and Wales (company number 09361964) whose registered office is at 11 Whinfield, Martlesham Heath, Ipswich, IP5 3TR. IMS Wealth Ltd is authorised and regulated by the Financial Conduct Authority, our Financial Services Register number is 668701.
We provide Independent Financial Planning and Advice along with Wealth Management services.
Information we may collect and use
To provide our service to you we may collect the following personal data when you provide it to us:
- Your contact information including phone numbers, addresses and email address.
- Your identity information including passport and other official identity document details.
- Your personal financial information covering a range of your assets and liabilities, income and expenditure.
- Your employment status and, if self-employed or a business owner, information about your business activities.
- Your lifestyle information including hobbies and holidays.
- Your health information including confidential medical details, smoker status and details of any medication you take.
- Details of any vulnerability including loss of capacity to make decisions.
- Details of your dependents and/or beneficiaries under a financial policy. If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.
- Product details including pension plans, investments and insurance contracts.
- Details of your attitudes towards investment risk and future financial goals.
Information we receive from other sources
We may also receive personal information about you from another party. This information could be used as part of the service we provide to you, or as part of our regulatory or legal obligations.
Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
We may receive personal information from third parties that we work with including:
- Companies that introduce you to us
- Product Providers
- Credit reference agencies
- Public information sources such as Companies House
- Agents working on our behalf
- Market researchers
- Government and law enforcement agencies
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.
Any data collection that is optional would be made clear at the point of collection.
How long we keep your personal information
We will keep your personal information for as long as you are a client of IMS Wealth Ltd.
After you stop being a client personal data shall be held for no longer than is necessary, in most cases data is held in accordance with the requirements of the Financial Conduct Authority to maintain a suitable audit trail for the safeguarding of the client’s best interest, such as:
- To respond to any questions or complaints
- To show that we treated you fairly
- To maintain records according to rules that apply to us
- To comply with relevant FCA record keeping requirements
- For any financial products we have arranged, we are required to retain data relating to these indefinitely.
We may keep your data indefinitely if we cannot delete it for legal or regulatory reasons or where any advice has been given or a regulated contract sold. If we do keep it indefinitely, we will make sure that your privacy is protected and only use it for those purposes.
If after making an initial enquiry for our services and no further information is obtained we will hold your data for no longer than 1 year after our last contact, this will be extended to 6 years from last contact if we have gathered further personal information but no advice was provided.
Safeguarding your personal information
Keeping your personal information safe is very important to us so we will take all steps necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection legislation.
Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access.
Using your information
Your personal information will be used for the purposes of providing financial planning advice and the administration and management of financial products.
We have set out our reasons for using your personal information in the table below, we have also included Third Parties who we routinely share your information with.
| Purpose | Legal basis | Third Parties |
| To provide Independent Financial Planning and Advice along with Wealth Management services. | To fulfil our contractual obligations | Product providers and fund
managers, research software providers, outsourced paraplanners |
| To refer you to third party professional advisers to provide you with advice in relation to legal or tax planning issues. | Your Consent | Specialist Advisers, Accountants and Solicitors |
| To retain records of service or advice provided to you. | Legitimate Interests | Data Storage Suppliers, Compliance Consultants and PI Insurance Broker |
| To provide you with information about products and services of a similar nature to those you have previously purchased or expressed an interest in which are offered by Third Parties in line with your preferences. | Your Consent | Email marketing provider |
We may also share your personal information with third parties if the make-up of the IMS Wealth Ltd changes in the future, such as:
- if we sell or buy any business or assets
- if we or substantially all of our assets are bought by a third party
- if there are ownership changes to our firm
Access to your information
You have the right to request a copy of the personal information we hold about you, subject to certain exemptions.
If you would like a copy of some, or all, of this information you may contact us using the details below
We will NOT charge a fee for providing you with this information, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
Data transfers out of the EEA
Our aim is that we will not transfer or store your personal information outside the European Economic Area (‘EEA’). Some third-party product and service providers that we use may transfer information outside of the EEA, you should read their data privacy statement, please ask us for further information.
If we do transfer or store information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA by using one of the following safeguards:
- Transfer it to a non-EEA country with privacy laws that have been approved as providing the same protection as countries in the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
You can find out more about data protection on the European Commission Justice website.
Marketing
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure the performance of our email campaigns.
Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services.
Calls to 01473 636100
When you call the IMS Wealth Ltd main client telephone number, 01473 636100, we may collect the Calling Line Identification information and retain a copy of the telephone call for our training and security processes, we will also use the information to help improve our efficiency and effectiveness.
Telephone calls maybe recorded and maintained securely within the UK and are only accessible by authorised IMS Wealth Ltd staff members.
Individual rights under the GDPR
The GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Letting us know if your personal information is incorrect
If any of the information we hold about you is inaccurate or incomplete, you can ask us to make any necessary amendments to your data.
Please contact us if you want to do this using the details below. If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right in certain circumstances to object to our use of your personal information, or to ask us to delete your personal information or ask us to suspend our use of your personal information.
There may be legal or other official reasons why we need to keep or use your personal information. But please tell us if you think that we should not be using it and we will consider this.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us using the details below.
What if I want to move my personal information to a different provider?
You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.
This right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic means).
How to withdraw your consent
You can withdraw any consent you have given us at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
Cookies
We use cookies to track visitor use of the website and to compile statistical reports on website activity. You can read more here https://imswealth.co.uk/cookie-policy
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
Changes to our privacy notice
We reserve the right to revise or supplement this Privacy Notice from time to time. We will place updates on our website, this notice was last updated on 23 May 2018.
What if I have a complaint?
You have the right to complaint to the Information Commissioner’s Office where you think we have not used your personal information in accordance with data protection law. Details of how to do this can be found on www.ico.org.uk
You can write to the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Contact us
If you have any queries regarding privacy issues, you can email us at martin@imswealth.co.uk or write to us at:
Data Controller
IMS Wealth Ltd
11 Whinfield
Martlesham Heath
Ipswich
IP5 3TR
Alternatively, you can call us on 01473 636100.