Privacy Policy

KMG Independent Limited has issued this privacy notice to you to explain how we use any personal information we collect about you.


What information do we collect about you?
We collect information about you when you engage us for any kind of financial planning advice.This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies.These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We may use your information collected from the website to personalise your repeat visits to the site.


Information about connected individuals
We may need to gather personal information about your close family members, dependants etc in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.


Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we will obtain your explicit consent in order to collect and process this information.


How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.


Who might we share your information with?
We will not share your information for marketing purposes with companies outside our group of companies (KMG Investment Management Limited is within our group of companies).
To deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit which will include but is not limited to password protection and/or encryption of data etc.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.


How long do we keep hold of your information?
In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we will not retain your personal data for longer than 5 years past the time of your death.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.


How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.


Marketing
We like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have 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.


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.


What can you do if you are unhappy with how your personal data is processed?
We may be required to report to the relevant supervisory authority within 72 hours upon discovering a data breach. This will be assessed on a case by case basis. For example, if personal details are lost or stolen which could present a risk of identity fraud for our clients. If a breach is likely to result in risk to an individual’s rights and freedoms, we will notify you directly detailing the nature of the breach, the categories and approximate number of individuals concerned, and the same for personal data records concerned.
We will give you a description of the likely consequences of the breach, and a description of any measures taken to deal with the breach, and any taken to mitigate the effects of the breach.
You also have a right to lodge a complaint with the supervisory authority for data protection.
In the UK this is:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
0303 123 1113 (local rate)


Changes to our privacy policy
We keep our privacy policy under regular review and we will inform you of any changes when they occur. This privacy policy was last updated on 11th January 2021.


How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:

By email at:
[email protected]

Or write to us at:
Compliance Officer
KMG IndependentLimited
Rough Beech Court
DowlandsLane
Smallfield
Surrey
RH6 9SD