INDIVIDUAL BUSINESS ABOUT CONTACT UKUS Data protection and privacy notice Who are we? We are Bartlett Group (Holdings) Limited (company registration number 00945137) and subsidiary companies (referred to as “Bartlett”, “we”, “us” or “our”). Our address is Broadway Hall, Horsforth, Leeds, LS18 4RS). We are the providers of the following websites: www.bartlettgroup.com, www.arborisk.co.uk. In the UK, Bartlett group companies are registered with the Information Commissioner’s Office as Data Controllers with the following registration numbers: Bartlett & Company Limited Z8268752 Bartlett Wealth Management Limited Z826877X We are committed to protecting and respecting your privacy. This Notice explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. We will process your personal information on the basis of “Legitimate Interests” and “Explicit Consent” (as defined by the Data Protection Act 2018 in the UK or the General Data Protection Regulation in the EEA). What is Personal Data? Personal data is information which relates to an individual and from which he or she can be identified either directly or indirectly through other data which the firm has or is likely to have in its possession. These individuals are sometimes referred to as data subjects. Personal data does not include information about companies and organisations. How do we collect information from you? We obtain information about you when you use our websites, contact us about products and services or engage with us to renew existing products or services. We may also collect data, with your consent via a letter of authority, from your existing product providers. Where relevant, we also collect sensitive personal information such as details regarding your health, credit history and/or criminal convictions. To ensure we carry out your instructions accurately and to help us to continually improve our service, we record and may monitor your telephone communications or conversations with us. We also work with third parties including regulators and business partners. We may receive information about you from them. Recording Telephone Calls To ensure we carry out your instructions accurately, to help us to continually improve our service and in the interests of security, we will record and may monitor your telephone communications or conversations with us. Copies of our telephone recordings will be retained indefinitely in line with the Bartlett Group Data Retention Policy (see ‘Data Retention’). How will we use the information about you? We will use your personal information to administer your account and to provide the products and services you have requested from us, to provide advice to you and to complete transactions on your behalf. We analyse and assess your data in order to maintain the suitability of our advice and provide you with ongoing services. We may share your information with, and obtain information about you from, credit reference agencies or agencies responsible for the prevention of fraud and financial crime. Information provided by you may be put onto a register of claims and shared with other insurers to prevent fraudulent claims. Any information you give to us, including sensitive personal data such as health and medical records, may be disclosed to selected third parties for the purposes of finding the best available product for you and for processing any application you make. We will disclose information held about you to insurance companies, other product and platform providers, researchers, compliance consultants and other professional advisors or anyone we may engage to process your application or provide professional services to you on our behalf. We may be required to share your information with regulatory authorities and/or fraud prevention agencies, to meet our responsibilities under the law. We will use your information to notify you of changes to our services which are necessary and relevant to the products you have with us along with information and communications in relation to additional products we feel may of interest. We will send you marketing communications subject to appropriate consent being provided. We will seek your views or comments on the services we provide. We will not share your personal information with any companies outside the Bartlett Group for the purposes of marketing. Data Retention We will retain your data in line with the Bartlett Group Data Retention Policy. We have different retention periods dependant on the requirements of each business division. We can provide details of specific retentions periods relevant to your data. Please submit all requests to dataprotection@bartlettgroup.com. Use and storage of your information overseas Your information may be transferred to, stored and processed outside, the United Kingdom or European Economic Area (EEA). We will not transfer your information outside the UK or the EEA unless it is to a country which is considered to have equivalent data protection laws or where we have taken all reasonable steps to ensure the firm has suitable standards in place to protect your information. Transfers between the UK and the EEA are subject to Standard Contractual Clauses (SCCs) between the relevant parties. Your Choices Your personal information may be accessed by companies within the Bartlett Group to provide information regarding services we offer. You have a choice about whether or not you wish to receive information from us. If you do not want to receive marketing communications from us about the work we do for other clients and information about our products and services, please ensure that your preferences are provided to your Bartlett representative. You can change your marketing preferences at any time by contacting us by email or directly contacting the Bartlett representative who deals with your insurances: Bartlett Group Ltd Broadway Hall Horsforth Leeds LS18 4RS Telephone Number: +44 (0)845 605 4155 Email: dataprotection@bartlettgroup.com Your Rights You have the right to request deletion of information where: Personal data is no longer necessary in relation to the purpose for which it was originally collected and processed. You are withdrawing your specific consent. You object to the processing of the data and there is no overriding legitimate interest for continuing the processing. The personal data was unlawfully processed. The personal data has to be erased in order to comply with a legal obligation. The request to delete your personal data can be refused; should this situation arise we will provide you with the specific rationale to support the decision. You have the right to restrict processing of personal data under the following circumstances: If there is any discrepancy in respect of your personal data, we will restrict the processing until we have verified the accuracy. If there is any individual objection to the processing of personal data if data processing isn’t being carried out for the original purpose(s) for which it was collected. If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim. Access to your information and correction You have the right to access information we hold about you. You can request a copy of these records by contacting our Head Office. If any of the information we hold is incomplete or inaccurate, please tell us and we will correct it. Contact details are as follows: Bartlett Group Ltd Broadway Hall Horsforth Leeds LS18 4RS Telephone Number: +44 (0)845 605 4155 Email: dataprotection@bartlettgroup.com We will endeavour to provide you with requested information within 1 month. We can impose a charge for this information if the request is manifestly unfounded or excessive. If we do refuse a request, we will advise you accordingly within 1 month. If this eventuality did arise you have the right to complain. Please refer to our complaints procedure within the website for details. In addition, without prejudice you have the right to lodge a complaint direct to the relevant Data Protection Authority (DPA). If you are a UK resident or if your complaint relates to a Bartlett UK company, please contact the Information Commissioner’s Office (ICO). The details are listed below for your information: https://ico.org.uk/concerns/ ICO Helpline: 0303 123 1113 If your complaint relates to Bartlett & Co. GmbH, you may contact the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (‘the Hamburg Commissioner for Data Protection and Freedom of Information’). The details are listed below for your information: https://datenschutz-hamburg.de/ Tel: 040/428 54 – 4040 EEA residents outside of Germany may also contact their national DPA. Our liability to you Security precautions are in place to protect the loss, misuse or alteration of your information. When you provide us with personal information, we take steps to ensure that it’s treated securely. Any sensitive information such as credit or debit card details are encrypted to ensure its protection. Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Changes to our Data Protection and Privacy Notice We may change this Notice from time to time so please check our website occasionally to ensure that you are happy with any changes. This Notice was last updated in January 2021. Third Party Website Links Our website may contain links to other websites run by other organisations. This Data Protection and Privacy Notice applies only to our website‚ so we encourage you to read the privacy statements on any other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. We do not endorse the content of any external sites and we are not responsible or liable, directly or indirectly, for any loss however caused to you by your use of any external site. Miscellaneous The information on our website is for residents of the UK and EEA only. These Terms shall be governed by and construed in accordance with English law and the English courts shall have jurisdiction over any disputes between us. Contact Us Any questions regarding this Notice and our privacy practices should be sent by email to dataprotection@bartlettgroup.com or alternatively please contact at: Bartlett Group Ltd Broadway Hall Horsforth Leeds LS18 4RS Telephone Number: +44 (0)845 605 4155 UKUS Head Office The Bartlett group Broadway Hall Horsforth Leeds LS18 4RS Tel: 0345 605 4155 Email: mail@bartlettgroup.com Data protection and privacy notice Cookie policy Complaints procedure Bartlett Group (Holdings) Limited incorporated and registered in England and Wales. Registered address: Broadway Hall, Horsforth, Leeds. United Kingdom. LS18 4RS. Registered in England & Wales under company registration number 00945137. Bartlett Group (Holdings) Limited is a holding company. Bartlett & Company Limited and Bartlett Wealth Management Limited are authorised and regulated by the Financial Conduct Authority (FCA). Bartlett & Co. GmbH is registered with the Hamburg Chamber of Commerce and accordingly entered in the broker register as an insurance broker with a permit according to § 34 d Paragraph 1 of the Industrial Code under registration number D-0767-L4J4W-03. Bartlett Group companies may also undertake non-regulated activities including tax planning and risk management consulting. © Bartlett Group 2017