Privacy & Cookies Policy

Introduction

This privacy notice explains who we are, how we collect, share and use your personal information, and how we protect your data. It is intended to help you understand your privacy rights and how we comply with UK data protection laws.

Personal information is any information that can be used to identify you as a unique individual.

 

Who we are

Our website address is: https://stephenevefinancial.com.

Stephen Eve Financial Planning Ltd. is an appointed representative of 2 plan wealth management Ltd which is authorised and regulated by the Financial Conduct Authority. It is entered on the FCA register (www.fca.org.uk ) under reference 980192. Registered office: Stephen Eve Financial Planning Ltd, 12 Regent Street, Nottingham, NG1 5BQ. Registered in England and Wales Number: 14084601.

Please see the Privacy Policy for 2 plan wealth management Ltd here: https://privacy.2plan.com/.

We have a website that provides the public with information on our company and what services we provide.

By using our website or by registering for any of the products and services we offer through it, you are confirming to us that you understand and accept that your personal information may be used by us in the manner described below. We may keep details of your visits to our website including, but not limited to, traffic data, location data, web logs.

If your visit also includes your registration to one or more of our products or services, you may unsubscribe from these at any time.

 

Content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, links, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

We are not responsible for the content served to you when visiting a website from a link we have shared and you should, therefore, refer to the privacy policies and cookie policies on these websites themselves for guidance.

Stephen Eve Financial Planning Ltd. are not responsible for any information provided by any other source once you leave the Stephen Eve Financial Planning Ltd. site. Any links from our website to other websites are provided merely for your convenience and do not imply our endorsement of the content or the provider. If you follow a link to any of these websites, you do so at your own risk and we do not accept any responsibility or liability for the content of such websites.

 

What personal data do we collect?

Stephen Eve Financial Planning Ltd. & 2Plan are both Data Controllers and Data Processors of information you provide to us.

In order to provide you with specific advice and services we will ask you questions that tell us more about you, your situation, lifestyle and attitudes. This is called personal data, some of which will be classed as confidential, private and sensitive.

The GDPR says that personal data is defined as any data from which a living individual can be identified. Any provision of that type of data should be given freely for the purpose(s) it was intended.

We ask for your permissions to use your personal information to enable our Advisers to provide you with detailed advice or proposals on the financial products and services you have asked about. This is classed as legitimate interests for processing. It simply means that we require your agreement to collect and process your details in order to provide you with a service or advice. Without it we would not be able to offer such advice or service to you.

Any of the consented personal and confidential detail, which will include any sensitive information you have provided, is only collected specifically for these purposes and is processed lawfully, fairly and transparently in a way which can be scrutinised.

That consent can be revoked by you at any time but it would mean that the more detailed advice that could be provided regarding these data will no longer be available to you.

All information is held and maintained in a secure format and encrypted where required to ensure controlled security. Only the minimum of relevant and adequate personal data will be collected and access is restricted to only those personnel that need to for the provision of the advice and services.

We may collect your personal data in several ways:

  • Directly from you:
    • During fact finding meetings and any other meetings with you.
    • When you complete a form or survey or provide information on our website.
    • When you contact us by phone, in writing, by email or electronic methods.
    • When you send us information as part of an on-going service delivery.
    • When you register to receive communications.
    • Provided by you as part of accessing 2plan services or attending 2plan events.
  • From Third Parties:

Before you provide personal data about another individual, please ensure you have their consent.

    • When you are referred to us by an introducer or a professional service firm.
    • From policy providers, mortgage providers, or other financial institutions.
    • Via publicly available sources and online searches.
    • From other clients where it is necessary to do so e.g. where you are a beneficial owner of their assets or as an individual making payments to their account.
    • Information provided by legal firms in relation to legal proceedings.
    • Where information is passed to us as a result of us acquiring or merging with another firm or advice network; or an RI or AR joining our firm (of which you were previously a client).
  • Through Our Website
    • Using cookies and similar technologies (please see our separate Cookie Notice on our website).

The types of personal information we collect

We may collect and process the following data about you:

  • Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our products and services, posting material or requesting further products and services. We may also ask you for information when you report a problem with our website.
  • Personal details that you provide by completing in-depth information gathering, either remotely or face to face with one of our registered and approved advisers in relation to offering you advice on financial products and services you have asked us about.
  • If you contact us, we may keep securely a record of that correspondence (including email and phone conversations) including your name, address, telephone numbers, email address and other information which you supply to us.
  • We may also ask you to complete, from time to time, surveys or questionnaires which you have agreed to, that we use for research purposes or to improve our relationship with our clients.

Further types of data collected:

  • Identity data includes your full name, title, date of birth, age, personal identifier and policy/account numbers.
  • Contact data includes your home address, email address and phone number.
  • Financial data includes your earnings, income, expenditure, bank account number, credit/debit card number, existing investments, pension and insurance products, spending habits, transaction history, tax reference number, source of wealth and source of funds.
  • Family data includes your marital status, next of kin, dependents and emergency contact details.
  • Profile data includes your sex, occupation, employment status, citizenship, residential and domicile status, property details, occupancy status and insurance information.
  • Identification data which includes your driving licence, passport, National Insurance number and other national identifiers.
  • Technical data includes internet protocol (IP) address, location data, operating system, time zone etc.

Our website uses cookies in order to maintain operational functionality for our website visitors. Please read our section on cookies for more information about how we use cookies.

When a website visitor enquires and submits our enquiry form, we capture the IP address for spam protection. We also ask for the name, email address, contact number and other questions to assist with your enquiry and ensure we can help you to the best of our ability. In submitting this form, you acknowledge that you are giving this information freely for this purpose. This form submission is then emailed to us and stored securely in accordance with GDPR (General Data Protection Regulation (EU) 2016/679) and data protection laws.

We also collect special categories of personal data which includes:

  • Health data which includes any physical disability, mental disability or any medical condition.
  • Criminal data which includes information about criminal convictions and offences, allegations. (proven or unproven) and investigations, penalties and restrictions, County Courts Judgements and insolvency details as well as information relating to the absence of convictions.
  • Special category data includes information about your health, racial or ethnic origin, sex life, sexual orientation.
  • Biometric data – includes a fingerprint, voiceprint, or scan of hand or face geometry, retina/iris scan.

It is important that the personal information we hold about you is accurate and up to date.

We do not and will not knowingly collect any personal data from any unsupervised child under 13. If you are under 13, you must not use our websites unless your parent or legal guardian has given explicit consent for your access.

Please keep us informed of any changes to your personal information, such as change of contact details.

 

How do we use this information?

We may use information held about you in the following ways:

  • To ensure that content from our website is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes. You may ask us to cancel this consent at any time and you will only then receive information specifically about your account activity with Stephen Eve Financial Planning.
  • To carry out our obligations arising from any contract entered into between you and us and that may involve providing some of your information to a third party to carry out necessary background checks (including but not limited to Identity Verification / Anti Money Laundering / Fraud Prevention / Residency Confirmation).
  • To provide some or all of your personal information (as required) to one or more financial products providers in order to fulfil a detailed proposal for the services you have asked Stephen Eve Financial Planning about.
  • To carry out a form of profiling that gives us a clear view of your circumstances and that is part of the advice process. Where this is done, you will be shown its recommendations and will be provided with the opportunity to review and amend its output to indicate your attitude to risk.
  • For training purposes, quality assurance or to record details about the products and services you ask us about.
  • To satisfy and meet our legal and regulatory requirements with the FCA and ICO, or as requested by UK security services.
  • To notify you about changes to our products and services or terms & conditions.

Unless prescribed by law, we will retain your details for no longer than is necessary for the purposes for which the personal information was collected or for which it is to be further processed by us.

 

Cookies

The Stephen Eve Financial website uses cookies to improve the experience of the website user. In order to do this we may place cookies on your device to assist the operation of our website, this may include (but is not limited to) improving website performance and loading speeds the next time you visit us. 

We may also use analytical cookies to enable us to understand how our visitors navigate our website and also to make informed decisions on the services we offer.

We also use Google reCAPTCHA v3 to analyse your usage of our website and flag whether any behaviour is suspicious and could indicate spam or bot related activities. Google reCAPTCHA allows us to ensure the forms on our website are secure and is only used to fight spam and abuse.

All cookies used on this website are within compliance with United Kingdom and Europe cookie law.

When visiting our website for the first time, you will be asked whether you would like to accept the use of cookies for our website. If you would like to delete any cookies placed on your device, you can do so freely within your browser settings. Should you also wish to disable cookies entirely for all websites, you can also find this in the settings panel in your website browser.

 

Artificial Intelligence (AI) 

We may use artificial intelligence (AI) systems to help us provide our services, improve efficiency, and enhance your experience. For example, we may use AI tools to analyse information, support decision-making, or assist with routine administrative tasks. 

When we use AI, we do so in accordance with data protection law. We ensure that:

  • AI tools are used responsibly and with appropriate human oversight.
  • Any personal data processed by AI systems is handled securely and only for lawful purposes. 
  • We assess the impact of AI systems to ensure they do not unfairly affect your rights or freedoms.
  • You have the right to request information about how AI has been used in relation to your personal data, and to object to certain types of automated processing.

We do not make solely automated decisions that have a legal or similarly significant effect on you without human involvement. 

 

Marketing

We may use your personal information to provide you with information about our products or services which may be of interest to you, if you have provided your consent for us to do so.

If you wish to opt out of marketing, you may do so by clicking on the "unsubscribe" link that appears in all emails that are sent to you or by telling us when we contact you. Otherwise, you can always contact us using the details set out the section “How to Contact Us” to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, you will still receive service based communications in connection with the products and services we provide to you.

 

Where your data is sent

For your security, Stephen Eve Financial Planning Ltd. and 2plan have made the conscious decision to only manage, host and process personal information in the UK.

We may disclose your personal information to any member of the 2plan group of companies in order to fulfil any obligations to you.

Any transferring, sharing or use of personal data will only be done with approved and contracted third-party companies, that have provided evidence of their own GDPR compliance, to develop the advice requested by the client with the exception of checks such as Anti-Money Laundering, Fraud Prevention and Identity Validation or from valid requests by regulatory or security bodies.

We may disclose your personal information to third parties if we are under a duty to disclose or share it in order to comply with any legal or regulatory obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of our customers, or others.

When submitting an enquiry form, we use Google reCAPTCHA v3 to protect from spam. Your usage data may therefore be analysed by Google to help us identify any suspicious behaviour before an enquiry form is submitted. Form submissions are then emailed directly to us securely and stored in compliance with GDPR.

 

Third parties we share your personal data with

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes set out in this privacy notice.

We may also share your data with third parties:

  • To perform services on your behalf
  • To the extent that we are required to do by law
  • In connection with any on-going or prospective legal proceedings
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purpose of fraud prevention and reducing credit risk)
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such or authority would be reasonably likely to order disclosure of that personal information.

In certain circumstances, where there are internal teams providing shared services across 2plan and other entities within The Openwork Partnership, personal data of 2plan clients may be stored and accessed on Openwork systems (including the use of their systems to facilitate 2plan’s services). For certain processing activities necessary to provide 2plan’s services and for related operations, personal data may be shared with other members of the Openwork Partnership. Depending on the specific processing activity, these entities may act either as data processors—processing data strictly on 2plan’s behalf—or as joint controllers, where they collectively determine the purposes and means of processing. In either case, all processing will be carried out in accordance with the requirements of data protection regulation, with appropriate agreements in place to clearly allocate responsibilities and safeguard data subjects’ rights.

Types of third parties who may have access to your personal data include:

  • Professional service providers: when you have asked us to share your details with them.
  • Regulatory authorities, the government and tax authorities.
  • Fraud prevention and/or law enforcement agencies.
  • Product providers: The scope and extent of the sharing of information with product providers depends on the type of service you are receiving or requesting from us.
  • Purchasers/investors: We may share your information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who are stakeholders or investors in our business. 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 notice.
  • Advertisers and data exchanges: We may share your information with advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customised content and advertising to you when you visit 2plan websites.
  • Social Networks: Our websites and/or applications may also allow you to log in using a social network or other third-party account. Logging into one of our sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party.
  • Third Party IT System Suppliers who may host your data on their systems and may need some level of access to resolve technical concerns.

We will never sell or share your personal information with other organisations for their direct marketing purposes without your explicit consent. Except as provided for in this Notice, we will not provide your personal information to other third parties.

We require all third parties to respect the security of your personal data and to treat it in accordance with data protection laws. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Protecting your personal information

We are committed to protecting your personal information and implementing appropriate technical and organisational security measures to protect it against any accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

We store all your personal data in highly secure software systems and when we share your personal data with third parties we do so in a safe and secure manner.

When collecting or transferring special category data we use a variety of additional security technologies and procedures to help protect this information.

 

How long do we keep your data for?

We keep your personal data for as long as it is required by us:

  • To the extent that we are required to do so by law.
  • If we believe that the information may be relevant to any on-going or prospective legal proceedings.
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
  • For the purposes set out in “How we use personal information” section.

Personal data that we process for any purpose will not be kept for longer than is necessary for that purpose. Notwithstanding the other provisions of this section, we will retain your personal data to support as specified above (with due consideration for the rights and freedoms of individuals’ privacy).

Different purposes will have different retention periods. When determining retention periods for personal data we take consideration of the following:

  • Legal and regulatory retentions periods.
  • The on-going operational needs of 2plan.
  • Our contractual rights and obligations.
  • Our IT system capabilities and any restraints.
  • Costs associated with maintaining, securing and retrieving data.
  • The types of advice clients have received and the products they hold.

If you would like further details on this, then please contact us directly by using the details in the “how to contact us” section.

 

Your rights and how to contact us

Under Data Protection Law, you have a number of rights relating to your personal data. The rights available to you depend on our reason for processing your information. You have the following rights which can be applied in certain circumstances:

  • The right to be informed about how and why your data is being collected and used.
  • The right of access to your personal data and receive a copy of it.
  • The right to rectification where you believe any of your data to be inaccurate or incomplete.
  • The right to erasure of your personal data (also known as the right to be forgotten).
  • The right to restrict processing of your personal data.
  • The right to data portability (e.g. transferring your data to a third party in in a structured, commonly used and machine readable format).
  • The right to object to processing of your personal data (including profiling) based on 2plan’s legitimate business interests, such as for direct marketing.
  • The right to withdraw your consent to data being processed about you (where processing is on the basis of your consent).
  • The right to object to decisions being taken solely by automated means, including profiling and request a human review in relation to any decision made solely through automated processing.
  • The right to make a complaint to the Information Commissioner’s Office about your data being processed.

You have the right to ask Stephen Eve Financial Planning to view any information we hold about you and you can expect to receive a response from Stephen Eve Financial Planning Ltd. in line with the guidance laid down by the GDPR.

Any requests should be either emailed to danielle.slater@stephenevefinancial.com. and marked 'Subject Access Request' or put in writing and addressed to:

The Data Protection Officer
Stephen Eve Financial Planning Ltd.
12 Regent Street
Nottingham
NG1 5BQ
 

 

 

If you are unhappy about the use of your personal data, then please contact us directly and we will try our best to resolve your concern.

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority the Information Commissioners Office.

We regularly review our policies and any changes will be posted on our website.

If you have comments or any questions about our GDPR, Privacy & Cookies Policy please contact: danielle.slater@stephenevefinancial.com.

 

FCA contact information:
www.fca.org.uk
Helpline - 0800 111 6768

ICO contact information:
ico.org.uk
Helpline - 0303 123 1113

 

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