Lumin Group Limited (“Lumin”) and its subsidiaries are committed to protecting the privacy of its clients and we therefore ask that you please read this Data Protection Agreement before providing us with any information about you or any other person.
This agreement explains when and why we collect personal information about people who enquire about or make an investment with Lumin. The agreement also explains how we use that information, the conditions under which we may disclose information to others, and how we keep personal information secure.
Lumin are regulated by the Information Commissioners Office (ICO) who are the UK’s independent body set up to uphold information rights. Lumin, as a Data Controller, are legally obligated to comply with the General Data Protection Regulations (GDPR) which applies to all UK and EU business who process personal data from 25th May 2018. This ensures that, as Lumin’s client, you can be certain that Lumin will manage and process your personal data in line with the newest regulations.
Data Controller – Lumin is classed as a Data Controller as we will determine the purpose and the means in which your personal data is processed with respect to the advice that we give.
Personal Data – When using the term “personal data”, we are referring to information that relates to you and allows us to identify you, either directly, or in combination with other information that we may hold, which may include your address, date of birth, income, assets etc.
Special Category Data – As part of our service we may be required to collect Special Category Data about you to help us to understand your personal circumstances and to help you to achieve your goals. This may be personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We currently collect and process personal identifiers, contracts, and characteristics (for example, name and contact details) and financial information. You acknowledge and understand that we process your personal and financial data (electronic and/or paper based) with regards to your circumstances, as this is a contractual requirement to be able to advise you on your financial planning needs. You also acknowledge that Lumin is allowed, for legitimate business purposes, to share your personal information within the Lumin group of companies, which includes any company that is owned wholly or in part by Lumin Group Limited. Without your agreement to process your data we will not be able to fulfil your financial planning requirements as it is essential to carry out this contract. You can withdraw consent to process your data at any time by contacting us, but this will result in an inability to provide you with financial advice.
When Lumin gathers data regarding your personal and financial situation, we may need to obtain data regarding your spouse or children to give you more rounded advice. The ongoing processing of their data falls under the lawful basis for processing titled ‘legitimate interest,’ since it is required for the continuation of the service offered by Lumin. Without this information, we may not be able to provide you with the personalised, high standard of service we endeavour to give all our clients. If this is required, please ensure that they provide sufficient details for us to provide this document to them.
We may disclose your information to Lumin Group and its subsidiaries, including Lumin Group Limited, Lumin Wealth Limited, Lumin Wealth Management Limited, Davidson Deem and our parent company VZ Group. In some instances, we may transfer data to entities within the VZ Group located in Switzerland, but only where necessary for legitimate business purposes. As Switzerland is considered a third country under European data protection regulations, we ensure that any data transfers to Swiss entities are in full compliance with relevant legal and regulatory requirements. VZ Group adheres to Swiss data protection laws to safeguard the privacy and security of your personal information.
We confirm that your personal data will not be used, or transferred by us to any other external firm, company, entity, or person without your consent to do so, or without your acceptance of the financial advice to apply to specific product providers i.e. Ascentric or Aegon. These providers are Joint Data Controllers and are responsible for processing your personal data under the GDPR in the same manner as Lumin.
Please also be aware that some service providers may provide some of their services from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Data Protection laws even when your personal information is processed outside Europe. We may also provide information to our regulators the FCA or ICO upon request for regulatory purposes only.
In order to verify your identification, we are required to use a third-party Anti-Money Laundering provider to carry out verification services on our behalf. We have chosen SmartSearch as they are extremely reputable and maintain the high standards that Lumin looks for when using contractors. They are therefore classed as Joint Data Controllers as we share some of your personal data with them to obtain certain certification documents. For further information please see the client agreement.
Under the new regulation your rights have been enhanced and updated to ensure you have more control over the data that Lumin holds. These include:
If you require more information on these please contact the Lumin Data Protection Officer at the address below, or the Information Commissioner’s Office (ICO) website at ico.org.uk
We may collect and use your personal information for the purpose of communicating with you by email, telephone and post.
Our financial planning and investment insights comprise a range of communication means. Direct marketing activities are based on legitimate interests to do so for information and business development purposes. By providing your personal data you consent to us contacting you through all of our communication methods.
We will retain your personal data only for as long as it is necessary to fulfil the purposes for which it was collected, such as sending you newsletters and updates. If you no longer wish to receive communications from us, you can opt out at any time, and we will remove your data from our records. To opt out from receiving communications please follow the unsubscribe instructions included in every email or alternatively contact the office directly. We regularly review the data we hold to ensure it is up to date and necessary for our ongoing relationship with you.
Our website uses cookies. Cookies are small text files stored on your device; they can be used by websites to make a user’s experience more efficient and provide personalised content. For detailed information on how we use cookies and how to withdraw your consent, please see our cookie policy: https://luminwealth.co.uk/cookie-policy/
We may use third-party service providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services including Google Maps, Google AdWords and Google Remarketing.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage:
https://policies.google.com/privacy
To opt-out of the cookie tracking and withdraw your consent please see our cookie policy; https://luminwealth.co.uk/cookie-policy/
If you become a Lumin client we will retain your personal data throughout the contract period, following termination of this contract, and until you are deceased. This is because under FCA regulation there are no clear limitations as to when a client can make a complaint regarding the financial advice from firms. Therefore, it is necessary to keep all data such that Lumin could defend a potential legal claim in the future. You do however have the right to restrict the processing of your data should you require it.
If you have a child under the age of 13, we will take your agreement of this privacy policy as your consent to Lumin collecting and processing the data of any minor we name on the fact find. Collection of this data is for the purpose of fully understanding your personal and financial situation, an exercise required for the continuation of the service offered by Lumin. Should you wish to opt out, please contact us directly.
Should you require any assistance, or you are concerned that your personal data has not been handled correctly, then you can make a complaint by writing to the Data Protection Officer at Lumin Wealth Limited, Second Floor, 4 Beaconsfield Road, St. Albans, Hertfordshire, AL1 3RD; by calling our telephone number 01727 893 333; or by contacting the ICO at ico.org.uk/concerns/ or by calling their telephone number 03031 231 113.
In accepting this privacy policy agreement you confirm that you understand and consent to the terms of this data protection agreement including the explicit consent to process special category data. You have the right to withdraw this consent at any time, but it may affect the advice Lumin provides.