We are committed to protecting and respecting your privacy.

As part of this commitment, we want you to know our principles and practices for collecting, using, storing, and disclosing your personal information.

Please read this notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information generally, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Succession Wealth Management Limited is part of the Aviva group of companies and is authorised and regulated by the Financial Conduct Authority.

Succession Wealth Management Limited is the company responsible as ‘controller’ of your personal information, registered in England (company number 07882611. Registered office address: The Apex, Brest Road Derriford Business Park, Derriford, Plymouth, United Kingdom, PL6 5FL. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number: 588378.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the UK General Data Protection Regulation and responsible as ‘controller’ for that personal information. Our Data controller registration number is ZA005958.

Scope

This notice relates to all data subjects whose personal information is processed by Succession Wealth Management Limited. Please refer to our Website Privacy Policy for information on how personal information is processed in relation to your use of our website.

Our collection and use of your personal information

When we mention “we”, “our” or “us”, we mean the relevant company in the Succession group that processes your personal information.

We use different methods to collect personal information about you when you enquire about or use one of our services.

This information may be provided by you directly. You may give us your personal data and special category data (see below in this notice) by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide either directly or via one of our Financial Planners, when you apply for products or services or when you enquire about becoming a potential client of ours or complete a fact-find for this purpose. When you provide one of our Financial Planners with your special category data as part of enquiring about becoming a client of ours, we will require you to complete a Data Processing Consent Form to confirm that you give your explicit consent to us processing that special category data about you.

We may also obtain or receive personal information about you from various third parties and public sources, including:

• Third parties involved in the relevant product or plan, including product providers, financial advisers, trustees, banks and other financial institutions, e.g. mortgage brokers;

• Healthcare providers and medical practitioners;

• Your attorney acting under a power of attorney or nominated representative;

• Legal advisers, accountants, auditors and professional services firms who act on our or your behalf or on behalf of your employer (past and current);

• Service providers in relation to the relevant product or plan, including experts, property surveys, valuations and, in limited circumstances, private investigators;

• Aviva group companies who may provide information in relation to services you have requested from us or other Aviva products or services you or people you live with hold, including previous claims, policies or quotes;
  Credit reference agencies;

• Financial crime detection agencies, databases and sanctions lists;

• Government agencies and regulatory bodies, including the police, the courts, the Office for National Statistics, Companies House and HM Revenue & Customs (HMRC);

• Regulators who regulate how we operate, including the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and Financial Ombudsman Service (FOS);

• Third parties who provide us with details of individuals who have expressed an interest in hearing about products;

• Third parties that help us maintain the accuracy of our data, e.g. by identifying individuals who are deceased, updating contact details for individuals who have moved;

• Other third party suppliers, including actuaries, auditors, legal advisers and other professional services firms and sanctions-checking service providers;

• Providers of marketing and advertising services;

• Data suppliers;

• Publicly available sources, including the Office for National Statistics (e.g. census data) and other data made available under the Open Government Licence, internet searches, news articles, online marketplaces and social media sites, apps and networks (e.g. Twitter, Facebook and Instagram);

• Third parties in connection with any acquisition of a business by us.

Our use of your personal information

We are committed to ensuring that the personal information we collect and use is appropriate and does not constitute an invasion of your privacy.

We may process both manually and by electronic means your personal information including details of your name, address, date of birth, nationality, your marital status and details of your spouse or partner and dependents, your health and lifestyle, your employment status, your income and expenditure, property, investments, pensions and liabilities, your bank details, your tax status and other associated tax details, any previous bankruptcy or insolvency, any life assurance you hold or inheritance tax plans, details of your will, powers of attorney or other legal documents, any identity verification documentation or any other information necessary to provide the service you have requested.

We may process your personal information by using a third party solution which incorporates artificial intelligence technology (" Solution"). The Solution has a recording and transcribing function as well as an automated function which identifies relevant information from the meeting and inputs that information into the relevant associated documentation in our records. The Solution will be used during meetings with you and to assist with the delivery of our products and services to you. Use of the Solution will enable us to have an accurate note of the meeting and capture relevant information you provide to us during meetings The personal information captured will be subject to Planner/Adviser oversight and decision-making throughout to ensure the quality and accuracy of the output from the Solution.

We only use artificial intelligence tools and systems subject to an agreed set of terms and conditions, as well as applicable law and we hold all third-party suppliers with whom we work, accountable to these requirements.

We will use this information about you:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

• for the purposes of providing advice, administration, transacting and management or any other purpose necessary for the service you have requested; and

• to meet any necessary legal and regulatory obligations

We may, with your explicit consent, contact you or pass your details to other companies associated with us to contact you (including by telephone) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.

We will only process your special category data with your explicit consent. Special category data means information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (including voice data) and data concerning health, sex life or sexual orientation.

If you provide us with personal information about another person, you should show them this notice.

Our use of children’s personal information

Generally, we would only process a child’s name and date of birth, unless further details were required to fulfil a service that you have specifically requested, such as to establish investments for or on behalf of the child, school planning purposes or to establish health or life insurance. We consider that children are people under 18 years of age. Whenever we collate information for children, we would always explain why the information is needed. Where a child is party to the contract, we would always consider the child’s capacity to understand the contract they are entering.

We will never use the child’s personal information for marketing purposes.

Our legal basis for processing your personal information

We are required by law to have a specific reason for collecting and using your personal information. We will only process your information where we have a valid reason to do so under data protection legislation as follows:

• Contract - we will process your personal information for the purpose of fulfilling our contractual obligations to you or to meet a pre-contractual request.

• Consent – we will request your explicit consent for the following purposes:
  
  - processing and sharing your special category personal information in connection with product applications or as part of advising you in relation to our products and services, including the use of online forms or via the Solution in meetings with you.
  - provision of marketing information to make you aware of our products and services which may be of interest.
  - sharing your personal information with third-party review platforms to receive feedback on our services, helping us ensure we continue to meet our clients’ needs and expectations.

• Legal obligation - in some circumstances we are permitted by law to process your personal information.

• Legitimate interests - we may use your personal information for our, or a third party’s legitimate business interests. When we process personal information to meet our legitimate business interest we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Who we share your personal information with

We use more than one company in our group to deliver our services. We may share your personal information with other Succession and Aviva group companies as part of our commitment to offer you services. Additionally, we may share your information with other Aviva group companies, for analysis and insight purposes, particularly if you were originally referred to us through them. For more information, please visit ginally referred to us through them. For more information, please visit www.aviva.co.uk/privacypolicy.

We may share your personal information with product providers, our compliance consultants, the FCA or any other regulatory, statutory, governmental, industry bodies including, where relevant, solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.

We use third party companies to provide services so we can deliver a service to you. For example, IT systems and software and associated support services to ensure they continue to operate effectively, the provider of the Solution, and compliance consultants.

We may disclose your personal information to anyone in the future who may buy or merge with our business. If we merge with another company or if we are sold, then we will need to share your information with the other party.

In the event of a sale of any part of our business we may have to pass your personal information to another party in a transaction where it is not possible to separate it from the information we need to pass to them. We will only do this where there is not a viable alternative.

Where we store your personal information

We take the security of your data very seriously and follow best practice on data security.

If personal information is processed outside of the UK, we will ensure that we put in place appropriate safeguards to protect personal information, such as, appropriate contractual arrangements and assurances including (but not limited to) recognised certification schemes.

Product Providers, Lenders and Investment Managers may administer your policy, any existing policies you may have with them and provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the UK General Data Protection Regulation.

Steps are taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures are also taken to safeguard against unauthorised or unlawful processing, accidental loss, destruction or damage to the data.

How long will you keep my personal information?

We will keep your personal information securely for as long as is necessary for the purpose it was collected.

Generally, we will retain most personal information for the duration of the relationship and time limits are applied thereafter, based on the type of data. Some records need to be retained indefinitely to meet FCA regulation.

The usual position is that we retain customer information for a minimum of six years from the date of the end of our relationship with you as our client. Voice recordings from those meetings is securely retained on our behalf by one of the third parties we work with in order to provide our services to you, for a period of nine months following each meeting and transcripts of those recordings stored for a period of 2 years after each meeting. Information relating to pensions is kept for a longer period – for a minimum of ten years from the date of the end of our relationship with you as our client or indefinitely, depending on the regulatory requirements to which we are subject. Actual retention periods may vary depending on each individual’s circumstances, but we would always inform you as part of our privacy information obligations.

Your rights

Under the UK General Data Protection Regulation, you have a number of important rights. In summary, those include rights to:

• access your personal information and to certain other supplementary information that this notice is already designed to address

• require us to correct any mistakes in your information which we hold

• require the erasure of personal information concerning you in certain situations

• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• object at any time to processing of personal information concerning you for direct marketing

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

• object in certain other situations to our continued processing of your personal information

• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation.

We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.

Access to your personal information will be provided free of charge, unless the request is manifestly unfounded, excessive or repeated or if more than one set of your personal data is requested and the second set is a hard copy. If a fee is charged, this will only reflect the costs incurred in producing and delivering the information to you.

Where you have provided explicit consent for the processing of your personal information, you have the right to withdraw such consent at any time by contacting dataprotection@successionwealth.co.uk. Please note however that if you withdraw your consent, or you do not provide it, this could mean that we have insufficient information to provide our services. Where that is the case, we will inform you before taking any action.

Contact Us

We would be happy to answer any questions, comments, requests or concerns you may have about the way we use your personal information.

If you wish to contact our Data Protection Officer, please send an email to dataprotection@successionwealth.co.uk or write to Succession Wealth, 60 Church Street (7th Floor), Birmingham B3 2DJ or call 0121 212 9212.

You also have the right to lodge a complaint to the Information Commissioner’s Office at www.ico.org.uk or by calling 0303 123 1113.

Changes to this notice

Any changes we may make to this notice in the future will be posted on www.successionwealth.co.uk. Please check frequently to see any updates or changes. The most recent update was made in September 2024.

Data Protection Consent Form (Special Category Information)

We have provided you with a copy of our Privacy Notice and explained the information that we will need to collect, store and share about you, in order to provide our services.

• I agree that the information that I will provide/have provided during the completion of the Fact Find will be/is accurate.

• I understand that you will carry out an independent check of my identify via an independent agency.

• I understand that any information collected can be held on computer and/or paper files in accordance
  with the UK General Data Protection Regulation.

• I understand that any information that I give may be disclosed to third parties (e.g., product providers) for the purpose of processing my application(s).

• I understand that Succession Wealth will use my data to access quotes on my behalf.

• I confirm that:
  
  - I have shown the Privacy Notice to my spouse/partner, my children (under 18 years of age) or any other dependants or family members whose personal data I may refer to during my meetings with Succession Wealth so that they understand that Succession Wealth will process that personal data; and
  - that I have consent from those individuals to discuss such details with Succession Wealth while accessing products and services provided or facilitated by Succession Wealth.

Please note, you may withdraw your consent by contacting us in writing at any time at dataprotection@successionwealth.co.uk. Please be aware that withdrawing consent may impact the service which we can provide you.