Last updated: 20/11/18

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.

 

  1. 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.

 

  1. 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).

 

  1. Using your information for Marketing Purposes

    Thornton currently does not actively engage in any marketing. We would not send you marketing if you ask us not to. If you agreed to receive marketing, but then later changed 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 mail@thorntonfs.com.

  2. How long do we keep hold of your information

    Personal data should not be retained longer than the terms of our contract with you requires it. We will not retain data after six years following the cessation of our relationship with you, except where regulatory requirements state the need under certain circumstances for us to retain data indefinitely, which include some actions relating to pensions and for the duration of a life policy.

 

  1. 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.

 

  1. Cookies

We may use cookies on our website to track the use by visitors and to review activity. For further details, please visit http:/www.allaboutcookies.org/ If you wish to do so, you can set your browser not to accept cookies, but as a result, you may find that you are unable to use all of our website.

 

  1. 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.

 

  1. Security

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.

 

  1. Your rights

You have the right under the Isle of Man Data Protection Act 2002 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.

 

  1. 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: mail@thorntonfs.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.