Privacy Notice

Personal data, or personal information, means any information about an individual from which that person can be identified (either by itself or when it is combined with other information). It does not include data where the identity has been removed (anonymous data).

Types of personal data we collect

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:-

• “Identity Data”, which may comprise information about you such as your first name, last name, marital status, age, date of birth, work location, job title, national insurance number, and gender. We may also require Relationship information relating to other parties directly associated with you (e.g. dependents, beneficiaries, trustees, etc)
• “Financial Data”, which may comprise your bank account and billing details. This may also include your salary information or additional information about your financial wealth management or employee benefit requirements where we are setting up Employee Benefit services for you, or for your employer on your behalf.
• “Contact Data”, which may comprise your address, email address and telephone number.
• “Transaction Data”, which may comprise details about payments to and from you and other details of products and services you have purchased from us.
• “Technical Data”, which may comprise your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device used to access our website.
• “Usage Data”, which may comprise information about how you use our website, when you contact us including through social media
• “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third parties and your communication preferences.
• “Recordings”, which may comprise of information we need to be able to provide you with help and support or may have been given during the course of our relationship in providing services through recorded lines or transcribed note taking

Special category data

We may need to collect certain sensitive information, or “Special Category Data” about you, and this may include details such as religious or philosophical beliefs, trade union membership, health and genetic or biometric data. We will always be clear in explaining when we are asking you to give us this information, why we need this information, and the purposes for which we will use it. We may process Special Category Data, where this is necessary for the provision of our services such as adapting communication methods, provide additional support or to comply with our legal and regulatory obligations. Where you disclose information relating to health, disability, bereavement or other circumstances that may indicate vulnerability, we may process this information where necessary to provide appropriate support, meet regulatory expectations and ensure good customer outcomes. Where we process Special Category Data, we will identify both a lawful basis under Article 6 UK GDPR and a separate condition under Article 9 UK GDPR. Depending on the circumstances, these conditions may include substantial public interest, the establishment, exercise or defence of legal claims, employment, social security and social protection law obligations, or, in limited circumstances, your explicit consent.

Dependent upon the nature of your contact with Mattioli Woods, we may process different types of information about you and collect this information in different ways. We will only process your data where it is lawful to do so and we will only collect the minimum amount of information necessary to meet the purpose for which we intend to use that information, for example in order to provide you with the services we have been engaged for.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Directly from you

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone and email or otherwise. Your employer may also give us your Identity, Contact and Financial Data where they are engaging our services on your behalf. For example, this includes personal data you provide when you (or, where appropriate, your employer on your behalf):

• When you fill in forms and applications, when you apply for any products or services and by the way you use financial products associated with us and
• request marketing to be sent to you, including when you enter a competition or survey or provide a business card for contact;
• interactions or queries with us by post, email, telephone, in person, via our websites, secure portals, social media or by any other means
• by visiting our premises, where our premises may operate CCTV systems for the purpose of prevention and detection of crime and protection of assets

Other sources may include:

• Other Mattioli Woods group companies
• Third parties or third parties acting on your behalf (e.g. third parties setting up a trust of which you may be a related party)
• Credit reference agencies, identification, verification and screening tools and service providers which receive information from other parties including publicly available sources (i.e Companies House)
• Our existing clients, connections, affiliates or introducers who refer us to you or you to us

We will only use your personal data where we have a lawful basis to do so under UK data protection legislation. The lawful basis we rely upon will depend on the nature of the processing activity and may include:

Performance of a contract: where processing is necessary to provide our services to you, administer your products, manage your relationship with us or take steps before entering into an agreement with you.

Legal obligation: where we are required to process your information to comply with regulatory, legal or statutory requirements, including obligations imposed by the Financial Conduct Authority, anti-money laundering legislation and other applicable regulations. This also includes in connection with legal claims (including disclosure of personal information in connection with legal process or litigation).

Legitimate interests: where processing is necessary for our legitimate business interests, such as managing our business, or where it is  the legitimate interest of another Mattioli Woods company, maintaining network security, improving our services and protecting our clients and business, provided these interests are not overridden by your rights and freedoms. When we process personal information where it is necessary for our legitimate interests or those of a third party, we ensure your interests and fundamental rights are not overridden by our legitimate interests. These include for monitoring and training purposes, telephone, video recording and transcribing to support our services offered to you. We may also seek to improve how we interact with you through our websites or communications mediums or where we invite you to marketing opportunities as well as where we are able to identify and develop potential prospective client relationships. You have the right to object to processing where it is in our or a third party’s legitimate interests at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Consent: where we require your permission to process information, such as certain marketing activities, or in limited cases processing of special category data where no other lawful condition applies. With your consent, where such consent is required under the applicable regulations and data protection laws, to send you information about products and services of ours and other companies in our group which may be of interest to you. You may withdraw your consent or otherwise opt out of receiving this information at any point. You can contact us using the details below; or opt to unsubscribe from marketing communications by using the method contained in any marketing message. Where we have appropriate marketing permissions, we will send you relevant marketing information (including details of other products or services provided by us, other Mattioli Woods Group companies or other selected third parties which we believe may be of interest to you), by mail, phone, email, text, our digital services and other forms of electronic communication. We will not share your information with non- group third parties for their own marketing purposes.

You have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing that we had carried out before your withdrawal. If you choose to withdraw your consent, we may not be able to provide or offer you with certain products and services.

We have set out in the Annex to this Privacy Notice, a description of all the ways we intend to use any personal data, and which of the legal bases we intend to rely on in order to do so. You can obtain further information about how we assess our legitimate interests against any potential impact on you in relation to specific activities by contacting us.

Your personal information may be shared at times within the Mattioli Woods Group and this may be for example, to provide you with the varying products and services that we offer.

Your data from time to time may also be shared amongst third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will ensure that your information is not subsequently shared further by these third parties without our agreement. We shall not share your personal data with any third parties for marketing purposes without your express consent.

We shall however, share your personal data with third parties, for the following reasons: –

• To meet any agreed contractual arrangements we have with you, or your employer on your behalf, we may share your information with other service providers that we use to perform that contractual service. Examples of service providers include hosting services, suppliers and sub-contractors. We may also need to share your personal data with third party software or IT support providers for the purpose of system administration, data security, data storage, back up, disaster recovery and IT support.
• We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
• We may share your personal data with carefully selected third parties to help us deliver and improve our services to you. We collaborate with specialised companies to enhance your experience and the quality of our services. We also utilise various software solutions and technologies to streamline our operations and improve service delivery. Your data may be processed by these providers to facilitate features.
• We reserve the right to disclose or share your personal data in order to comply with any legal or regulatory requirements, enforce our terms and conditions (or any agreement we enter into with you), or to protect the rights, property, or safety of our business and other website users. We may also share your personal data with our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• We may share your personal information when your employer contacts us regarding our Employee Benefits services. As part of an exchange of information between your employer and ourselves prior to any agreement taking place, we may need to obtain some information about you, and this may include certain Identity Data and Financial Data, in order to respond to this enquiry. This may include, for example, your age, salary information and work location. However, where possible, we will always request that any information we receive about you from your employer is anonymised and will only collect the minimum amount of information about you which is necessary to respond fully to any such enquiry.

Technology solutions – Automated decision making

• When you have a meeting with a financial advisor

Where we use technology solutions, including artificial intelligence tools, to assist with meeting bookings, recording, transcription or summarisation, this processing is undertaken to improve record keeping, support adviser supervision, enhance service quality and meet regulatory requirements. Any information generated through these tools will be reviewed with ‘human in the loop’ where appropriate and will not replace professional judgement or decision making. You will be informed where these technologies are used and, where appropriate, you may request that meetings are not recorded or transcribed.

• Third party marketing services

Where we use technology solutions which may include artificial intelligence tools to assist with supporting and tailoring our marketing communications to you. Any information processed includes ‘human in the loop’ with no sole automated decisions. You have the right to ‘opt out’ where these technology solutions are used at any point. This does not affect your marketing preferences. You may opt out from receiving marketing information by using the ‘unsubscribe’ link that is contained in all electronic marketing messages. You may choose which topics you wish to receive communications regarding and for which businesses. Alternatively, you can opt out from receiving marketing information at any time by visiting our contact address provided in the Who are we? section at the start of this Privacy Notice.

Please note that we do not make any decisions without human intervention but believe that we should still be transparent and inform you of this right, even though we do not believe you will need to exercise it with us. We don’t allow any partnered third parties, which may utilise AI systems or models, to use your personal data for their own training purposes. If you believe that Mattioli Woods have made a business decision regarding you that has been based entirely upon an automated process, for example profiling of your circumstances prior to offering of any services, then you have a right to ask for that decision to be reviewed. You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

When you visit our website.

As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Cookies are small text files that are placed on your computer by websites that you visit.  They are widely used in order to make websites work more efficiently, as well as to provide information to owners of the websites. Please see our Cookie Policy for further details.

Most web browsers allow some control of most cookies through the browser settings.  To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. We use a third-party service, Google Analytics, to collect internet log information and the behaviour patterns of visitors to the website, in other words to monitor which parts of our website get visited.  This information is processed in a way that does not identify you or anyone else.  For further information on Google’s policies and practices, please visit www.google.com/policies/privacy/partners/.

Our website also contains a search engine that you can use to find information you require.  Any use of this search engine is logged, albeit anonymously, and no user specific identifiable information is captured.  Information that is captured is used to improve the search functionality and website navigation.

When you contact us via social media or e-mail

When you contact us via social media outlets you are using applications that are outside of the control of Mattioli Woods. We cannot guarantee the security of any communication made using social media and we advise that should you have any concerns that you look at the privacy policies that these applications publish. When you contact us via e-mail, we use an industry standard tool called Transport Layer Security (TLS) to encrypt and protect e-mail traffic. If your e-mail service does not support TLS, you should be aware that any e-mails we send or receive may not be protected in transit. We also monitor e-mails and attachments sent to us for identification of any viruses or malicious software.

Third party websites

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website that you visit.

International Transfers

Where possible we aim to ensure that any third party with whom we share personal data is based within the United Kingdom or the EEA. In some instances, as part of our agreed contractual relationship with you, or your employer on your behalf, we may undertake an international transfer of information to a third party outside of the UK. When doing so, we implement appropriate safeguards to ensure the protection of your information.

For transfers to the USA, or to countries without an adequacy decision from the UK authorities, we will take a combination of the following steps:

• We use Standard Contractual Clauses (SCCs) approved by the UK Information Commission or the European Commission
• We utilise the UK-US Data Bridge for eligible transfers to the United States*
• We also utilise UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the UK and EEA and where required conduct transfer impact assessments to evaluate the level of data protection in the recipient country and organisation
• We implement supplementary measures as necessary, which may include encryption, pseudonymization, or additional contractual safeguards
• We regularly review and update our agreements with these organisations to ensure ongoing compliance with UK data protection requirements

*Where we rely on the UK-US Data Bridge or other transfer mechanisms, we will ensure that the relevant requirements continue to be met and that appropriate safeguards are in place.

We retain personal information in line with regulatory requirements, legal obligations and business needs. Due to the long-term nature of pension and investment products, and the need to protect our contractual and legitimate interests, we retain most client records for extended periods. Specific retention requirements apply to different types of information:

Core Financial Records

Pension transfer records may be retained indefinitely where necessary to meet regulatory expectations; We retain records indefinitely

Most products and services: Your information may be retained up to ten years (in the event of legal claims) following account closure in order to:

• Meet ongoing regulatory obligations
• Maintain complete client history
• Support future advice needs

Other Records

• Prospect client records are reviewed periodically and retained only for as long as necessary to support legitimate business activities.
• CCTV footage: 30 days
• Call recordings: 7 years (regulatory requirement)

We keep retention periods under regular review and are implementing enhanced data management systems to ensure appropriate handling of all personal information.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (for example anti-virus solutions and electronic monitoring applications, policies, procedures, employee vetting and training). In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please note that the transmission of information via the internet is not completely secure. Although we shall do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.

At Mattioli Woods, we want to work with you to ensure that we deliver an excellent service to you, and we recognise that you should feel and remain confident that you are in control of how we always use your information. This section explains what rights you have under data protection law. If you want to exercise any of these rights, or if you would like further information about them, you can do so by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

We will grant your rights request only to the extent that, following an assessment of your request, we are allowed and required to do so under data protection law. Your rights may be limited; for example, if fulfilling your request would unfairly reveal personal information about another person, or if you ask us to delete information which we are required by law or have a compelling legitimate interest to keep.

You can submit any request to us under this section by contacting the Privacy Team via one of the contact addresses provided in the Who are we? section at the start of this Privacy Notice.

You have the right to:

Your right to be informed about the information we collect and process that can identify you.

You have a right to be informed of what information is collected about you by Mattioli Woods, and for what purpose. This Privacy Notice is intended to give you information you may require in order to better understand what information is processed and why.

Should you require any further clarification or information please contact the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right of access to your information.

You have a right to access your information that you have provided us with, or any other information we hold about you. Unless we consider the request to be exceptional or excessive (and we will communicate further with you should we consider this to be the case) then this service will be free.

You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right to make changes to the information we hold.

If you believe the information that Mattioli Woods holds about you requires updating, for example you have a new contact address, or believe that any information we hold is currently inaccurate, then you have a right to have changes made to it. This right is sometimes referred to as your right to rectification.

If we have disclosed any incorrect or incomplete data to any third parties, we shall inform them of any necessary amendments or corrections made to your personal data under this section.

You may be contacted by your direct contact, Consultant or Client Relationship Manager within Mattioli Woods from time to time to confirm the accuracy of records and information we hold. You will be able to respond to them directly to ensure your information is correct. You may also contact them at any stage yourself to request records are updated to reflect any changes in your circumstances.

In addition to this you can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right to have your information removed or deleted.

If you believe Mattioli Woods should no longer be holding information about you, or you no longer wish Mattioli Woods to process your information then you have a right to request that your information be deleted. This right is sometimes referred to as your right to erasure, or your right “to be forgotten”.

Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right to request that we temporarily restrict the processing of your information.

Should you wish, you have a right to request that we place a temporary halt to any processing of your information, rather than requesting that we delete your information. You may wish to exercise this right, for example, should you be involved in any dispute or legal proceedings regarding the processing of your information, or in connection with a contractual arrangement.

You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right to have us transfer your information elsewhere in a readily available format.

This right allows you to obtain and re-use your personal information for your own purposes, to move it easily from one IT environment to another in a secure manner. Alternatively, we can transmit such data directly to another organisation. This right assists you to take advantage of other applications or services that can use this information to offer you a service. This right is sometimes referred to as the right to data portability.

You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice.

Your right to object to the processing of your information.

Should you no longer wish to have dealings with Mattioli Woods, for example you have been receiving marketing type communications from us, and you no longer wish to be in receipt of these then you have a right to ask that we stop doing this. If you have previously given us your consent to process your information and we have relied upon this consent to contact you, then you can withdraw this consent at any time. This right is sometimes referred to as “the right to object”.

You can exercise this right by contacting the Privacy Team at the contact address provided in the Who are we? section at the start of this Privacy Notice. If you wish to withdraw your consent to us contacting you for marketing purposes you can also request this this by e-mailing us at marketing@mattioliwoods.com

We are committed to aligning our practices with the FCA’s Consumer Duty requirements. This ensures that we consistently act to deliver good outcomes for our retail customers, and our approach to data protection is an integral part of this commitment.

We would like to work with you to understand how we can provide a better service to you in the exercise of your rights, and in our processing and use of your information.  We understand the importance of your privacy and want you to feel that you can entrust us with your valuable information.

Should you be dissatisfied with how we have responded to you when you have tried to exercise your information rights with us then we would ask that you initially contact us to express your dissatisfaction and ask that we conduct an internal review of how we have responded.  You can contact us at:

Privacy Team
Mattioli Woods Limited
One New Walk Place
Leicester
LE1 6RU

Telephone: 0116 240 8700

Email: privacy@mattioliwoods.com

Right to lodge a complaint with the Information Commission

You also have the right to lodge a complaint directly with the independent “supervisory body” should you wish, if you are unhappy in any way with how we handle your personal data.  The supervisory body can act upon your behalf and investigate to ensure that your rights have not been compromised.  Within the United Kingdom, the supervisory body is the Information Commission, and they can be contacted directly at:

Customer Contact

Information Commission                           or via their website:www.ico.org.uk/concerns
Wycliffe House
Water Lane                                                       or via telephone:  0303 123 1113
WILMSLOW
SK9 5AF