Lumin and Protecting Your Data: Privacy Policy

Lumin is committed to protecting the privacy of its clients and we therefore ask that you please read 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.

The Regulation

Lumin are regulated by the ICO (Information Commissioners Office) who are 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 Regulation (GDPR) which will apply to all UK and EU businesses who process personal data from 25 May 2018. This ensures that, as our client, you can be sure that Lumin will manage and process your personal data in line with the new regulations.

Definitions

Data Controller – Lumin Wealth Management Ltd  is classed as a Data Controller as we will determine the purposes and means of the processing your personal data in respect of the advice we give.

Personal Data – When using the term “personal data” in our agreement, we mean 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 understand your personal circumstances and 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. If this is applicable you will need to give us explicit consent to process this data by using the opt-in box below.

The Purpose and Lawful Basis for Processing your Personal Data

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. 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.

Relatives Personal Data

When Lumin gather 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 and high standard of service that we endeavor to give all of our clients. If this is required, please ensure that either they complete the consent box or provide sufficient details for us to provide this document to them.

Third Parties and your Personal Data

We confirm that your personal data will not be used, or transferred by us to any other 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. We do not transfer any of your personal data to non-EU jurisdictions or international organisations. We may also provide information to our regulators the FCA or ICO upon request for regulatory purposes.

Where Personal Data is not obtained directly from the Client

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 in order to obtain certain verification documents. For further information please see the client agreement.

Your Rights available under the General Data Protection Regulations (GDPR)

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 the rights to be informed, of access, to rectification, to erasure, to restrict processing, data portability and to object to processing. If you require more information on these then please contact the Lumin Data Protection Officer at the address below or the ICO (Information Commissioners Office) website at ico.org.uk.

Marketing

Lumin do not ‘direct market’ to any of our clients. We have legitimate interest in contacting you about your plans and will only contact you regarding the performance of your existing contracts or portfolios, and for associated purposes such as our quarterly investment newsletter and individual tax efficient opportunities. It is not recommended to stop these communications as they are vital to the performance of your contract, however if you wish to have these removed then please do contact the office directly.

Retention periods for your Personal Data

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 due to the fact that under FCA regulation there are no clear limitations as to when a client can make a complaint regarding the financial advice from firms and 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 are a prospect client we will retain your data for 2 years, after which point we will delete it, unless you revoke your consent to process your data sooner than this.

Questions or Concerns

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 Management Ltd, 5 Sandridge Park, Porters Wood, St Albans, Hertfordshire AL3 6PH  Telephone number: 01727 893333 or contact the ICO (Information Commissioners Office) at  ico.org.uk/concerns/ or on 0303 123 11