Privacy Policy
A quick summary
We collect personal information and usage data in various ways to help us deliver the best possible financial plan for your future. We share this data with select third parties to help us achieve this, and not for any other reason.
Who are we?
We are NOVA Wealth.
We take your privacy seriously.
If you have any questions about this policy or need to get in touch with us, you can do so by:
Phone
+44 (0)20 7390 0222
Post
NOVA Wealth
20 Farringdon Street, London
EC4A 4AB
Email
ask@novawm.com
We're registered with the Information Commissioner's Office under number ZA288484
What information do we hold about you?
Information or documents you give to us during our conversations or online:
- For example, information you provide while becoming our client (like your name, date of birth and email address)
- The contents of our advice conversations and reports, which are always recorded and kept for future reference
- Copies of your passport, driving licence or other official documentation so that we can verify your identity
- If you give us 'sensitive' information (for example, details about your health), we'll only use it in strict accordance with the law.
Details about you and your family's financial position and history, given to us by you or a third party (such as solicitors, accountants or financial services providers):
- For example, information about existing and previously held investments, pensions and other financial products
- Information about your income, expenditure, employment status and credit status
- Information about your bank details and payment information.
If you are a trustee working with one of our customers, we may hold information you give us to enable us to verify your identity and run anti-money laundering checks, both initially and on an ongoing basis to satisfy regulatory and compliance requirements:
- Personal details about your identity (like your name, date of birth)
- Contact details for you (like your address, phone number and email address)
- Copies of your passport, driving licence or other official documentation so that we can verify your identity
If you are a director of a company that employs one of our customers (or are a co-director of a customer), we may hold information you give us to enable us to verify your identity and run anti-money laundering checks, both initially and on an ongoing basis to satisfy regulatory and compliance requirements:
- Personal details about your identity (like your name, date of birth)
- Contact details for you (like your address, phone number and email address)
- Copies of your passport, driving licence or other official documentation so that we can verify your identity
Information we receive from companies within the Octopus Group, provided you agreed with them that they can share it:
- For example, if you are a customer of Octopus Energy or Octopus Money, we might hold your name and contact details.
Information on how you use our online services, including our website:
- For example, the IP address of the devices you use to access our services and other technical usage data.
Cookies
- Our website uses cookies, and you accept this when visiting our website and using our online services. This refers to small text files used to store information in web browsers. Other technologies, such as data stored on your device, identifiers associated with your device, and other software, are used for similar purposes.
- Cookies help us improve our website and give users a great experience. We use them to keep track of how often users come to our website and see how they interact with it using Google Analytics.
- We use some cookies for remarketing purposes and, if you agree, will used them to send you tailored advertisements.
- Certain cookies may also be placed as a result of engaging with our advertisements on third party sites. Please review the cookie policies on third party sites to see how they are using and implementing cookies on your browser.
- Hotjar is also present throughout our site, which helps us understand users' experience and better serve them in the future.
If you wish to block cookies, you can do this in your browser's settings. Alternatively, just search 'how to block cookies'. You can opt out of Google's re-marketing features here.
How do we use your information?
To fulfil our agreement to provide you with our services. We use it to:
- Produce completed versions of your Lifeline and personal financial plan, and keep them up to date
- Provide you with additional financial advice if you ask us to
- Help intermediate financial transactions you are undertaking
- To let you know of any updates or changes to our services that we think you need to know about.
To fulfil our legal obligations. We use it to:
- Search third-party data sources in order to verify your identity and prevent fraud
- Help combat financial crime.
Where it's in our 'legitimate interest' to do so (meaning our use of your information is in our's or your's interest and does not override your privacy):
- To help keep security and training standards high
- To monitor and record the advice we give so that we can ensure quality and investigate complaints
- To analyse how our clients use our services so that we can improve them.
With your permission. We use it to:
- Provide you with information about other products or services offered by us or another company within the Octopus Group (such as Octopus Energy or Octopus Investments).
Who do we share it with?
We may share your personal information with:
- Anyone who works for us if they need it to do their job.
- Any organisation which supports us in providing you with our services, if they need it to offer you those services. This includes:
- Investment firms (such as fund managers), insurers, insurance or credit brokers and similar organisations who offer financial products
- Providers of third party data sources to verify your identity and prevent fraud (such as TransUnion)
- Providers of financial planning, content management or productivity software and tools.
- Any organisation which you disclose to us that might hold information about your investments, pensions and other financial products or anything else we might need to know about. This includes:
- Your existing providers
- Your current and past employers
- Government departments
- Other persons or organisations we believe may help us.
- Anyone who you give us permission to share it with.
We'll also share it to comply with the law; to enforce agreements between us; or to protect the rights, property or safety of us, our clients or third parties.
One of the key third party providers we use to verify your identity and prevent fraud is TransUnion International UK Limited. More information about TransUnion and the ways in which it uses and shares personal information can be found in its privacy notice at: https://www.transunion.co.uk/legal/privacy-centre.
How long do we keep it for?
If you become a client, we'll keep your data for as long as you're with us, and for five years after that to make sure we comply with our legal obligations. In some cases we might need to keep it longer, for example if we're conducting investigations or if the law says we have to.
If you aren't a client, we'll delete your information when we're no longer using it.
External links and third party sites
You may find links to (and similarly from) external third party sites, some of which may include our advertising and distribution partners.
We cannot accept and responsibility of liability for the content or programs running on such third party sites. Please refer to the third party's terms of use and privacy and cookie policies before using and/or providing any information to or via their sites or apps as they may process your personal data for their own purposes.
What are your rights?
You have the right to:
- Access your personal data and request a copy of it
- Ask us to amend information for accuracy
- Request that we delete your personal data (please note that for legal reasons we might not be able to do this)
- Withdraw any consent you've previously given us.
To take any of these actions, please contact us at ask@novawm.com
Where is your data stored?
The data we hold might be transferred and stored somewhere outside of the European Economic Area (EEA). The people who work for us or third parties we work with outside of the EEA might also process the data. We may share data with organisations and countries that:
- The European Commission say have adequate data protection rules and laws
- We've agreed specific data protection clauses with.
How to make a complaint
If we've made a mistake or you aren't happy with our services, we'd like the opportunity to try and put it right. We take all complaints seriously and try to resolve them quickly. Please contact us at complaints@novawm.com.
If you're not happy with how we've handled your complaint, you can contact the Financial Ombudsman Service. You can find out about and contact them by visiting the Financial Ombudsman.
Changes to this policy
When we change this document you'll be able to find the latest version here. We'll also contact you about changes if we think you need to know about them.
Version 2.5 (January 2024)