Cookies & Privacy Policy

Appendix 3: Data Protection Statement

How we will handle your personal data and protect your privacy.

A guide to how we meet the requirements of the Data Protection Act.

Making sure personal data is secure and properly dealt with is of paramount importance in our dealings with you. It is therefore important you understand what
information we will take, why we need it, and how we will process your details.

Who will process my data?

Aston & Co Financial Services Ltd is an appointed representative of HL Partnership Limited which is authorised and regulated by the Financial Conduct Authority. As such, both Aston
& Co Financial Services Ltd and HL Partnership Limited will process your data in order to provide our services.

What data will you ask me for?

In order to fully understand your financial needs and be able to give good advice, we need to obtain information about you, your family, your personal
circumstances, and your preferences.  Some of the information will be private and may be sensitive, such as details of
your income and expenditure, health, debts and credit commitments, legal proceedings and adverse credit. Much of the information you provide will need
to be passed on to the companies whose products you apply for.

Do I have to provide my personal data?

In order for us to be able to give you suitable advice, we need you to provide all the information we ask for as openly and honestly as possible. If you prefer
not to disclose some information, please tell us that you prefer not to disclose it and we will assess whether this will alter or impede the work we
are doing for you.

How will you use my data?

1.      
The primary reason we will use your data is to allow us to do the job you’ve asked us to do. Specifically, we will use your data to:

·        
Assess and provide advice to meet your needs and circumstances;

·        
Introduce you to a range of product and service providers in order to meet your requirements;

·        
Administer cases and assist processing of applications;

·        
Tell you about any changes to products and service we have arranged for you;

·        
Inform you about products and services we think may be suitable for you (unless you ask us not
to send you this information).

2.      
We may also process your information in order to meet our legal and regulatory
requirements. These may include:

·        
Complying with the regulations set out by the Financial Conduct Authority and other regulators
as required;

·        
Preventing financial crimes such as money laundering and fraud by passing your details to
other relevant bodies such as the police and National Crime Agency where
required.

3.      
We may also process your personal data for our own legitimate interests. Typically, these
would be limited to:

·        
Analysing our business for trends and research how we can improve our services to customers;

·        
Reviewing the work we have carried out for you to ensure we have met the regulations and
quality standards;

·        
Ensuring we are able to exercise or defend legal challenges in the future.

4.      
HL Partnership Limited will use your data to monitor and assess our work to ensure we have
provided a high standard of service and met our legal and regulatory
commitments.

How long we will store your data?

We will only keep your personal information as long as necessary. How long that is depends on the type of data and the nature of the work we have carried out. In
most cases, your personal data will be stored for an indefinite period as we need to keep evidence that we have fulfilled our legal and regulatory
requirements.

Can I see a copy of my personal data?

Yes. Please write to our Data Controller (details below) and we will provide a copy of any personal data we hold about you within one calendar month of receiving
your request. Please note that we may need to verify your identity before providing the information.

What if my data is incorrect or incomplete?

You have the right to have your data corrected or completed by contacting our Data Controller in writing (details below). Please be aware that we need to maintain
records of information as it was at the time of the advice or the transaction taking place.

Can I have my data erased?

If we have provided you with advice or processed a transaction on your behalf, we will not normally be able to erase your personal data. This is because we are
obliged to maintain records of our advice and transactions to meet our regulatory requirements and in case we need to exercise or defend legal claims
in future.

Who is the Data Controller?

How can I 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, HL Partnership Limited, 6
Merus Court, Meridian Business Park, Leicester, LE19 1RJ

Email: compliance@hlpartnership.co.uk

If you’d like to make a complaint about how we have handled your personal data…

Please write in the first instance to The Data Protection Officer at the above
address.

 If you are not satisfied with the Data Protection Officer’s response, you can make a complaint to:

Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745
              (national rate)

Email through their website at: https://ico.org.uk/concerns/

Important Notes on Protecting your own Data

Please be aware of cybercrime and protecting your own information online, particularly financial information. Do not send unsecure personal information over the internet. We recommend you use encryption software or provide any information to us using the online tools we provide.

Do not respond to emails asking you to pay money. Never make a payment purely in response to an email. Always call the company to validate any payment requests and check the phone number independently from the email (i.e. via a secure web site). If you receive a phone call asking for payment ensure you are satisfied the call is genuine, or else call the company back to check. Neither Aston & Co Financial Services Ltd nor HL Partnership will take responsibility if you transfer money to a fraudster in error.

PERSONAL DETAILS

ASTON & CO FINANCIAL SERVICES may require certain details and Personal Data from you, including without limitation your name and email address. This policy is in relation to these details and any other Personal Data which ASTON & CO FINANCIAL SERVICES subsequently collects from you or about you (collectively “the Information”).

USE AND DISCLOSURE OF THE INFORMATION AND CLIENT INFORMATION

ASTON & CO FINANCIAL SERVICES will use the Information in a variety of ways, some of which will assist and enable ASTON & CO FINANCIAL SERVICES to provide its services to its clients and prospective clients. This may include for example, ASTON & CO FINANCIAL SERVICES contacting you directly to monitor progress and to inform you of progress on specific projects and ASTON & CO FINANCIAL SERVICES publishing some Information (e.g. your name and email address) on certain pages of its websites.

ASTON & CO FINANCIAL SERVICES may also in its sole discretion retain the Information and use it for direct marketing services, e.g. ASTON & CO FINANCIAL SERVICES may send marketing information to you. Such marketing information may relate to the legal profession, to financial matters and to goods and/or services provided by ASTON & CO FINANCIAL SERVICES and/or third parties as well as goods and/or services provided by third parties which are entirely unrelated to your original requests.

ASTON & CO FINANCIAL SERVICES may in its sole discretion sell some Information to unrelated third parties who may use such Information for direct marketing purposes in relation to a wide range of goods and/or services which, for the avoidance of doubt, are entirely unrelated to your original request: If you do not wish to receive such information, please click on the box provided.

ASTON & CO FINANCIAL SERVICES reserves the right to report any activity which Aston & CO FINANCIAL SERVICES suspects violates any relevant laws or regulations to the appropriate authority. ASTON & CO FINANCIAL SERVICES is requested by such authority for the Information ASTON & CO FINANCIAL SERVICES reserves the right to disclose it to them.

You shall indemnify and keep ASTON & CO FINANCIAL SERVICES and ASTON & CO FINANCIAL SERVICES s directors, officers, employees and agents fully indemnified against all actions, claims, proceedings, costs and damages (including any damages or compensation paid by ASTON & CO FINANCIAL SERVICES on the advice of its legal advisors to compromise or settle any claim) and all legal costs or other expenses arising out of any breach of any representations, warranties and/or undertakings or out of any claims by a third party based on any facts which if substantiated would constitute such a breach.

SECURITY

All Information and will be kept as confidential and as secure as possible using ASTON & CO FINANCIAL SERVICES secure server software. This means that the Information and can only be exchanged between you, ASTON & CO FINANCIAL SERVICES and any third party to whom ASTON & CO FINANCIAL SERVICES decides to transfer the Information to for the purposes detailed above. Furthermore as required by the Act ASTON & CO FINANCIAL SERVICES follows strict security procedures in the storage and disclosure of the Information which you have given to ASTON & CO FINANCIAL SERVICES to prevent unauthorised access.

ASTON & CO FINANCIAL SERVICES uses industry standard practices to safeguard the confidentiality of the Information including “firewalls” and Secure Socket Layers. ASTON & CO FINANCIAL SERVICES treats the Information as an asset that must be protected against loss and unauthorised access. ASTON & CO FINANCIAL SERVICES employees use many different security techniques to protect the Information from unauthorised access by users inside and outside the company. However, “perfect security” does not exist on the Internet.

INDIVIDUAL’S RIGHTS

Under the Data Protection Act 1998 all individuals are entitled on the payment of a fee, to be given from ASTON & CO FINANCIAL SERVICES a description of all Personal Data ASTON & CO FINANCIAL SERVICES holds about the individual, the purposes for which this is being processed and the recipients to whom this may be disclosed. All such individuals also have the right to have communicated to them in an intelligible form the information constituting the Personal Data and any information available to ASTON & CO FINANCIAL SERVICES as to the source of that Personal Data. If you require any further information on this point, please contact ASTON & CO FINANCIAL SERVICES as detailed above.

GENERAL

ASTON & CO FINANCIAL SERVICES reserves the right to vary the terms and conditions of this Agreement from time to time. Such variations become effective immediately upon the posting of the varied Agreement on the Websites. By continuing to use the Websites after such posting you will be deemed to accept such variations. You should visit this page periodically to review the terms and conditions of this Agreement because they are binding on you.

In the event that any term of this Agreement is held to be invalid, unlawful, void or for any reason unenforceable, that term shall be deemed severable, and the remainder of this Agreement shall remain valid and enforceable. No waiver of any term of this Agreement shall be deemed a further or continuing waiver of such term or any other term.

Except as expressly provided in additional terms of use for areas of the Websites, this Agreement constitutes the entire agreement between you and ASTON & CO FINANCIAL SERVICES with respect to your use of the Websites. Where such areas are subject to additional terms of use, by using such areas or any part thereof, you agree to be bound by such additional terms applicable to such areas.

For the avoidance of doubt nothing in these terms and conditions shall confer on any third party any benefit or the right to enforce any terms contained herein.

Cookies

Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we put on your computer. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use are ‘analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

These cookies do not record any personally identifiable information (PII).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

CHANGES TO OUR PRIVACY & COOKIES 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 check back frequently to see any updates or changes to our Privacy and Cookies Policy.