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Privacy Policy

This Privacy Policy explains how we collect, use, and protect your personal information in compliance with UK data protection laws and FCA regulations.

Last updated: January 2025

Effective date: January 2025

1. Introduction

This Privacy Policy applies to all personal data processing activities carried out by our company in connection with our regulated financial services. We are committed to protecting and respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Financial Conduct Authority (FCA) data protection requirements.

As a financial services firm authorized and regulated by the Financial Conduct Authority, we are required to collect and process certain personal information to comply with our regulatory obligations and provide you with our services.

We are the data controller for the personal information we collect about you. This means we are responsible for deciding how and why your personal information is used.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

  • Identity information: name, title, date of birth, nationality, photographs
  • Contact information: address, telephone numbers, email addresses
  • Financial information: income, assets, liabilities, investment experience, risk tolerance
  • Professional information: employment details, business interests
  • Technical information: IP addresses, browser types, device information
  • Documentation: copies of passports, driving licences, utility bills, bank statements

2.2 Special Categories of Personal Data

We may process special categories of personal data (such as health information) where necessary for regulatory compliance or with your explicit consent.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Regulatory Compliance

  • Customer due diligence and know your customer (KYC) requirements
  • Anti-money laundering (AML) and counter-terrorism financing checks
  • Regulatory reporting and record-keeping
  • Compliance with sanctions and restrictions

3.2 Service Provision

  • Providing investment management and advisory services
  • Conducting suitability assessments and risk profiling
  • Portfolio management and reporting
  • Transaction execution and settlement
  • Client communications and relationship management

3.3 Business Operations

  • Risk management and internal controls
  • Business planning and analysis
  • System security and fraud prevention
  • Training and quality assurance

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

Legal Obligation

To comply with regulatory requirements including FCA rules, AML regulations, and tax obligations.

Contractual Necessity

To provide the financial services you have requested and fulfill our contractual obligations.

Legitimate Interest

For business operations, risk management, and fraud prevention, where balanced against your rights.

Consent

Where you have provided explicit consent for specific processing activities.

5. How We Share Your Information

We may share your personal information with:

Regulatory Bodies

FCA, HMRC, and other regulatory authorities as required by law

Service Providers

Third-party service providers who assist us in delivering our services, subject to strict confidentiality agreements

Professional Advisors

Lawyers, accountants, and other professional advisors bound by professional confidentiality

Market Counterparties

Investment platforms, custodians, and other financial institutions necessary for service provision

Important Note

We never sell your personal information to third parties. All sharing is done in accordance with applicable laws and regulations.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

Technical Measures

  • Encryption of data in transit and at rest
  • Secure network infrastructure
  • Regular security updates and patches
  • Multi-factor authentication
  • Regular security assessments

Organizational Measures

  • Access controls and user permissions
  • Staff training on data protection
  • Data breach response procedures
  • Regular compliance audits
  • Secure disposal of information

7. Data Retention

We retain your personal information for as long as necessary to:

Retention Periods

Client records 6 years after relationship ends
Transaction records 5 years from transaction date
Marketing consents Until withdrawn
Regulatory records As required by law

8. Your Rights

Under UK GDPR, you have the following rights:

Right of Access

Request copies of your personal information

Right to Rectification

Request correction of inaccurate information

Right to Erasure

Request deletion of your personal information

Right to Restrict Processing

Request limitation of processing activities

Right to Data Portability

Request transfer of your data to another provider

Right to Object

Object to processing based on legitimate interests

Important Limitations

Some rights may be limited by regulatory requirements. We will advise you of any restrictions when you make a request.

9. Contact Us and Complaints

For any questions about this Privacy Policy or to exercise your rights, please contact us:

Data Protection Officer

Email: dpo@northpropertyltd.co.uk

Phone: +44 (0) 20 1234 5678

Address: Data Protection Officer, Your Company Name, Address Line 1, Address Line 2, City, Postcode

Right to Complain

You have the right to complain to the Information Commissioner's Office (ICO) about our processing of your personal data. Visit ico.org.uk for more information.

10. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make changes, we will:

  • Update the "last updated" date at the top of this policy
  • Notify you of significant changes via email or prominent notice on our website
  • Provide you with a reasonable period to review the changes
  • Obtain your consent where required by law

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your personal information.