Privacy Policy

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Blue Rose Wealth Limited

Blue Rose Wealth Limited (‘We ‘, ‘Us ‘) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (‘Policy’), together with any other documents referred to therein, sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the UK General Data Protection Regulation (‘GDPR ‘) and the Data Protection Act 2018 (collectively the ‘Data Protection Laws ‘) the Data Controller is Michelle Crowley.

We are an authorised representative of Best Practice IFA Group Limited (the Network), who assist us with various aspects of our compliance activity, including FCA compliance, AML checks and data protection. In order that the Network can provide these services, we are required to send across the personal data that we have collected.

Your personal information

Information we collect from you.

We collect and process some, or all, of the following types of information from you while providing our services and other information to you. The types of information that you are required to provide will vary depending on the products that we are advising you about, but will usually include:

• Full name (including previous names)
• Postal address
• E-mail address
• Telephone number
• Date of birth
• Gender
• Bank details
• Tax identifiers
• Information about your liabilities, assets, financial and tax affairs
• Additional information required by your chosen product providers or our regulators.

There may also be a requirement to include special category personal data relating to:

• Your health &
• Biometric data

The provision of your name, address and date of birth, as well as certain other personal data that we will notify you of from time to time, is required from you to enable us to advise you and to fulfil our regulatory and legal obligations. We will inform you, at the point of collecting information from you, whether you are required to provide this information to us. If you contact us, we may keep a record of that correspondence.

Details of your visits to our website, www.bluerosewealth.co.uk, including (but not limited to) traffic data, location data, weblogs and other communication data, and the resources that you access may also be gathered.

We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them, we would greatly welcome your feedback.

Uses made of your information

We use information held about you for the following purposes:

• To provide you with our services and to carry out our obligations arising from any contracts entered between you and us, including:
• Sending you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.
• Operating, protecting and improving our services, our business, and our clients’ experience.
• Responding to any enquiries you submit to us.
• As part of our efforts to keep our services safe and secure.
• Where we have a contract with you to provide our services, and where the processing of your data is necessary to perform such contract, we rely on ‘performance of a contract with the data subject’ as the legal basis for the processing. In all other circumstances we rely on ‘legitimate interest’ and our legitimate interests are improvement of our services and/or prevention or detection of fraud.
• Where you provide us with special category data, this will be used solely with your consent to research and advise on one or more products to suit your needs and to assist you with applications for and management of such products. We will provide such special category data to the Network and third-party providers so that they can carry out the services that they provide to us.
• To comply with our legal obligations as an authorised representative of an FCA regulated entity, including preparing and sending reports and submissions to the Network and/or regulatory authorities such as the FCA. ‘Compliance with a legal obligation’ is the lawful basis on which we rely when we are carrying out regulated activities.
• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. In these circumstances we rely on ‘legitimate interest’ and the legitimate interest is the improvement of our services.
• We may use your personal data to provide statistical analysis of the use of our website via the use of cookies. In these circumstances we rely on ‘consent’ to our use of non-essential cookies.
• We also use your personal data where you have contacted us via the Website, by e-mail, telephone or participated in any surveys. In these circumstances we rely on ‘legitimate interest’ and the legitimate interest is responding to and contacting you regarding the enquiries you have made in relation to the services we offer.

Marketing

In addition to the above uses we may use your information to notify you about goods or services which may be of interest to you. If you do not want us to use your data in this way, you may either (i) tick the relevant box situated on your service charter on which we collect your data; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.

Disclosure of your information

We routinely disclose your personal data to third parties as follows:

• We pass your information to the Network, who provide us with various compliance services. The Network is a separate data controller.
• We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
• We may pass your information to your authorised representatives, such as your Solicitor or Accountant.

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• If we or substantially all our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our client agreement/service charter; or
• To protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
• In relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you

Other than as set out above and save insofar as is necessary for us to carry out our obligations arising from any contracts entered in to between you and us or with any regulatory or other legal obligation. We will not share your data with third parties unless we have procured your express consent to do so.

Storing your personal data

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; 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.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note they have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If any of your personal details change you may update them by accessing this data through the wealth platform portal, or by contacting us using the contact details below. If you have any questions about how we use data collected which relates to you, please contact us using the details provided below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data.

• We will hold personal data (e.g. name, address, date of birth and contact details) in line with our regulatory and legal obligations as set out by our regulator – currently a minimum of five (5) years for investment business and indefinitely for occupational pension transfer or opt-out business.
• If you contact us, as a prospective customer/client, using our e-mail address requesting general information about our services, we will hold the personal data you choose to provide such as your name, address, e-mail address, for twelve (12) months from our last point of contact.

Where we store your personal data

All of the information that we hold about you is stored on our secure servers within the European Economic Area (‘EEA’). The data that we collect from you may be transferred to, and stored at, a destination outside the EEA and by submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

If you would like further information, please contact us or our Compliance Director (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your rights

Under GDPR you have several important rights free of charge. In summary, these include:

• Access to your personal data and to certain other supplementary information that this policy is already designed to address.
• Us to correct any mistakes in your information which we hold.
• The erasure of personal data concerning you in certain situations.
• Receiving the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
• Objecting at any time to processing of personal data concerning you for direct marketing.
• Objecting to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
• Objecting in certain other situations to our continued processing of your personal data.
• Restricting our processing of your personal data in certain circumstances.
• Claiming compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the guidance issued by the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, please:

• E-mail, call or write to us at Blue Rose Wealth Limited or contact our Compliance Director (see the ‘Contact’ section below for details).
• Supply enough information to clearly identify yourself (e.g., account number, username, registration details, etc).
• Provide us with proof of your identity and address (a copy of your driving licence / passport and a recent utility / credit card bill).
• Let us know the information to which your request relates (including any account or reference numbers, if you have them).

How to complain

We hope that we or our Compliance Director can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, particularly in the European Union (or European Economic Area) stating where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to our privacy policy

We reserve the right to modify this Policy at any time and any changes we may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and Website shall be deemed your acceptance of the varied Privacy Policy.

Information about our use of cookies and IP addresses.

We may collect information about your mobile phone, computer or other device from which you access the Website. This includes, where available, your IP address, operating system and browser type, for systems administration and to report aggregate information to third party affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you to track your usage of our services.

Our website uses cookies to distinguish you from other users and this supports us to provide you with a better experience whilst browsing our site, allowing us to improve. By using our website, you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use include:

• ‘Analytical ‘cookies - These allow us to recognise and count the number of visitors and to see how they move around the Website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• ‘Strictly necessary ‘cookies - These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• ‘Functionality ‘cookies - These allow us to recognise you when you return to our website, personalising our content for you. We can greet you by name and remember your preferences (for example, your choice of language or region).
• ‘Targeting ‘cookies - These record your visit to our website, the pages you have visited and the links you have followed to our affiliates’ websites. We will use this information to develop our website, e-mail offers to you and make the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third party affiliates may also use cookies, over which we have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our website.

Contact

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to enquiries@bluerosewealth.co.uk or you can write to us at Blue Rose Wealth Limited, Prince of Wales House, 2nd Floor, 3 Bluecoats Avenue, Hertford, Hertfordshire SG14 1PB Alternatively, please contact our Compliance Director at Holmwood House, Broadlands Business Campus, Langhurst Wood Road, Horsham, West Sussex, RH12 4QP, telephone number 01403 334455, or via email at info@bestpractice.co.uk.