This website is operated by AJ Bell Management Limited and AJ Bell Limited.
This policy (together with any other documents referred to in it) explains how we collect, process and protect personal data about you. By visiting our website, you are accepting and consenting to the practices described in this policy.
From time to time, the website may 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 that they have their own privacy policies and that we do not accept any responsibility or liability for your data if you choose to use these websites. Please check these policies before you submit any personal data to these websites.
This policy includes details of:
- the types of personal data we may collect and store
- the legal basis for using your personal data
- how we capture and receive this personal data
- how we use your personal data
- how we may disclose your personal data and share this with third parties
- where we store and protect your personal data and how long we will hold it for
- your legal rights in relation to your personal data we hold
- how you can contact us for more information
For the purpose of the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and other relevant legislation, our data controller is AJ Bell Management Limited of 4 Exchange Quay, Salford Quays, Manchester M5 3EE.
The Data Protection Officer for AJ Bell Management Limited is Karen Goodman, Chief Risk Officer, who can be contacted at the address shown above, by email to enquiry@ajbell.co.uk or by telephone on 0345 40 89 100.
The table below confirms the personal information we collect from you and your adviser, along with why we collect your data and the legal basis for doing so:
| Type of data | Data collected | Purpose of processing | Legal basis |
|---|---|---|---|
| Residential and contact information |
Including details of your:
|
Verifying your identity Contacting you about products, services, regulatory obligations and contractual obligations. Seeking your consent for transactions and changes to terms and conditions. |
In order to fulfil our contractual obligations to contact you and update you on product changes, and in order to comply with regulatory requirements. |
| Socio-demographic |
Including details of your:
|
Developing products and services. Defining customer types and target markets. Complying with regulatory requirements and managing risk effectively. |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements. |
| Family circumstances |
Including details of your:
|
Understanding your circumstances. Paying benefits appropriately from your account/s. |
In order to fulfil our contractual obligations and in order to comply with regulatory and legislative requirements. |
| Transactional information |
Including details of:
|
Efficiently completing transactions you instruct, or that we must undertake for legal or regulatory reasons. | In order to fulfil our contractual obligations and in order to comply with regulatory requirements. |
| Technical |
Each time you visit the website, we may automatically collect the following information: Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); page response times; download errors; length of visits to certain pages; page interaction information; methods used to browse away from the page and any phone number used to call our customer service number. |
Developing products and services. Defining customer types and target markets. |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements. |
| Special and one-off items of information |
Including details of your:
|
Paying benefits appropriately from your account/s. | In order to fulfil our contractual obligations and in order to comply with regulatory requirements. |
| Legal |
Including:
|
Verifying your identity, authority and eligibility in relation to the products and services we provide to you. | In order to fulfil our contractual obligations and in order to comply with regulatory requirements. |
The legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- you have provided your consent to us using the personal information, for example in the course of you or your adviser opening your account and agreeing to our terms and conditions
- our use of your personal information is in our legitimate interest as a commercial organisation to verify your identity or to communicate with you about the products and services that you use or may wish to use. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained below
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you - for example on opening an account for you, instructing an investment with a third party provider or in the sale or purchase of a property
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have, for example providing information on investment transactions to the FCA and reporting holdings, payments, accruals, and charges to the relevant tax authorities
If you would like to find out more about the legal basis upon which we process personal information, please contact us.
Information you give us
You and your adviser may give us information by filling in forms on the website or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our websites; apply for one of our products; search the website; enter a competition or promotion; take part in a survey; or when interacting with the website in any other way. This also includes any occasions when you report a problem with the website. The information you give us may include your (or your client’s) name, address, email address, phone number, financial information and/or other relevant personal details.
By submitting such details, you and your adviser confirm that you are entitled to disclose information about, or provided by, any third party. If you are an adviser submitting an application on behalf of your client, you confirm that you have their authority to do so and that they understand that we will use their personal details.
Information we receive from other sources
We may also receive information about you if you use any of the other websites we operate, or the other services we provide. In such cases, when we collect the data, we will inform you that it may be shared internally and combined with data collected on this site. We also work closely with third parties (including, for example, business partners; external service providers in technical, payment and delivery services; advertising networks; analytics providers; search information providers and credit reference agencies) and may receive information about you from them.
If you authorise a third party to contact us on your behalf and entitle them to provide us with information about you or the services you have with us, we will always verify their identity and right to access you information before any further information about your account(s) is divulged. Please see our website terms of use for more details.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to improve your experience when you browse our website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.
Disclosure of your information
We may share your personal information with any member of our group. This includes our subsidiaries and our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We share information amongst our subsidiaries to ensure that each business unit which provides platform and pension administration services has the information it needs to efficiently and effectively process transactions and other administrative duties on your behalf. It also means they comply with regulatory requirements and reporting obligations.
We may share your information with selected third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including but not limited to:
- investment providers regulated and authorised to provide investment services in the United Kingdom
- data and software providers
- regulatory and tax authorities
- credit reference and fraud prevention agencies
You can find out more about TransUnion (a credit reference agency) on its website via the following link: Click here
- analytics and search engine providers that help us to improve and optimise the website.
We may disclose your personal information to third parties in the following circumstances:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of the business or assets;
- if AJ Bell Management Limited or substantially all of its assets are acquired by a third party, in which case the personal data we hold about our customers will be one of the transferred assets; or
- if we’re required to disclose or share your personal data in order to comply with a legal obligation, or to enforce or apply our rights under this policy or terms and conditions and other agreements; or to protect the rights, property, or safety of any member of our group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How we store and protect your personal data
Your data will primarily be held in the UK but there may be occasions when the data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of orders, the processing of your payment details and the provision of support services. 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 treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you, or you have chosen, a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you, your adviser or your representative contact us for details of your account, we will ask some questions so that we can establish your identity (or the identity of your adviser or representative) and we will not disclose any details unless we are satisfied that you, your adviser or your representative are who you claim to be.
Unfortunately, the transmission of information via the internet cannot be 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. We strongly suggest you purchase and keep up-to-date software to protect the security of your computer or device.
How long we will store your personal data for
Your personal data will be stored for the duration of your relationship with us. After that, we will store your personal data for as long as it is legal, appropriate and necessary to do so. This includes retaining all anti-money laundering check data for 5 years.
We may also store other information for longer than 10 years if needed to evidence that we have met our regulatory requirements and to demonstrate that we have correctly recorded and reported information on your accounts to the relevant authorities.
Your rights
You have the following rights in relation to your data that we hold:
The right to access
You have a right to request that we provide you with a copy of your personal information that we hold. You also have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
The right to rectification
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
The right to erasure
You can request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which you are subject
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims
The right to restriction of processing
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person
The right to object to processing
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we will then need to demonstrate that we have compelling legitimate interests which override your rights and freedoms in order to continue processing your data.
The right to portability
You have the right to ask us to provide you with an electronic file containing all personal information we hold about you. You can then give this information to other organisations if you wish to.
Right to object to how we use your personal information for direct marketing purposes
You also have the right to ask us not to process your personal data for marketing purposes, or to change the way in which we process your data for direct marketing purposes.
You can request that we don’t transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
You can exercise your right to prevent or change such processing by using the unsubscribe button in marketing emails sent to you. You can also exercise the right at any time by contacting The Marketing Department, AJ Bell, 4 Exchange Quay, Salford Quays, Manchester M5 3EE or email us at marketing@ajbell.co.uk.
However, keep in mind you cannot opt-out of receiving regulatory or legal updates (e.g. information about a change in the product terms and conditions) by email. We regularly review our records to ensure that we only retain your personal details for as long as is necessary for the purposes set out above.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
If you have concerns about how we are processing your personal information, you have a right to lodge a complaint with your local supervisory authority.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Access to information
Before disclosing the personal information you requested, we may ask you for additional information to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law - for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please note that updates to this policy are not emailed as a matter of course, so please check back frequently to see any updates or changes to our privacy policy.
Contact
Please send any questions or comments about this policy to The Marketing Department, AJ Bell, 4 Exchange Quay, Salford Quays, Manchester M5 3EE. Email us at marketing@ajbell.co.uk or by calling 0345 40 89 100.