Privacy Policy

This privacy policy is for the website: www.reflectparaplanning.co.uk and is brought to you by Reflect Paraplanning. It governs the privacy of its users who choose to use it and the services of Reflect Paraplanning. We take the privacy of our website users and clients very seriously. We ask that you read this Privacy Policy (‘the Policy’) carefully as it contains important information about how we will use your personal data.

For the purposes of the Data Protection Act 1998, Reflect Paraplanning (‘we’ or ‘us’) is the ‘data controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).

Personal data we may collect about you

We will obtain personal data about you (such as your name, address and contact information whenever you complete an online form). We also hold information as a data processor when you engage us for financial planning services, this information will relate to personal and financial circumstances gathered by the Data Controller.

It can also include information which either you give to us about your clients or which we obtain about your clients on your behalf. It may also include special categories of personal data such as data about health, if this is necessary for the provision of our services. This data shall only be used for the benefit of providing the services agreed between the two parties.

Reflect Paraplanning will approach third party institutions, on your behalf, to obtain information relating to your Client’s financial arrangements; provided you have obtained the necessary authority from the Client concerned, and you have given us express permission to do so. Reflect Paraplanning shall not involve any other third party in the processing of the Data without the consent of the Data Controller. If consent is given a further processing agreement will be required with the Third Party.

Reflect Paraplanning agree to fulfil the Data Controllers’ obligation to respond to requests from individuals exercising their rights laid down in Chapter III of GDPR – rights to erasure, rectification, access, restriction, portability, object and right not to be subject to automated decision making etc

Reflect Paraplanning will assist the Data Controller in ensuring compliance with the obligations pursuant to Articles 32 to 36 of GDPR  security, notification of data breaches, communication of data breaches to individuals, data protection impact assessments and when necessary consultation with the ICO.

We may also gather data from the use our website ‘contact us’ form to enquire about products and services or register to receive one of our newsletters.

Sharing your personal information

Reflect Paraplanning will only share your personal data where data protection law allows it, with adequate protection and where appropriate will have contracts in place to protect the security and confidentiality of your data for the following purposes:

• To provide you with the information, products and services that you have requested from us.
• To meet a legal or regulatory obligation.
• To marketing our own products and services by mail and email in accordance with your communication preferences

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer Personal Information to the third party.

When we use third party service providers, we disclose only the personal information that is necessary to deliver the service agreed.

The external Data Processors we use are and the type of information processed:

• Dropbox – we use Dropbox to securely share files and documents that may contain client data, in accordance with our agreed service.
• PPOL Calcs – we use this for calculations and cashflow planning. We enter only the data relevant to undertaking the agreed task.
• Genovo – we use this to produce suitability reports and may add client specific data as required to write a compliant report.

We may also use systems and tools as directed and owned by you. In this instance you are responsible for ensuring compliance with your own Privacy Policy and Reflect Paraplanning shall undertake the work as if acting solely on your behalf as a member of your firm.

Please note that the Privacy & Security policies of the processors are aimed at the controllers who use them and may be updated.

We will not sell or distribute your personal data to other organisations without your approval.

Your rights

You have the right, subject to the payment of a small fee (currently £10) to request access to personal data which we may possess about you. If you wish to exercise this right you should:

• put your request in writing
• include proof of your identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill)
• attach a cheque in the amount of £10 made payable to Reflect Paraplanning and specify the personal data you want access to, including any account or reference numbers where applicable.

You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right you should:

• put your request in writing
• provide us with enough information to identify you
• specify the information that is incorrect and what it should be replaced with.

You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right you should:

• put your request in writing (an email sent to jessica@reflectparaplanning.co.uk with a header that says ‘Unsubscribe’ is acceptable)
• provide us with enough information to identify you
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel (eg email or telephone) please specify the channel you are objecting to.

Storing this information

We hold a person’s data under Legitimate interest and will be held for as long as you remain a client of Reflect Paraplannning and require us to continue within the original client terms of engagement. Due to the nature of the service we offer, it may be required for us to retain personal data even after an account has been closed for legal or operational reasons under the guidance of the FCA.

You have a right to challenge our legitimate interest if you believe we do not have a valid reason to collect, use, share or hold your data. You can withdraw your consent at any time.  If you withdraw your consent for marketing you may miss out on information about our products, services, offers and other news that may be of interest to you.  We will however continue to contact you regarding the administration of your existing accounts and relationship with us.

Keeping your data secure

We will use technical and organisational measures to safeguard your personal data. All the data that we collect and store on a cloud based server is encrypted. Such servers are located either in the EEA or US. If this is a US based server, this will be covered by the EU-US Privacy Shield.

Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.

Transfers of data out of the EEA

We may need to transfer your personal data outside the European Economic Area. Any transfer of your data will be undertaken subject to appropriate security measures to safeguard your personal data.

Our contact details

We welcome your feedback and questions. If you wish to contact us, please send an email to jessica@reflectparaplanning.co.uk or you can write to us at 1 Netherby Gardens, Bracknell, Berkshire, RG12 7GQ or call us on 07850 629227.

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you access this website.

Use of Cookies

We may monitor your use of this website through the use of cookies and similar tracking devices, and this is confirmed in our ‘Cookie Policy’ available on the site. For example, we may monitoring how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on “Cookie Policy” below.

Occasionally we may receive information about you from other sources which we will add to the information which we already hold about you in order to help us improve and personalise our service to you.

Cookie Policy

What are cookies?

This website uses cookies to collect information. Cookies are small data files which are placed on your computer or other mobile or handheld device. This includes information about pages viewed and the visitor’s journey around our website. We do not, however, use cookies to collect or record information on users’ name, address or other personal details. Reflect Paraplanning are able to monitor individual visitor browsing behaviour but third parties are not able to identify users using cookies.

Who sets the cookies?

The cookies stored on your computer or other device when you access this website are set by Reflect Paraplanning and our suppliers who partner with us to help deliver a high quality website and online experience.

How do you disable cookies?

 If you want to disable cookies you need to change your website browser settings to reject cookies however doing so will mean loss of certain functionality on this website. How to disable cookies from your device will depend on the browser you use, here’s how to do it on the most popular Windows PC browsers:

Microsoft Internet Explorer:

1. Choose the menu “Tools” then “Internet Options”
   2. Click on the “Privacy” tab
   3. Select the appropriate setting

Mozilla Firefox:

1. Choose the menu “Tools” then “Options”
   2. Click on the icon “Privacy”
   3. Find the menu “Cookie” and select the relevant options

Opera 6.0 and above:

1. Choose the menu “Files” then “Preferences”
   2. Click Privacy and select one of the available options.

What happens if I disable cookies?

This depends on which cookies you disable, but in general the site may not operate properly if cookies are switched off

What sorts of cookies do Reflect Paraplanning use?

Analytics Cookies

This website uses a web analytics service provided by Google, Inc.(‘Google’). Cookies are used to collect information about how visitors use our site; they do not contain any personal information.

We use the information to compile reports and to help us improve the site and user experience. Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page.

For more information regarding Google Analytics and your data privacy please visit: http://www.google.com/analytics/learn/privacy.html

It is possible to opt out of Google Analytics tracking on all websites you visit by installing an add-on to your browser. The Google Analytics Opt-out Browser Add-on is available for Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera. The add-on can be downloaded here: https://tools.google.com/dlpage/gaoptout