Privacy Policy
EFFECTIVE DATE: 17/03/2025
Privacy Notice
This Privacy Notice outlines how we collect, use, and share your personal data, and explains your rights.
Introduction
The Bowmore Wealth Group needs to understand enough about you and your financial situation to enable us to determine if we can be of service to you and to enable us to provide our services to you. Because we collect your personal data for these purposes, we want you to understand the legal rules that we are relying upon and your legal rights, which we explain in this document, the Bowmore Privacy Notice.
Bowmore Wealth Group respects your privacy and is committed to protecting your personal data, and includes our two businesses:
- Bowmore Financial Planning Ltd
- Bowmore Asset Management Ltd
What Personal Data We Collect
We may collect and process the following categories of personal data:
| CATEGORY | EXAMPLES |
|---|---|
| Identity Data | Name, date of birth, National Insurance number, passport/ID |
| Contact Data | Address, email address, phone numbers |
| Financial Data | Bank details, income, tax records, pension and other product details, investment holdings |
| Special Category Data | Health data e.g. medical data for pension and some insurance work |
| Technical Data | Your system and usage details when interacting with our website or online tools, including your IP address, cookies, browser type and usage data |
We only intend to collect your personal data that is necessary, or may be necessary, for us to deliver our services to you. We only use your personal data within the Bowmore Wealth Group and where we need to pass on your personal data to open and administer your accounts that we arrange.
Data About Connected Individuals
We may require data about your family members, dependants, or joint account holders and we want to make sure that they understand the Bowmore Privacy Notice. We are able and willing to rely upon your confirmation that they are aware of the Bowmore Privacy Notice and that you have their consent to share their personal data with us.
Why We Collect Your Personal Data
It is important to us that you understand why we collect your personal data, our purpose, and the legal rules that we are relying upon to collect and use your personal data; the legal basis.
| PURPOSE | LEGAL BASIS |
|---|---|
| Delivering financial planning, advice, and investment management. Sending statements, reviews, and updates in respect of your accounts and investments managed by us. Notifying you about changes to our services, our terms and privacy notice. Using essential cookies and data analytics necessary for the effective use of our online services and your customer experience. | Contractual obligation |
| Compliance with legal, regulatory and security obligations (e.g., anti-money laundering checks). | Legal obligation |
| Using health data for financial planning. Recording other sensitive personal data that might be useful for the delivery of our services to you where we must obtain your explicit consent. | Explicit consent |
| Collecting your personal data at any initial meeting before you agree to use our services. Asking you to leave a review or to complete a survey. Administering and protecting our business and website, including troubleshooting, data analysis, system maintenance, support, reporting, and hosting data. Delivering relevant website content and measuring or understanding the effectiveness of the content you see. | Legitimate interest |
| Sending marketing communications. | Consent |
| Using data analytics to improve your experience of our website and online services. | Consent to system cookies |
You have the legal right to withdraw your consent, including explicit consent, which means that we cannot use the data for that purpose. We may continue to use your personal data if this is allowed by another legal basis, for example you may continue to use our services, and we can use your data in accordance with the contract we have agreed with you, but you may withdraw your consent for us to send to you marketing communications.
How We Use Your Personal Data
We use your data for several purposes, each of which is linked to specific types of data and lawful bases for processing.
Bowmore may use data that we have received from another person who agreed with you how they will process and protect your data. In this situation we are allowed to use your data because we are treated as a data processor. Your data is subject to the purpose and legal basis explained to you by the other person. We operate the same high level security standards to ensure that your data remains safe.
Who We Share Your Data With
| RECIPIENT | REASON FOR SHARING |
|---|---|
| Bowmore Group entities | To provide seamless services to you from our different businesses |
| Third-party service providers | Bowmore carefully selects other providers to support us in delivering our services to you, for example our IT support and compliance review service. We will only share data with third parties once we are satisfied that they follow similar high level security standards, and we have a contract with them. |
| Regulators and authorities | To fulfil legal and regulatory obligations |
We never share your data for marketing purposes outside the Bowmore Group without your consent.
Data Retention
We retain your personal data while we are providing our services to you and only as long as necessary after we have agreed that the service will stop. The period of time that we may keep your data is to enable us to respond to you about any matter arising from the services we had provided and to comply with applicable rules.
| DATA CATEGORY | RETENTION PERIOD |
|---|---|
| Identity, contact and financial data in relation to Financial Planning and Investment business | 7 years |
| Identity, contact and financial data in relation to Pension transfer advice | Indefinitely |
| Identity, contact and financial data in relation to Insurance business records | 7 years |
| Identity, contact and financial data in relation to initial meetings and discussions | 1 year |
Data will be securely deleted or anonymised once it is no longer required.
Your Rights
You have the following legal rights regarding your personal data:
- Access: You may request a copy of your personal data held by us.
- Correction: You may request corrections to incomplete or inaccurate data which we welcome in any case so that we can be sure that we have the most up to date data for us to deliver our services to you.
- Erasure: You may request deletion of your data that we hold where you have given your consent. We are allowed to keep your data where we are relying upon another legal rule such as to fulfil our regulatory obligations. We will explain this to you when we respond to your request.
- Restriction: You may request that we limit our use of your data. For example, you may accept that we use your personal data to deliver our services to you, but you do not want to receive any marketing material.
- Data Portability: You may request that your data is passed onto another company in a way that the other company would not have to manually process that data.
- Objection: You may object to us processing your data where we are relying upon a legitimate interest. This will reduce the services we can provide to you, and you may choose not to object once you understand in more detail the reasons for us using your data in this way.
To exercise your rights, or to understand your rights in more detail, please contact us at enquiries@bowmorewealth.com.
Security Measures
We use advanced technical and organisational measures to safeguard your personal data against unauthorised access, loss, or misuse. These measures include:
- Encryption of sensitive data
- Secure storage systems
- Secure records and system destruction
- Regular security audits
- Staff training
- Overseeing arrangements of third parties
Cookies and Online Tracking
When you interact with our website, we may use cookies to collect technical data. For details, refer to our Cookie Policy.
Updates to This Privacy Notice
We may update this notice periodically. The latest version will always be available on our website. Significant changes will be communicated to you directly where appropriate.
Contact Details
For any questions or to exercise your rights, please contact us:
Email: enquiries@bowmorewealth.com
Address: Farleigh House, Farleigh Court, Old Weston Road, Flax Bourton, Bristol, BS48 1UR
If you are concerned about the security, or our use of your personal data, in any way, we encourage you to let us know about your concerns. We will do all we can to reassure you or correct any errors we have made. You may raise a complaint with the Information Commissioner’s Office (ICO), the UK regulator for data protection matters, if you are not satisfied with how we have dealt with your concerns. You may contact the ICO through their website:
Website: www.ico.org.uk