Last updated: January.2019
Thornton Associates Ltd. are Chartered Financial Planners, trading as Thornton Chartered Financial Planners. We are registered in the Isle of Man and licensed by the Isle of Man Financial Services Authority.
We are committed to safeguarding the privacy of visitors to our website. Please read the following notice to understand how we will collect and use your information and the rights you have in relation to your information. References in this notice to “your information” are also to personal information that you provide to us. This notice was last updated on the above date and may vary from time to time so please check it regularly. Any significant changes to this notice will be clearly indicated on our home page. Thornton Associates Ltd is the data controller of any information provided via our website and our contact details are set out below. We are registered with the Information Commissioner in the Isle of Man.
- The information we collect
Working in the financial services sector, data handling and confidentiality in respect of any information we collect is always of utmost importance.
You are not required to provide any personal information on the public areas of this website, however, you may choose to do so by completing any relevant sections.
We also obtain personal information from your IP address, operating system and web browser that you use to access our website. Please see section 5 (Cookies) and section 6 (IP Addresses) below for more details about this. You may also provide us with personal information if you contact us by email, telephone or letter.
We will try to keep all personal data collected and processed, accurate and up to date and will check the accuracy at regular intervals. Where necessary, steps will be taken to amend, or delete data as appropriate.
- How we use your information
We will only use the information you provide to us in order to: –
- conduct administrative or operational processes within our business;
- process and respond to requests, enquiries or complaints received;
- to provide products and services requested by you;
- to identify products and services you may be interested in;
- to communicate with you about our products and services;
- to invite you to events;
- monitor and analyse our business;
- form a view of you as an individual and to identify, develop or improve our services and/or products that may be of interest to you and to carry out market research;
- send you marketing information.
For more details about how we use your information for marketing purposes please see section 3 below (Using your information for Marketing Purposes).
- Using your information for Marketing Purposes
Thornton does not actively engage in marketing.
If we decided to do this, this would be presented to you as an option on the relevant application form or page on our website. We would not send you marketing if you ask us not to. If you have agreed to receive marketing, but then later change your mind and no longer wish to receive marketing, please let us know so we can remove you from our distribution lists. You can contact us on firstname.lastname@example.org.
- How long do we keep hold of your information
Although personal data shouldn’t be held for longer than is required under the terms of our contract for services with you, we’re 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. We’ll not retain your personal data for longer than 6 years past the cessation of our relationship or the time of your death, unless this relates to pension transfers, pension opt outs or free standing additional voluntary contributions where records will be held indefinitely or for long term insurance or pure protection contracts when records need to be retained for the period of the contract.
- How and why we share your information
Please note that we may on occasion be required to share your information with third parties who provide services on our behalf or with companies whose systems we use to provide services that you have requested. However, we have taken steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of. In relation to any other third parties, we will only disclose your information with companies whose systems we use to provide services where you have given your consent, or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.
In order to deliver services, we may use are tools supplied by 3rd parties for profiling customers and 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.
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.
Please note that you may request that data is not held, you may opt out or withdraw or refuse consent without detriment.
- IP addresses
When you visit our website, our server will record your IP address together with the date, time and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. It enables us to identify which organisations have visited this website. We use this information to compile statistical data on the use of our website to track how users navigate through our site in order to enable us to evaluate and improve our site.
We use up-to-date data storage and security techniques to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your information. However, the transmission of information via the internet is not completely secure. Although we will do our best to try and protect your information, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
- Your rights
You have the right under the Isle of Man Data Protection law to apply for a copy of the information we hold about you. This is called a data subject access request and you can make a request by writing to us using the contact details below. We may require further information from you in order to verify your identity before disclosing any personal information to you. You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details below if you would like any corrections made to your information.
- Contact information
If you have any questions in relation to this notice please contact: The Data Protection Officer, Thornton Chartered Financial Planners, 39 Athol Street, Douglas, Isle of Man, IM1 1LA.
Telephone: 01624 660220 Email: email@example.com
All email messages sent to and from Thornton Associates Ltd may be monitored to ensure compliance with internal policies and to protect our business.
If you are unhappy with how your personal data is processed, you have a right to lodge a complaint with the supervisory authority for data protection in the Isle of Man: Isle of Man Information Commissioner, PO Box 69, Douglas, IOM, IM88 1EQ
Thornton Chartered Financial Planners is the registered business name of Thornton Associates Ltd. Registered in the Isle of Man, number 101131C.Registered Office: The Elms, Westmead, Glen Darragh Road, Glen Vine, Isle of Man IM4 4BB. Licensed by the Isle of Man Financial Services Authority.
ACCEPTANCE OF LEGAL AND PRIVACY NOTICE TERMS
Without prejudice to the above, we will use your information for administration, marketing, market research, customer services, crime (including tax evasion) prevention and detection, anti-money laundering and counter financing of terrorism, due diligence, establishment of beneficial ownership, verification of identity, underwriting and statistical analysis. We may disclose your information to providers of financial services and products and similar third parties for these purposes and should we do this, we will provide you with details of the name the provider. We may keep your information for a reasonable period to contact you about our services.
Some services are provided to us by third parties such as processing business or obtaining compliance or regulatory advice, which warrant the disclosure of more than just your basic contact details. You agree that personal information held by ourselves may be stored, managed, maintained and used and if necessary disclosed on a confidential basis to any such third parties. This will be in accordance with Isle of Man Data Protection law.
You also agree that this information may be transferred electronically, e.g. via email and you agree that we, or any such third party, may contact you in future by any means of communication which we consider appropriate at the time.
To help us prevent fraud, to check your identity and to prevent money laundering and terrorist financing, we may search the files of credit reference, due diligence and similar agencies who may record any searches on your file.
No person other than a party to these terms, their successors and permitted transferees or assigns, shall have any right to enforce any of its terms unless we expressly agree in writing to such third party rights.
We reserve the right to vary, amend or add to any of these terms and will give at least 30 days’ notice to you (either by email or in writing) of any variation.