SOPER & CO WEBSITE PRIVACY POLICY
‍Soper & co Ltd is a company registered in England & Wales (collectively referred to as Soper & co “we” or “us” in this policy).
‍OVERVIEW This policy applies when you visit and interact with our website at https://soperandco.com and to the financial services that we provide to you. It contains information about:– how we use your data;– what personal data we collect;– how we ensure your privacy is maintained; and– your legal rights relating to your personal data.More details are below
‍SOPER & CO PRIVACY POLICY
INTRODUCTION
‍This privacy policy will inform you as to how we look after your personal data when you visit  https://soperandco.com (the “Website”) (regardless of where you visit it from) as well as when you instruct us as a client (“Services”) and tells you about your privacy rights and how the law protects you.1. IMPORTANT INFORMATION AND WHO WE AREPurpose of this privacy noticeIt is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.ControllerSoper & co is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).Contact detailsIf you have any questions about this privacy policy, please contact us using the details set out belowContact detailsOur full details are:Chawlet SoperEmail address: chawley@soperandco.comPostal address:1 Crow Lane, Salisbury, Wilton, SP2 0HB Telephone number:  +44 7423 770444You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.Changes to the privacy notice and your duty to inform us of changesThis version was last updated on 17^th April 2023.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
‍2. THE DATA WE COLLECT ABOUT YOUPersonal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes first name, last name. Contact Data includes email address.Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.If you fail to provide personal dataWhere 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 certain 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. Information about connected individualsWe may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
‍3. HOW IS YOUR PERSONAL DATA COLLECTED?We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity and Contact Data by [ ]  or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:Request to use our services.
‍4. HOW WE USE YOUR PERSONAL DATAWe will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:Where we need to perform the contract for services we are about to enter into or have entered into with you.Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.Where you have provided your express consent for us to use your personal Where we need to comply with a legal or regulatory obligation. Purposes for which we will use your personal data we have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity: 1. Providing your name, telephone number and email address in the ‘Request a callback’ function on the Website 3. When you contact us via email by clicking on the email address links or ‘get in touch’ links on the WebsiteType of data: Contact, Profile, Marketing and Communications
Lawful basis for processing: Consent
Purpose/Activity: To discharge our duties as your adviserType of data: All information necessary to act as your financial adviser, including, but not limited to: Identity, Contact, Profile, Financial, Employment
Lawful basis for processing: Performance of contract
Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a surveyType of data: Identity, Contact, Profile, Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity: To enable you to complete a surveyType of data: Identity, Contact, Profile, Usage, Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity: To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Type of data: Identity, Contact, TechnicalLawful basis for processing: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to youType of data: IdentityContact, Technical, Usage, Profile
Lawful basis for processing: Necessary for our legitimate interests (to develop our products/services and grow our business)

5. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?During the course of our relationship with you, we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:Five years for investment businessThree years for mortgage businessIndefinitely for pension transfers and opt-out businessThree years for insurance businessThese are minimum periods, during which we have a legal obligation to retain your records.We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
‍6. DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.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.Regulatory Agencies for financial services.We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions or in accordance with applicable laws.
‍7. INTERNATIONAL TRANSFERSWe do not transfer your personal data outside the European Economic Area (EEA).
‍8. DATA SECURITYWe 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. 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.
‍9. DATA RETENTIONHow long will you use my personal data for?We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
‍10. ACCESS TO YOUR DATANo fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.Time limit to respondWe try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
‍11. YOUR LEGAL RIGHTSYou have the right to:Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.