This privacy policy applies between you, the User of this Website and LEBC Group Limited, the owner and provider of this Website. LEBC Group Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.
1 General
1.1 Definitions
1.1.1 LEBC Group Ltd (“we” “us” “our”) is committed to protecting and respecting your privacy. We are the data controller and will process your personal data in accordance with the UK GDPR and the Data Protection Act 2018 and any national laws which relate to the processing of personal data (“data protection legislation”).
Data - Collectively all information that you submit to LEBC Group Limited. This definition incorporates, where applicable, the definitions provided in the UK GDPR and the Data Protection Act 2018;
Cookies - a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by our Website
Site(s) - https://www.lebc-group.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions
1.2 Visitors to Our Websites
1.2.1 We may collect and process personal data about you in the following circumstances:
a) when you complete the online contact forms on our Site providing us with your name, address, contact details and the nature of your enquiry;
b) whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
c) when you visit our Sites we will retain details such as traffic data, location data, weblogs and other communication data, and the resources that you access (see section 1.3 on Cookies below); and
d) whenever you disclose your information to us, or we collect information from you in any other way, through our Sites.
1.2.2 IP Address: We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
1.2.3 We may use your personal data for our legitimate interests in order to:
a) provide you with information, or services that you requested from us;
b) respond to an enquiry submitted via our online contact forms;
c) allow you to participate in interactive features of our Sites, when you choose to do so;
d) ensure that content from our Sites are presented in the most effective manner for you and for your device;
e) improve our Sites and services;
f) process and deal with any complaints or enquiries made by you; and
g) contact you for marketing purposes (see section 4 for further details).
1.2.4 Website Links - Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites.
1.3 Cookies
1.3.1 This Site may place and access certain Cookies on your computer. We use Cookies to improve your experience of using the Site. LEBC Group Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
1.3.2 All Cookies used by this Site are used in accordance with current UK and EU Cookie Law.
1.3.3 Before the Site places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling LEBC Group Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Site may not function fully or as intended.
1.3.4 Type of Cookie and Purpose:
(1) Strictly necessary cookies: These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(2) Analytical/performance cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
(3) Functionality cookies: These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(4) Targeting cookies: These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
1.3.5 You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
1.3.6 You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, personalisation settings.
1.3.7 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
1.4 Facebook pixel – performance/analytical
1.4.1 The cookies used for this pixel are: c_user, datr, fr, presence, sb, spin, wd, xs, fbp
1.4.2 The data stored in session storage gets cleared when the page session ends. A page session lasts for as long as your internet browser is open.
1.4.3 The purpose of this cookie is that it enables Facebook to track user interest with Facebook Pixel Events.
1.4.4 The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/.
1.4.5 You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/ds/preferences/?entry_product=ad_settings_screen#_=_.
1.5 Force24 Cookies & Tracking
1.5.1 Our organisation utilises Force24’s marketing automation platform. Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:
• F24_autoID
• F24_personID
1.5.2 They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.
f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.
f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.
1.5.3 The information stored by Force24 cookies remains anonymous until:
• Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
• A user of the website completes a form containing email address from either our website or our Force24 landing pages.
The Force24 cookies will remain on a device for 10 years unless they are deleted.
1.5.4 Other Tracking
We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities
1.5.5 Device & browser type and open statistics
All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.
1.5.6 Link Tracking
All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.
2 Customers
2.1.1 We will collect details such as name, address, email address, contact number, date of birth, national insurance number, financial information and information about personal circumstances in order to provide you with the service that you have engaged us for. We will collect and use this information both initially and ongoing where you ask us to provide a service to you.
2.1.2 Where you have asked us to provide a service, we will use your data to verify your identity with a credit referencing service in order to comply with the law in relation to preventing money laundering, terrorist financing and other financial crime.
2.1.3 We will share customer personal information with our employees to manage our relationship with you and we will retain your personal data. We will retain this data for 6 years. Where we have given you regulated financial advice, to allow us to assist you in the future in the event that you raise a complaint or have concerns about any advice we have given you, we will archive your file.
2.1.4 We will use your personal data provided to comply with our contractual obligations arising from the agreements we enter into with you and share the data with financial institutions who can assist in the provision of financial services to you including product providers, lenders, banks, insurers, fund managers and platform providers.
2.1.5 We will use customer personal data for our legitimate interests including:
a) sharing personal data with companies who provide compliance services to us. This is necessary to ensure that LEBC is complying with its regulatory responsibilities to ensure that the advice and the services we provide are suitable for our customers and comply with the relevant regulatory rules;
b) sharing personal data with companies who provide services which allow us to conduct product research on your behalf to ensure you get the most suitable advice;
c) informing you about products and services which may be of interest to you;
2.1.6 In addition to the above, with your consent, we will obtain “special category data” from you and from third parties. This can include details about your health, ethnic origin, criminal prosecutions, religion, political opinions, trade union membership, sex life and sexual orientation. In most cases, we will get this information from you directly but occasionally, in some cases, we may get this information from third parties (such as from employers who have engaged us to provide a service to you).
2.1.7 Unfortunately, in some instances due to the regulatory requirements we are subject to in providing advice or services, without special category data mentioned above, we may not be able to provide you with a service. We will let you know if this is the case.
2.1.8 We will not transfer any customer personal data outside the European Economic Area (“EEA”).
3 Suppliers and Introducers
3.1.1 We will collect details such as contact names, address, email address and telephone number in order to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of six years from the date of our last contact with you, with the exception of records relating to pension transfers which must be kept indefinitely. We will not transfer your personal data outside the EEA.
4 Marketing
4.1.1 If you indicate that you consent to marekting contact, we may use customer personal data to provide you with details about our services, products and business events which we think may be of interest. We believe this is in our legitimate interest but, before contacting you on this basis, we will take into account customer rights and reasonable expectations.
4.1.2 You have the right to opt-out of receiving the information at any time. To opt-out of receiving such information you can:
a) asking your financial planner or other member or staff to update your preferences;
b) clicking the unsubscribe button contained in any such communication received; or
c) email us at compliance@lebc-group.com or call 0800 055 6585 providing us with your name and contact details.
4.1.3 Where you have subscribed to receive marketing correspondence from us we will keep your personal data for six years from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).
5 Legal Basis for Obtaining and Using Your Data
5.1.1 In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:
a) for performance of a contract we enter into with you;
b) where necessary for compliance with a legal obligation we are subject to; and
c) for our legitimate interests (as described within this policy).
5.1.2 We will also process your personal data including personal sensitive data where we have obtained your explicit consent.
6 Third Parties
6.1.1 In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:
a) staff members in order to facilitate the provision of services to you;
b) staff members of our sister company, Aspira Corporate Solutions, to facilitate the provision of services to you;
c) IT software providers that host our Site and store data on our behalf; and
d) to a prospective buyer of some or all of our business or assets, in which case personal data including Your Data will also be one of the transferred assets.
e) We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal and regulatory obligations, or in order to enforce or apply our agreements.
6.1.2 We may also disclose your personal data to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.1.3 We will not sell or distribute your personal data to other organisations without your consent to do so.
6.1.4 We do not transfer personal data outside the EEA. Where this is required in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation.
7 Data Security
7.1.1 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
7.1.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites or the site of any product provider recommended to you by us, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.1.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
8 Your Rights
8.1 Keep Your Data Up to Date
8.1.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes. Where we provide an ongoing service to you, we will periodically ask you to update your details
8.2 Remove, Restrict or Access Your Data
8.2.1 You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided.
8.2.2 You can also ask us to undertake the following:
a) remove your personal data from our servers and systems entirely;
b) send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract;
c) restrict the use of your personal data; and
d) provide you with access to information held about you and for this to be provided in an intelligible form.
8.2.3 We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
8.2.4 Please send any requests relating to the above to:
Compliance
LEBC Group
7th Floor
East Wing
3 Temple Quay
Temple Back East
Bristol
BS1 6DZ
Email: compliance@lebc-group.com
Tel: 0333 136 2233
Please specify your name and the action you would like us to undertake. Please also include full contact details in case we need to query your request.
8.3 Withdrawing Your Consent
8.3.1 Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at:
Compliance
LEBC Group
7th Floor
East Wing
3 Temple Quay
Temple Back East
BS1 6DZ
Email: compliance@lebc-group.com
Tel: 0333 136 2233
8.4 Data Protection Complaints
8.4.1 If you have any concerns or wish to complain about how LEBC handles your data, you can call 0800 055 6585 and ask to speak to the Compliance Team. You can also email compliance@lebc-group.com.
8.4.2 If you are not happy with Sean Kavanagh's response or if you would prefer not to speak to LEBC then you can find more information about raising a grievance on the website of the Information Commissioners’ Office (ICO) https://ico.org.uk/concerns or by calling them on 0303 123 1113. The ICO is the UK's independent body set up to uphold information rights.
8.4.3 LEBC is registered on the Data Protection Register under Registration Number Z7522619
9 Changes to this Policy
9.1.1 We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.
You may contact LEBC Group Limited by email at marketing@lebc-group.com