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’re Octopus Wealth, which is a trading name of Carib Planning Limited.
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|
33 Holborn, London
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.
Information we receive from other 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 Choice, 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 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. 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‘.
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
- 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.
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 and in any case for no longer than a year.
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 do any of these, please contact us at firstname.lastname@example.org
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 email@example.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 http://financial-ombudsman.org.uk.
Changes to this policy
When we change this document you’ll be able to find it the latest version here. We’ll also contact you about changes if we think you need to know about them.
Version 2.0 (March 2019)