Privacy Policy

You are here

Privacy Notice

Stonewood Wealth Management LLP (Stonewood) is a company registered in England and Wales with company number 613665. Stonewood is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 613665.

For the purposes of the General Data Protection Regulation (‘GDPR’), Stonewood will be the ‘controller’ of the personal data you provide. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data. Should you have any questions, please email us at sean@stonewoodwealth.com.

 

What data privacy principles does the Firm adhere to?

  • The Firm will process all personal data in a lawfully, fair and transparent manner;
  • The Firm will only collect personal data where it is necessary;
    • For the Firm to provide a service to you;
    • For you to provide a service to the Firm;
    • For the Firm to keep you informed of its products and services; or
    • For the Firm to comply with its legal and regulatory obligations.
  • The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
  • The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
  • The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
  • The Firm will hold and process person data in a manner that ensures appropriate security;
  • The Firm will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
  • The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.

 

What personal data does the Firm collect and why?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence).

As a client, contact or employee of Stonewood, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations whereas other information may be required in connection with the provision of services to you). The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

  • Personal information: Such as your name, date of birth, passport number or national insurance number;
  • Contact information: Including your address, telephone number and email address.

 

Where does the Firm store my personal data?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:

  • Data encryption;
  • Firewalls;
  • Intrusion detection;
  • 24/7 physical protection of the facilities where your data is stored (i.e. Microsoft’s UK data centres);
  • Background checks for personnel that access physical facilities; and
  • Security procedures across all service operations.

 

How long does the Firm retain personal data?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe. 

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

 

How have I been categorised in accordance with GDPR?

The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:

  • Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
  • Service providers – Information is maintained on the basis of contractual obligation; and
  • Database/marketing contacts – Information is maintained on the basis of legitimate interest.

 

What are my rights?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

  • You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at sean@stonewoodwealth.com. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
  • You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
  • As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
  • You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact sean@stonewoodwealth.com.
  • You have the right to object to your information being processed, for example for direct marketing purposes.
  • You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
  • You have the right to object to any decisions based on the automated processing of your personal data, including profiling. 
  • You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/  if you are not happy with the way that we manage or process personal data.

 

Will I be notified of changes to this policy?

The Firm may, from time to time, review and update this policy. The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.

 

Who should I direct questions to?

If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data you should contact our data protection representative the contact details for whom are provided below.

Sean Patterson

Stonewood Wealth Management International Limited, Suite 3, 2 Grange Place, St. Peter Port, Guernsey GY1 2QA

sean@stonewoodwealth.com

 

We will endeavour to resolve the issue as soon as possible. In the event you remain dissatisfied, and in any case, you have the right to complain to the Office of the Data Protection Commissioner, whose contact details are set out below:

Office of the Data Protection Commissioner

St. Martin’s House, Le Bordage, St. Peter Port, Guernsey GY1 1BR

Tel: +44 1481 742074

Email: enquiries@odpa.gg

You may also have the right to complain to the relevant data protection authority in the jurisdiction in which you reside.

 

Cookies

Cookies are small files located in browser directories that are used to help users navigate websites efficiently and perform certain functions. You can choose to refuse cookies or tell your browser to notify you each time that a website tries to set a cookie. However, refusing cookies may mean some sections of the site will not work properly. For more information about cookies (including how to turn them off) please visit: https://www.allaboutcookies.org/

We use cookies to monitor and improve the functionality and user experience of our website. Details of the cookies we use are as follows:

Salesforce Pardot: Pardot tracks visitor and prospect activities on your website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to your site. Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.

Pardot sets first-party cookies for tracking purposes and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets first-party cookies on your tracker subdomains and Pardot domains. Pardot uses third-party cookies on https pages and when your account doesn’t have a tracker subdomain set up.

Pardot sets three kinds of cookies:

i. The visitor cookie is composed of a unique visitor ID and the unique identifier for your account. For example, the cookie name “visitor_id12345” stores the visitor value “1010101010”, and “12345” is the account identifier. This cookie is set for visitors by the Pardot tracking code;

ii. If your account tracks opt-in preferences, the pi_opt_in cookie is set with a true or false value when the visitor opts in or out of tracking; and

iii. A session cookie named “pardot” is set when you’re logged in as a Pardot user. This cookie isn’t set on a visitor’s browser.

You can learn more about Pardot here: https://www.pardot.com/

  1. Google Analytics: further details of Google Analytics can be found here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage; and
  2. Google recaptcha: recaptcha uses cookies to validate that you are a real user when submitting a form on the site, and not an automated bot. You can learn more about recaptcha here: https://www.google.com/recaptcha/intro/v3.html

Updates to this Privacy Notice

Stonewood may amend this Privacy Notice at any time without notice, in which case this date will be revised and any changes made available to view on request. Updated copies will in any case be provided via a circular and via the website.

Updated April 2021