We collect data about you when you register with us or when you contact us and provide us with information voluntarily. Website usage information, including client IP address, request date/time, page requested, HTTP code, bytes served, user agent and reference are typically collected using cookies and web server logs. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services regarding which you have transacted with us.
• Dependant Data includes number of dependants and age of each dependant.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes requests for services made by you; your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Where applicable we may require personal data relating to children under 13 years of age. If you are a parent or guardian of a child under the age of 13 and think that we may have information relating to that child that you wish to be deleted, please contact us at info@schneiderfs.com We will ask you to prove your relationship to the child, but if you do so you may (subject to applicable law), request access to and deletion of, that child’s personal data.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

The information we receive is handled and processed by our staff who are located in the UK; however, we store information in the cloud and in an offsite server located in Europe. No third party will have access to your personal data unless permitted by Law, and we will take steps to give only the amount of data required.

We use different methods to collect data from and about you including through:

1.  Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Your appointed solicitor.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators; and
• Identity and Contact Data from publicly availably sources such as Companies House.

Please contact us at info@schneiderfs.com if you need details regarding how your personal data is collected.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) – and your interests and fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, other than maybe in relation to sending third party direct marketing communications to you or to responding to your queries. You have the right to withdraw consent to marketing at any time by contacting us at info@schneiderfs.com.

We have set out below, in tabular format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@schneiderfs.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We may disclose your personal data to:

• your appointed solicitor;
• other companies within our group;
• our lawyers, agents and service providers;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• we may also disclose your information for the prevention and detection of crime and to protect the interests of the Company; and
• auditors and lending institutions.

If we are required to send your data to any other third parties we will only do so with your explicit consent.

Under GDPR the rules inside of the UK and the EEA will be the same with regard to personal data and accordingly we are able to trust the built-in safeguards. If we are required to send any of your data outside the EEA, we will send you information on the reason for this, how the data will be protected and details of how to obtain copies of the relevant safeguards’

The GDPR defines special data as being more sensitive, thus it needs more protection. Due to the nature of our business we might be required to hold and process some of this data. The categories which we could potentially process include (but not limited to): race, ethnicity, politics, religion, health, sex life or sexual orientation.

Please be aware, we will not require this information unless it is pertinent to your individual circumstance and the service we will deliver to you. We will require your explicit consent to handle this data or if processing is necessary for the establishment, exercise or defence of legal claims.

We will only keep your personal information for as long as necessary, for the purpose(s) for which it was collected, to provide you with services and to conduct our legitimate business interests, or where otherwise required by Law.

To determine the appropriate retention period for personal data, we consider the nature, amount and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose(s) for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements.

We record all calls for Training and Monitoring purposes and to assist in staff training. Calls are retained for 6 years after you cease to be a customer, at which time they will be destroyed.

Currently we keep your personal information for a minimum of 6 years after which time it will be destroyed. If your personal information relates to Deeds, we will keep the information for a minimum of 12 years.

We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt out at any time.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our group of companies.

If you wish to be contacted for marketing purposes, please contact us at info@schneiderfs.com.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this Marketing).

You will receive Marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that Marketing.

We use “session” cookies which enable a visitor’s web browser to ‘remember’ which pages on our website have already been visited. We may also map and analyse website visitor usage patterns to help us develop the site and enhance a visitor’s experience.

Depending on the type of browser you are using, you may be able to configure your browser so that:

• you are prompted to accept or reject cookies on an individual basis; or
• to prevent your browser from accepting any cookies at all.

You should refer to the supplier or manufacturer of the web browser for specific details about cookie security.

We may collect and store certain ‘technical information’ about your visit to this site, such as:

• the IP address from which you access this website;
• the type of browser and operating system used to visit this site;
• the date and time of your visit(s) to this site;
• clickstream data which reveals the activities of visitors around this website; and
• the websiteaddress of the website from which you accessed this site.

For more information about the cookies we use, please see our Cookie Policy.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@schneiderfs.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. Right to be informed

We must inform you about the data processing we will be carrying out using your data in concise, transparent and easily accessible language.

2. Right of access

You can request a copy of your information which we hold. This is known as a Data Subject Access Request (“DSAR”) and is free of charge. If you would like to request a DSAR please:

• Either download the Request for Access to Personal Information form here or email, call or write to us (see ‘How can you contact us?’ below)
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility bill), and
• Let us know the information you want a copy of, including any account or reference numbers, if you have them

3. Right of rectification

If you believe we have any data which is incorrect you have the right of rectification. This is free of charge and allows us one month (two if the information is complex) to make the necessary corrections. If you would like to do this, please:

• email, call or write to us (see ‘How can you contact us?’ below)
• let us have enough information to identify you (e.g. account number, username, application details), and
• let us know the information that is incorrect and what it should be replaced with.

4. Right of erasure

You can request we remove all of the personal data we hold on you however we can only do this in specific circumstances. Please contact us to discuss how this can be done.

5. Right to restrict processing

You can request we block or supress the processing of your personal data. If this occurs we are able to store data but not process it further.

6. Right to object

You have the right to object to the processing if:

• it’s based on legitimate interests;
• it’s direct marketing; and/or
• it’s for historical, scientific and/or statistical purposes.

7. The right to lodge a complaint

If for any reason you have wish to make a complaint with regard to our handling of your personal data, you may do so at the Information Commissioners Office (ICO).

You will not have to pay a fee to request your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please contact us if you have any questions about this notice or the information we hold about you. You can contact us in the following ways:

By email: info@schneiderfs.com

By telephone: 020 3411 1033

By post: Schneider Financial Solutions, 1 King William Street, London, EC4N 7AF

We may change this notice from time to time. You should check this notice occasionally to ensure you are aware of the most recent version. This version is dated November 2019.