Version 1 (3rd October 2022)
Privacy policy
Touch by AJ Bell is committed to protecting your personal data. This policy explains how we collect your personal data and the reasons why we need it. It explains the occasions where we’ll need to share your data with third parties and the way in which we keep it securely stored. It will also tell you the length of time that we expect to hold your data, and the rights that you have while we’re holding it.
By visiting our website or app, you are accepting the practices described in this policy. The website or app may also contain links to other websites and we can’t accept responsibility for any data that you provide to them.
Our data controller is AJ Bell Management Limited of 4 Exchange Quay, Salford Quays, Manchester M5 3EE.
Our Data Protection Officer is Karen Goodman, Chief Risk Officer, who can be contacted at the address shown above, by email to support@ajbelltouch.co.uk or by telephone on 0345 646 1661.
The information below confirms the personal information that we collect from you and your adviser, along with the purpose and the legal basis for doing so:
Residential and contact information
Data collected - including details of your:
- Name
- Address
- Email address
- Telephone number
- Place of work
- Any other contact details
- Nationality and citizenship
Purpose of processing
Verifying your identity and providing platform services. Seeking your consent for transactions and changes to terms and conditions. Contacting you about products, services, contractual, and regulatory obligations.
Legal basis
To fulfil our contractual obligations to contact you and update you on product changes, and to comply with regulatory requirements.
Socio-demographic
Data collected - Including details of your:
- Age
- Gender
- Profession or employment
- Earnings
- Other details of the source of your wealth
Purpose of processing
Developing products and services. Defining customer types and target markets. Complying with regulatory requirements and managing risk effectively.
Legal basis
To fulfil our contractual obligations and to comply with regulatory requirements.
Family circumstances
Data collected - Including details of your:
- Marital circumstances
- The names of members of your family and their relation to you
Purpose of processing
Understanding your circumstances. Paying benefits appropriately from your account/s.
Legal basis
To fulfil our contractual obligations and to comply with regulatory and legislative requirements, as well as a Legitimate interest to pay beneficiaries.
Transactional information
Data collected - Including details of your:
- Payments to and from your accounts
- Transactions instructed on your account by you
- Enquiries in relation to your account and proposed or completed transactions
Purpose of processing
Efficiently completing transactions you instruct, or that we must undertake for legal or regulatory reasons.
Legal basis
To fulfil our contractual obligations and to comply with regulatory requirements.
Technical
Data collected:
Each time you visit the website or app, we may automatically collect the following information:
Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the website or app (including date and time); page response times; download errors; length of visits to certain pages; page interaction information; methods used to browse away from the page.
Purpose of processing
Developing products and services. Defining customer types and target markets.
Legal basis
To fulfil our contractual obligations and to comply with regulatory requirements.
Special and one-off items of information
Data collected - Including details of your:
- Health and illnesses
- Disabilities and special requirements
- Personal financial information including bank account details and bankruptcy or insolvency status
Purpose of processing
Paying benefits appropriately from your account/s.
Legal basis
To fulfil our contractual obligations and to comply with regulatory requirements.
Legal
Data collected - Including:
- Documents relating to your identity, residency, nationality and citizenship
- National identifiers, passport number and tax authority identifiers
- Your passport, driver’s license, marriage certificate, birth certificate and proof of addresses
- Source of funds and wealth
- A video selfie taken by yourself
- Information relating to Sanctions or Political appointments (including family members and affiliates)
Purpose of processing
Verifying your identity, authority and eligibility in relation to the products and services we provide to you.
Legal basis
To fulfil our contractual obligations and to comply with regulatory requirements.
If you would like to find out more about the legal basis upon which we process personal information, please contact us using general contact details provided at the end of this document.
Information you give us
You and your adviser may give us personal information through the website, app, email, phone, or post. This includes information you provide when you join Touch by AJ Bell; apply for one of our accounts; search the website or app; enter a promotion; take part in a survey; or when interacting with the website or app in any other way. This also includes any occasions when you report a problem with the website or app. When giving us personal information about third parties, you and your adviser confirm that you are entitled to disclose that information. If you are submitting personal information on behalf of another person, you confirm that you have their authority to do so and that they understand that we will use their personal details.
Information we receive from other sources
We may also receive information about you if you use any of the other websites or apps that we operate, or the other services we provide. When we collect your data, we will inform you that it may be shared within the AJ Bell Group. We also work closely with third parties (including, business partners; external service providers in technical, payment and delivery services; advertising networks; analytics providers; search information providers and credit reference agencies) and may receive information about you from them.
We use Google Maps for the address look up function to allow you to easily find your address. The Terms of Use and Privacy Policy for this service can be found using these links.
If you authorise a third party to contact us on your behalf and allow them to provide us with information about you or the services you have with us, we will always verify their identity and their right to access your information before any information about your account(s) is divulged.
Cookies
We use cookies to authenticate users to ensure that only the actual owner of an account can access that account. Cookies also help us to improve your experience when you browse our website and app.
Disclosure of your information
We may share your personal information with any member of our group. This includes our ultimate holding company and its subsidiaries. We share information within the group to ensure that each business unit has the information it needs to process transactions and administration on your behalf. It also means that as a group we comply with regulatory and reporting requirements. We may share your information with selected third parties, including:
- business partners, suppliers and sub-contractors, including but not limited to:
- investment providers
- data and software providers
- regulatory and tax authorities
- credit reference and fraud prevention agencies
- identity verification providers that help us to check your selfie video against the identity document that you have provided (a biometric check)
- analytics and search engine providers that help us to improve and optimise the website or app
We may also share your personal information to third parties in the following circumstances:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of the business or assets;
- if we’re required to disclose or share your personal data in order to comply with a legal obligation, or to enforce or apply our rights under this policy or terms and conditions and other agreements; or to protect the rights, property, or safety of any member of our group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How we store and protect your personal data
Your data will be held in the UK and the European Economic Area (EEA) but there may be occasions when the data we collect from you may be transferred to, and stored at, a destination outside these locations. It may also be processed by staff operating outside these locations who work for us or for one of our suppliers. This processing may be required to fulfil your order, arrange payments, and to provide support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on secure cloud servers. Any payment transactions will be encrypted using TLS technology. Where you have a password which enables you to access certain parts of the website or app, you are responsible for keeping it confidential. Unfortunately, sending information via the internet cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when sent to the website or app; and it is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We strongly suggest you purchase and keep up-to-date software to protect the security of your mobile device.
How long we will store your personal data for
Your personal data will be stored for the duration of your relationship with us. After that, we will store your personal data for as long as it is necessary to do so. This includes retaining all anti-money laundering check data for five years.
We may also store other information for longer than 10 years if needed to evidence that we have met our regulatory requirements and to demonstrate that we have correctly recorded and reported information on your accounts to the relevant authorities.
Your rights
You have the following rights in relation to your data that we hold:
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Right to be informed
This policy has been designed to inform you about how we collect and use of your personal data. -
The right to access
You have a right to request a copy of your personal information, and you can do this by emailing DataSubject.AccessRequests@ajbell.co.uk or by using general contact details provided at the end of this document. Before disclosing the personal information, we may ask you for additional information to confirm your identity. We reserve the right to charge a fee where your request is unfounded or excessive. We will make every reasonable effort to honour your request promptly or inform you if we require further information to fulfil your request. We may not always be able to fully address your request, for example if it would impact the privacy of others or if we are legally entitled to deal with the request in a different way. -
The right to rectification
You have a right to request that we correct inaccurate personal information. We may seek to verify the accuracy of the personal information before correcting it. You can make a request by using the general contact details provided at the end of this document. -
The right to erasure
You can request that we erase your personal information in limited circumstances where:- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- this is required to comply with a legal obligation to which you are subject
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims
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The right to restrict processing
You can ask us to restrict your personal information, but only where:- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- necessary to establish, exercise or defend a legal claim; or
- necessary to protect the rights of another natural or legal person
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The right to portability
You have the right to ask us to provide you with an electronic file containing all personal information that we hold about you. You can then give this information to other organisations if you wish to. -
7a. The right to object to processing
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your rights and freedoms outweigh our legitimate interests. If you raise an objection, we will then need to demonstrate that we have compelling legitimate interests which override your rights and freedoms if we wish to continue processing your data.7b. Right to object to how we use your personal information for direct marketing purposes
You also have the right to ask us not to process your personal data for marketing purposes, or to change the way in which we process your data for direct marketing purposes.
You can request that we don’t transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
You can let us know that you want to stop direct marketing or change your preferences at any time by using the unsubscribe button in marketing emails, or you can write to The Marketing Department, Touch by AJ Bell, 4 Exchange Quay, Salford Quays, Manchester M5 3EE or email us at marketing@ajbell.co.uk. However, keep in mind you cannot opt-out of receiving regulatory or legal updates (e.g. information about a change in the product terms and conditions). We regularly review our records to ensure that we only retain your personal details for as long as is necessary for the purposes set out above. -
Rights related to automated decision-making including profiling
Certain rights are available to you when firms make decisions solely by automated means (without any human involvement). However, our processes always ensure that human involvement is required before any final decision is made.
Information safeguards used for transfers outside your jurisdiction
You can ask for information on the safeguards that we use when your personal data is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
How to make a complaint if things go wrong
If you have concerns about how we are processing your personal information, you have a right to lodge a complaint with the Information Commissioners Office (ICO). We ask that you attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please note that updates to this policy are not emailed as a matter of course, so please check back frequently to see any updates.
Contact
The Marketing Department, Touch by AJ Bell, 4 Exchange Quay, Salford Quays, Manchester M5 3EE. Email us at marketing@ajbell.co.uk or by calling 0345 646 1661.
