Privacy Policy

The following policy sets out how we, Compare Wealth Managers Ltd (company registration number 13043592), (hereafter referred to as "CWM", "we", "us" or "our"), collect, store, and use information about you when you interact with our website, comparewealthmanagers.com, including any data you may provide when you utilise our service. This website is not intended for children, and we do not knowingly collect data on children.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we use your personal data. Please read it carefully. From time to time, changes may be made to this policy following review; in the case of alterations, this policy will be updated, and date stamped accordingly.

For clarification of some of the terms used within this policy, please refer to the glossary.

How to contact us

If you wish to make an enquiry regarding your data, you can contact us via the following details:

enquiries@comparewealthmanagers.com

+44 020 7046 6050

Swan Court, 11 Worple Road, London SW19 4JS

Or alternatively, you can use the contact form to Contact us.

We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than this should your request be particularly complex or if you have made a number of requests; should this be the case, we will notify you of this.

At our discretion, we may request to see a form of identification (for example a passport or utility bill) in order to confirm your identity prior to responding to a Subject Access Request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You 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 could refuse to comply with your request in these circumstances.

The type of information we collect

Contact Information

When you contact us through the contact details listed on the website, through the enquiry form, or via email, telephone or post, your contact details will be retained in accordance with your enquiry. This will include your name, email address and telephone number. We may also use your contact details to send you information about our services or to follow up on an enquiry you have made, in accordance with your marketing preferences.

We do not collect any special categories of data.

Financial Data

If you decide to engage our services, we will need to collect and use certain financial and personal information in order to understand your circumstances and to match you with suitable wealth managers. This may include (but is not limited to) information about your net worth, investments and assets, and your family situation. This information will be ascertained during an initial call with yourself, and may also be collected from the contact form, should you choose to provide this information in your initial enquiry. This information will only be used to find wealth managers that can provide tailored advice based on your situation.

Cookies

We use cookies and similar technologies on our website. Some cookies are strictly necessary to ensure the website functions properly. Others are used for analytical and statistical purposes to help us understand how visitors use our website. This information helps us improve the performance and usability of our website. Analytics data is used in an aggregated and anonymised form wherever possible.

We will only place analytics or other non-essential cookies on your device where you have given your consent. You can manage your cookie preferences at any time using our cookie banner or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

We use third-party tools, such as Google Analytics, to help us analyse website usage. These providers may process information about your use of our website on our behalf and in accordance with their own privacy policies. Where personal data is transferred outside the UK as part of these services, appropriate safeguards are used in line with data protection law.

For more detailed information about the cookies we use, including the types of cookies, their purpose and how long they are stored, please see our Cookie Policy.

Server Logs

IP addresses associated with visits to this website are recorded in server logs for the purposes of detecting and preventing fraud, unauthorised access, and other malicious activity. These logs are retained only for as long as necessary to fulfil these security purposes and are not used for marketing or profiling.

How we use your information

We use your personal information to operate our website and to provide our matching and introduction service.

Your contact details are used in order to process your enquiry, communicate with you about our services and enter into a contract with you.

If you decide to utilise our matching service, your financial and personal data will be used in order to understand your circumstances and requirements and to identify wealth managers whose services may be suitable for you. This processing is necessary to provide our service and does not involve us giving financial or investment advice.

As part of our service, we may share your contact and relevant financial information with one or more wealth managers in order to introduce you to professionals whose services may be suitable for your requirements. This sharing of information is a core part of how our service operates and is based on our assessment of the information you provide and your use of the platform.

In some cases, including where the value or complexity of your circumstances is higher, we may ask for your specific permission before passing your details to a wealth manager. In other cases, your information may be shared without a separate prompt, in line with this Privacy Policy and the way the service is described to you when you complete the questionnaire.

Where your information is shared with a wealth manager, that firm will act as an independent data controller in relation to any personal data it receives and will provide you with its own privacy information.

We may use your contact information to send you information about our services, including updates or follow-ups related to an enquiry you have made. Where required, we will only send marketing communications with your consent, and you can opt out of receiving marketing communications at any time.

We may use anonymised and aggregated website analytics data to understand how our website is used and to improve our services. We do not sell your identifiable personal data. Further information about how we use cookies and similar technologies is set out in the Cookies section of this policy and in our Cookie Policy.

Business Changes

Should we make a commercial change to the business, for example, choosing to sell, acquire or merge with another business, your data will be used for the same purposes as set out within this policy. Should any changes be made to our working practices, this policy will be updated accordingly, and data subjects will be informed in writing.

Lawful grounds for processing data

We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please refer to the below table in which we have determined the ways we plan to use your data, and the legal basis for doing so.

Purpose / Activity: Providing our matching and recommendation service

Type of Data: Contact and financial information

Lawful Basis: Performance of a contract / steps to enter into a contract

Purpose / Activity: Internal assessment and shortlisting of wealth managers

Type of Data: Financial and personal information

Lawful Basis: Legitimate interests

Purpose / Activity: Disclosure of your details to a selected wealth manager

Type of Data: Contact and financial information

Lawful Basis: Legitimate interests (and consent in some cases)

Purpose / Activity: Website analytics and performance

Type of Data: Technical data

Lawful Basis: Consent (where required) / legitimate interests

Purpose / Activity: Marketing communications

Type of Data: Contact information

Lawful Basis: Consent or legitimate interests (as applicable)

Data Retention

By law we must retain basic information about our customers (including contact, identity, and financial data) for six years after they cease being customers for tax purposes.

In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you fail to provide personal data

Where we need to collect personal data as determined by our contractual obligations, 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. In this case, we may have to cancel a service you have with us but would inform you of this in writing.

Data security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, altered, or disclosed. This includes performing regular data back-ups and only using systems that utilise robust security measures.

In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties you have a business requirement to access it. They will only process your personal data on our instruction and are subject to a duty of confidentiality.

Your rights

In accordance with the Data Protection Act (DPA) 2018, you have the following rights in relation to the personal data we may hold on you, namely:

• to access your information and to receive information about its use
• to have your information corrected and/or completed
• to have your information deleted
• to restrict the use of your information
• to receive your information in a portable format
• to object to the use of your information
• to withdraw your consent to the use of your information
• not to have significant decisions made about you based solely on automated processing of your information, including profiling;
• to complain to a supervisory authority.

Your right to complain

As a data subject, if you believe your data has been mismanaged, you have the right to make a complaint at any time to the UK supervisory authority for data protection, the Information Commissioner's Office (ico.org.uk). We would, however, appreciate the opportunity to deal with any concerns prior to this, so please contact us in the first instance.

We are registered with the ICO, registration number ZA845319.

Third-party links

This website includes links to third-party websites and applications. Clicking on those links may allow third parties to collect or share your data; we do not control these third-party websites and are not responsible for their privacy controls.

GLOSSARY

Data Subject

An individual whose personal data is collected.

Data Controller

A person or organisation which determines how and why personal data is processed. Compare Wealth Managers Ltd acts as a data controller in relation to the personal data it processes.

External third parties

When we introduce you to a wealth manager, that firm will act as an independent data controller in relation to any personal data it receives and will provide you with its own privacy information.

Legitimate Interest

Our interest in conducting and managing our business to enable us to give you the best service and most secure experience. We ensure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless permitted by law).

Personal data

Any information that may be used to identify an individual, directly, or indirectly; for example, an IP address, bank details, or surname.

This does not include data from which it is impossible to identify an individual (anonymous data).

Special Categories of Data

Special categories of data are classified as any of the following:

• personal data revealing racial or ethnic origin;
• personal data revealing political opinions;
• personal data revealing religious or philosophical beliefs;
• personal data revealing trade union membership;
• genetic data;
• biometric data (where used for identification purposes);
• data concerning health;
• data concerning a person's sex life or sexual orientation.

Special categories of data are considered sensitive and thus require further protection than other personal data.

Subject Access Request

Subject Access Request (SAR) is the formal term for a personal information enquiry made by a Data Subject to a Data Controller.

This could be a request to find out what personal data we hold on you, how it is being used, who it is being shared with, and so forth.

Website cookies

Cookies are small files that are stored on your device by your browser when you visit a website; necessary cookies help make a website useable by enabling basic functions such as page navigation, and the website cannot function correctly without them.

Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Cookies collection can be disabled within your browser settings.