Hanover Wealth Management
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Privacy and Cookies Policy

1 Introduction

We understand that we have a responsibility to protect and respect your privacy and look after your personal data.

This Privacy Notice, inclusive of our Terms and Conditions, explains what personal data we collect, how we use your personal data, reasons we may need to disclose your personal data to others and how we store your personal data securely.

For clarity, we may be both data controller and data processor for your personal data under certain circumstances.

We must advise that this policy is subject to change, so please check our website on a regular basis for any further changes.

2 Data Protection Law

The law changed on 25 May 2018.  This Privacy Policy sets out your rights under the new laws.

3 Who are we?

We are a provider of products and services.  We have a registered office, the address for which can be found on our contact page.

4 How the Law Protects You

Data protection laws state that we are only able to process personal data if we have valid reasons to do so.  The basis for processing your personal data includes, but is not limited to, your consent, performance of a contract, to enable billing and remittance, and to contact you for customer service purposes.

5 How We Collect Personal Data from You

We receive information about you from you when you use our website, complete forms on our website, if you contact us by phone, email, live-chat or otherwise in respect of any of our products and services or during the purchasing of any such product.  Additionally, we also collect information from you when you sign up, enter a competition, promotion or survey or when you inform us of any other matter.

If you provide us with personal data about a third party, you warrant that you have obtained the express consent from the third party for the disclosure and use of their personal data.

Your personal data may be automatically collected when you use our services, including but not limited to, your IP address, device-specific information, server logs, device event information, location information and unique application numbers.

6 Types of Data We Collect from You

The personal data that we may collect from you includes your name, address, email address, phone numbers, payment information and IP addresses.  We may also keep details of your visits to our site including, but not limited to traffic data, location data, weblogs and other communication data.  We also retain records of your queries and correspondence, in the event you contact us.

Please be aware that any video, image, or other content posted, uploaded or otherwise made available by you onto your website, whether published content or not, is not subject to our Privacy Policy.

We merely process such data on your behalf, subject to our Terms and Conditions and you are responsible for any applicable legal requirements in respect of your content.

7 How We Use Your Data

We use information about you in the following ways:

  • To process orders that you have submitted to us;
  • To provide you with products and services;
  • To comply with our contractual obligations we have with you;
  • To help us identify you and any accounts you hold with us;
  • To enable us to review, develop and improve the website and services;
  • To provide customer care, including responding to your requests if you contact us with a query;
  • To administer accounts, process payments and keep track of billing and payments;
  • To detect fraud and to make sure what you have told us is correct;
  • To carry out marketing and statistical analysis;
  • To review job applications;
  • To notify you about changes to our website and services;
  • To provide you with information about products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; and
  • To inform you of service and price changes.

8 Retention Periods

We will keep your personal data for the duration of the period you are a customer.  We shall retain your data only for as long as necessary in accordance with applicable laws.

On the closure of your account, we may keep your data for up to 7 years after you have cancelled your services with us.  We may not be able to delete your data before this time due to our legal and/or accountancy obligations.  We may also keep it for research or statistical purposes.  We assure you that your personal data shall only be used for these purposes stated herein.

9 Who Can Access Your Personal Data

Here is a list of all the ways that we may use your personal data and how we share the information with third parties.

9.1 Delivery of Products and Services

We process your data for administration, billing, support and the provision of services.  Your data may be sent to payment processors and logistics companies who may be outside of the EEA.

9.2 Third Parties

For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing or advertising purposes.

We work closely with a number of third parties (including business parties, service providers and fraud protection services) and we may receive information from them about you.  These third parties may collect information about you including, but not limited to, your IP address, device-specific information, server logs, device event information, location information, and unique application numbers.  We use their features within our website, however, in some instances, they may be acting as data controller and they will have their own privacy policies, which we advise you to read.

We may pass your personal data to third parties for the provision of services on our behalf (for example processing your payment).  However, we will only ever share information about you that is necessary to provide the service and we have specific contracts in place, which ensure your personal data is secure and will not be used for any marketing purposes.

We may share your information if we are acquired by a third party and therefore your data will be deemed an asset of the business.  In these circumstances, we may disclose your personal data to the prospective buyer of our business, subject to both parties entering into appropriate confidentiality undertakings.  Similarly, we may share your personal data if we are under a duty to disclose data in order to comply with any legal obligation or to protect the rights, property, or safety of the business, our customers, or others.  This includes but is not limited to exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and dispute policies.  However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

10 Your Rights

In preventing the use or processing of your personal data, it may delay or prevent us from fulfilling our contractual obligations to you.  It may also mean that we shall be unable to provide our services or process the cancellation of your service.

You have the right to object to our use of your personal data, or ask us to delete, remove or stop using it if there is no need for us to keep it.  This is known as your right to be forgotten.  There are legal and accountancy reasons why we will need to keep your data, but please do inform us if you think we are retaining or using your personal data incorrectly.

Our Privacy Policy shall be made clear to you at the point of collection of your personal data.

You have the right to ask us not to process your personal data for marketing purposes.  If you choose not to receive marketing communications from us about our products and services, you will have the choice not to choose these by ticking the relevant boxes situated on the pages at point of contact with us.

We will not contact you for marketing purposes unless you have given us your prior consent.  You can change your marketing preferences at any time by clicking the unsubscribe link at the bottom of each email.

11 Accessing and Updating Your Data

You must maintain the accuracy of your information and ensure all your details, including but not limited to, name, address, title, phone number, e-mail address and payment details are always kept up to date.  You must do this by logging in to your My Account area.

You have the right to access the information we hold about you.  Please log your requests via our contact page so we can obtain this information for you.

12 Use of Cookies

The law on cookies demands that you, as a website user, are given the opportunity to understand how cookies are used on our websites and consent to cookies being stored on your computer (laptop/mobile/tablet).

12.1 What are cookies?

A cookie is a small text file, typically of letters and numbers, downloaded to your computer when you access websites. Typically, they contain the following information: a site name and unique user ID, the duration of the cookie's abilities and effects, and a random number. As a rule, cookies cannot be used to reveal your identity or personally identifying information.

When you visit a website that uses cookies for the first time, a cookie is downloaded onto your computer. The next time you visit that website, your computer checks to see if it has a cookie that is relevant and sends the information contained in that cookie back to the website. The website then notes that you have been there before, and in some cases, tailors what pops up on screen to take account of that fact. They also might record how long you spend on each page on a site, what links you click, even your preferences for page layouts and colour schemes.

Generally, the role of cookies is beneficial, making your interaction with frequently-visited sites smoother with no extra effort on your part. Without cookies, online shopping would be much harder. Without cookies, some websites will become less interactive with the cookie option turned off.

12.2 Session Cookies

These cookies expire when you close your web browser (Internet Explorer, Edge, Firefox, Safari, Google Chrome).  These cookies are used for various reasons, for example, remembering what you have put in your shopping basket as you browse a website.  They can also be used for security to access your Internet banking or email.

12.3 Persistent Cookies

These cookies are still stored on your computer after you have closed your web browser which allows your preferences on websites to be remembered. These cookies are used for a variety of purposes, for example, remembering your preferences on a website (your language choice or your user name on a particular website).

12.4 First and Third-party Cookies

This refers to the website placing the cookie. First party cookies are cookies set by the website you are visiting. Third party cookies are set by another website; the website you are visiting may have advertising on the page and this other website will be able to set a cookie on your computer. Third party cookies on the main web browsers allow third party cookies by default. Changing the settings on your browsers can prevent this.

12.5 Exceptions

There are some exemptions to the above where it is essential for a website to store information on your computer, for example, to provide a service to you that you have requested.

12.6 Our Use of Cookies

  • We use cookies to improve your experience on our website and for functionality purposes, for example, if you choose to buy any of our products and services, you must consent to us placing a cookie on your computer;
  • We also use cookies to understand your usage of our website;
  • We have partners who have referred clients and in using cookies, we track referred sales so we can compensate our partners accordingly;
  • We also use cookies for remarketing purposes, for example, once you have been on our website and then you visit another website which has Google adverts, you will see an advert to remind you of our products and services.

Further information can be found at: ICO and All About Cookies.

13 Links to Other Sites

We may provide links to third party sites.  Since we do not control those websites, we encourage you to review the privacy policies of these third-party sites.  Any information that is supplied on these sites will not be within our control and we cannot be responsible for the privacy policies and practices of these.

14 Where We Store Your Personal Data

We follow accepted ISO standards to store and protect the personal data we collect, including the use of encryption if appropriate.

All information you provide to us is stored on our secured servers within the EEA.  From time to time, your information may be transferred to and stored in a country outside the EEA in relation to provision of the services.  The laws in these countries may not provide you with the same protection as in the EEA; however, any third party referred to above outside of the EEA has agreed to abide by European levels of data protection in respect of the transfer, processing and storage of any personal data.  By providing your data to us, you agree to this transfer and storage.  However, we will ensure that reasonable steps are taken to protect your data in accordance with this privacy notice.

As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Any sensitive data (payment details for example) are encrypted and protected.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping the password confidential.  We ask you not to share a password with anyone.

15 Liability

We agree to take reasonable measures to protect your data in accordance with applicable laws and in accordance with our Terms and Conditions.

16 Data Breaches

In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.

17 Contact Us

Please send any questions or comments you have about privacy to us via the contact form on our website.

18 Your Right to Make a Complaint

You have the right to make a complaint about how we process your personal data to the Information Commissioner:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113