BroadLeaf Assist Limited (we, us or our) respect your privacy and are committed to protecting your personal data. This privacy notice will provide you with information about how we look after your personal data when you engage our services, or visit our website (regardless of where you visit it from). It will tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide through, or as a result of your use of our website, when you contact us, or where we are providing any service to you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements those other notices and is not intended to override them.
For the purpose of data protection laws in the UK, BroadLeaf Assist Limited is the data controller and is therefore responsible for your personal data.
If you have any questions, including any requests to exercise your legal rights, in the first instance please contact us using the details set out at the bottom of this privacy notice.
The personal data we collect
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Personal data does not include data where your identity has been removed or which is not associated with or linked to your personal data (anonymous data).
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific page of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Please note that where we need to collect personal data by law, as required by a regulator or under the terms of a contract we have with you 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 (for example, to provide you with services that you request). In this case, we may have to cancel a service you have requested but we will notify you if this is the case at the time.
How we collect personal data
We use different methods to collect data from and about you including through:
o Identity, Contact, and Investment Data from wealth management service providers, bond administrators and pension platforms you have engaged or who are engaged in respect of your bonds, pensions or other investments based inside or outside the UK;
o Identity and Contact Data from your employer or any business who you are representing or acting on behalf of;
o Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK.
The purposes for which we use personal data
We will only use your personal data when the law allows us to. We may collect and process the personal data about you for the following purposes:
We may also use personal data which you provide to us, where the law allows us to do so, as follows:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Where we process personal data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service with the best outcome and the best and most secure experience. We make sure we 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 we have your consent or are otherwise required or permitted to by law, including compliance with our regulatory obligations). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
We will only use your personal data for the purposes for which we 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. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. This may include removing you from our marketing database where there has been no interaction between us over a prolonged period.
Disclosure of personal data to third parties
Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:
We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect. In addition, the access to and use of the personal data that we collect is restricted to our employees who need the personal data to perform a specific job role or activity. Where personal data is shared with third parties in line with this privacy notice responsible measures are used to protect your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet.
The United Kingdom was, until recently a member of the European Economic Community has in place provisions for the protection of personal data which are comparable with those of the European Economic Area. It may be necessary from time to time for us to transfer your personal data outside the UK and the European Economic Area (“EEA”).
Whenever we transfer your personal data out of the United Kingdom and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have the right to:
If you wish to exercise any of your above rights, please send a written request to our UK representative at the address listed at the end of this privacy notice.
You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Other websites and links
Our website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third party websites and are not responsible for their privacy notices or for the content, accuracy or opinions express in such websites. We do not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by us of the linked website.
If you decide to leave this website and access these third-party websites, plug-ins and/or applications you do so at your own risk. We encourage you to read the privacy notice of every website you visit.
Changes to this privacy notice
This version was last updated March 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our full contact details are:
BroadLeaf Assist Ltd.
PO Box 5099, Maidenhead, Berkshire,
United Kingdom SL60 1PG
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.