Privacy Policy

JOHNSON WEALTH SOLUTIONS LTD PRIVACY POLICY

Johnson Wealth Solutions Ltd is a company registered in England and Wales (collectively referred to as “Johnson Wealth Solutions”, “we” or “us” in this policy).

OVERVIEW

Maintaining the security of your data is a priority at Johnson Wealth Solutions, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Johnson Wealth Solutions is also dedicated to being transparent about what data we collect about you and how we use it.

This policy, which applies when you visit our website at https://johnsonwealthsolutions.com/ provides you with information about:

– how we use your data;

– what personal data we collect;

– how we ensure your privacy is maintained; and

– your legal rights relating to your personal data.

More details are below

INTRODUCTION

Welcome to Johnson Wealth Solutions Privacy Policy. 

Johnson Wealth Solutions respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit https://johnsonwealthsolutions.com/ (the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please read this Privacy Policy together with our Terms of Use and Cookie Policy, with care before you use this Website. If you do not accept this Privacy Policy, please do not use this Website. 

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of and interaction with the Website.

This Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy 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 data. This privacy policy supplements the other notices and is not intended to override them. 

Controller

Johnson Wealth Solutions is the controller (i.e. is responsible for the keeping and use of your personal information) (collectively referred to as “we”, “us” or “our” in this Privacy Policy).

Contact details

If you have any questions about this Privacy Policy, please contact us using the details set out below

Contact details

Our full details are:  

Johnson Wealth Solutions 

Email address admin@johnsonwealthsolutions.com 

Postal address: 11 Kings Rd, Fleet, Hampshire, GU51 3AA

Telephone number: 01252 979673

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 ICO, so please contact us in the first instance. 

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 5th October 2021.

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the date at the top of this section and post it on our Website. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our Website before they take effect or directly sending you a notification by email.

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.

Third-party links

This website may include links to third-party 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 these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name. 
• Contact Data includes email addresses, telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website. 
• Profile Data includes your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use the Website. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, 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 certain services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. The Website includes functions that allow youto give us your Identity and Contact Data by signing up to our newsletter or requesting a call back or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Instruct or are interested in utilising our services;
• subscribe to our blogs or publications; 
• request marketing information about our services to be sent to you;
• enter a competition, promotion or complete a survey; or
• give us some feedback on our services. 

• Automated technologies or interactions. As you interact with the Website, and this includes when you input data on the ‘Advisor Website Index’ function we provide, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. 
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: 

• Technical Data from the following parties:

1. analytics providers such as Google based outside the EU; 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract for services we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Data Protection

Collecting information and protecting your privacy

Our aim is to offer advice that helps you plan your financial future. To provide such advice, we need to know about your personal situation and your Adviser may request sensitive and private information about you, for example, your income, current financial arrangements, health, family commitments and any legal proceedings you may be involved in. Much of the information you provide will, as part of your application, be passed to the company whose products you apply for and details of how they use your information are included in their data protection literature.

If you are unable or unwilling to provide some, or all, of this information your Adviser will be unable to provide you with advice suitable for your circumstances. We do not collect personal information from third parties.

We are committed to protecting your privacy. As we would like you to be a lifetime client, we need to earn your trust and assure you that we will keep your personal information confidential and secure and only for as long as is necessary. The criteria we use to determine how long this period is can be obtained from Openwork’s Data Protection Officer at the address below.

We will use it with care and it will only be shared in the ways explained here, or if we are required to by Law or the Financial Conduct Authority (FCA).

Your personal information will only be held for as long as necessary and collected for the purposes of providing advice in respect of the range of products and services outlined in the Initial Disclosure Document or Client Proposition Brochure provided by your Adviser. In addition, we will make every effort to ensure that the information you provide is recorded accurately and that it is only passed to companies who comply with the General Data Protection Regulations (GDPR). If it is required to send your information abroad, we will only do so to countries within the European Union (EU) or to a third country that the EU has determined provides an adequate level of protection and where you are able to exercise your rights to access your personal information under the GDPR.

Controlling and using your personal information

A Data Controller is someone who determines the purposes for and the manner in which your personal data should be processed. Openwork, its Appointed Representatives (your Adviser) and the companies whose products you buy are all Data Controllers. Your Adviser will have given you their contact details and Openwork’s contact details are shown below.

We use your information in a variety of ways:

• To introduce you to a range of products and services offered by the companies we are associated with (or may be associated with in the future).
• To help with administration.
• To contact you with details of changes to products you have bought.
• For business analysis and research.
• For marketing products and services we think may be suitable for you (unless you ask us not to send you this information).
• To comply with the Law and/or FCA requirements.
• To verify your identity by searching publicly available records held by credit reference agencies.
• To prevent fraud and money laundering we may pass your details to other companies, public bodies including the police or to an insurer’s database. Insurance companies can search databases for any relevant information that exists about you.

We therefore process your data because it is necessary for:

• the performance of a contract to which you are a party.
• compliance with legal obligations to which we as the controller are subject.

None of the information gathered about you will be used in automatic decision making.

Your health details

If you apply for some types of insurance (eg. life insurance, pensions, sickness etc.) you will be required to provide details of your health. Under the GDPR, this is regarded as sensitive personal data.

Your Adviser will have access to your medical details unless you prefer to complete a medical statement of health in private. If this is the case, please send it with your application marked for the attention of the “Consultant Medical Officer” in a sealed envelope.

We do need your explicit consent to collect and process your health details, which of course you may withdraw at any time.

Mortgage credit checking

If you apply for a mortgage your information will be passed to the lender, who will carry out a credit check. You will also have to provide details of any criminal convictions you may have had. These details will be passed to the lender to carry out any necessary checks.

Marketing and sharing your information

The information you give us will be added to any other details we hold about you. Openwork will never sell your details to a third party, but we may share your information with carefully selected companies we are associated with. Therefore, we (or they) may contact you (by post, email, telephone or other appropriate means) to tell you about products, services or offers we believe may interest you. The products and services may not be related to financial services. You can ask us not to contact you for this reason, at any time, by writing to us at our Head Office. This will not affect your relationship with your Adviser.

We may have to pass your details to another Adviser if, for example your Adviser is ill or you need advice in a different product area. If your Adviser leaves we may pass your details to another Adviser so that we can continue to provide you with a high standard of service.

We may send your information to third parties that are carrying out work on our behalf.

Your Data Protection rights

You have certain rights under the GDPR. These include the right to:

• Ask for a free copy of your personal information in a portable format.
• Stop us sending you marketing material about products and services.
• Have any incorrect information we hold about you corrected.
• Ask us to restrict processing of your personal data.

As the processing of your personal information is necessary for a legal obligation placed upon us by the FCA and may be required for the establishment, exercise or defence of legal claims, we will not be able to permanently delete your personal information until the end of the period we have deemed necessary.

How to get more information

If you would like further details on how we use your personal information or if you have any data protection queries, please write to:

The Data Protection Officer
The Openwork Partnership
Auckland House
Lydiard Fields
Swindon
SN5 8UB

You may receive more information about data protection from the companies that we have introduced you to.

We may record telephone calls so we can check we have acted on your instructions correctly and to ensure we are giving you appropriate service. We may also monitor calls for security and training purposes.

Complaints

If you have any complaints about the way we or your Adviser have handled your personal information, please contact the Data Protection Officer at the address given above.

You also have the right to refer your complaint to the Information Commissioner.

The Openwork Foundation

The Openwork Foundation takes data privacy very seriously. Please click here for details of their privacy policy and how they use any data you may provide to the Openwork Foundation.