Data Privacy & Protection Policy

This Data Privacy & Protection Policy sets out how Financial Advisers (“the Site”) uses and protects any information that you disclose or is collected when you use this website.

Performance Leads Ltd is a company registered in England and Wales (Company No. 10720622) with its registered office at Blake House 2A St Martin’s Ln, York YO1 6LN (“we”, “our”, “us”, “the Company”).

We take your privacy seriously. This privacy policy describes how and why we obtain, store, and process data which can identify you. We are committed to ensuring that your privacy is protected. This Data Privacy & Protection Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully as it contains important information on our practices regarding your personal information and how we, as a data controller, will treat personal information you provide to us through the Site, including the information we collect, what we do with the information you provide to us and who we may share your information with.

Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

DATA PROTECTION PRINCIPLES

We will comply with data protection law and principles, which means that your information will be:
– Used lawfully, fairly and in a transparent way;
– Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
– Relevant to the purposes we have told you about and limited only to those purposes;
– Accurate and kept up to date;
– Kept only as long as necessary for the purposes we have told you about; and
– Kept securely.

WHAT WE COLLECT

Information is collected from you when you submit your details on our site. The information we collect is clearly set out on the web page on which we collect it. In addition, we may collect your IP address and use cookies (see our cookie policy below) unless you configure your web browser not to accept them.

HOW IS INFORMATION COLLECTED?

We collect your personal information through different methods including:
– Directly from yourselves when you fill in the form on this site requesting to be matched with a Financial Advisor
– Cookies
– The referring site e.g. google.co.uk

FOR WHAT USE

We collect information about you so that we can match you with an FCA approved Financial Advisor. Your personal data will not be used for any other purpose other than this one, specific enquiry. For clarity this includes Performance Leads making contact to ensure that you are satisfied with the Advisor we have matched you with. We may also email you prior to your indicated Retirement Date to see if you need any further assistance

DATA PROTECTION

This site is owned by Performance Leads Limited, registered with the Information Commissioner in the UK as a “data controller” in accordance with the provisions of the Data Protection Act 2018. Further details of the registration are available at staging.dpr.gov.uk. ICO registration number ZA247374

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps respond to you as an individual by remembering previous data stored. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We periodically use traffic log cookies to identify traffic patterns anonymously. This can be optionally blocked by opting out of Google’s Analytics programme.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Externally you can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent the website operating correctly and is an unsupported environment and as such we offer no guarantee of the correct operation of the web-site.

Most websites you visit will use cookies in order to improve your user experience by enabling that website to ’remember’ you, either for the duration of your visit (using a ’session cookie’) or for repeat visits (using a ’persistent cookie’). Some websites will also use cookies to enable them to target their advertising or marketing messages based, for parties not associated with the primary reason for data submission – See ICO guidance: “The GDPR sets a high standard for consent. But you often won’t need consent.”

Our organisation utilises Force24’s marketing automation platform.

Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:
– F24_autoID
– F24_personID

They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.

f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.

f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.

The information stored by Force24 cookies remains anonymous until:
– Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
– A user of the website completes a form containing email address from either our website or our Force24 landing pages. 

The Force24 cookies will remain on a device for 10 years unless they are deleted.

Re other Tracking  we also use similar technologies including tracking pixels and link tracking to monitor your viewing activities
– A user of the website completes a form containing email address from either our website or our Force24 landing pages. 
– Device & browser type and open statistics 

All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.
– Link Tracking

All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes. 

Legitimate Interest Justification

The forms on our websites introduce a customer looking for the service in question. It is clear that contact details will be used by the Partner we connect them with in order to satisfy their request. Other than customer satisfaction calls no further marketing or processing will be conducted by us. For this reason, we do not request or rely on ’consent’ as provided by opt in check boxes as the legal basis for data processing. This Opt in method is appropriate for Websites providing further data sharing with 3rd parties unrelated to the initial processing reason. For clarity if a Partner (Financial Advisor) is looking to provide “other” ongoing services to the customer or marketing to them beyond the initial reason for their enquiry, they will need to ensure they gain consent directly as part of their initial interaction with them

WHAT WE DO WITH THE INFORMATION WE GATHER

We only share personal information with other companies or individuals in the following limited circumstances:

Making an introduction or referral to an financial adviser that you have requested. The Financial Advisor will be bound by contractual provisions with us and only have access to personal data to perform the described purposes, and may not use it for other purposes without further explicit permission obtained from you. Further, they must process the personal data in accordance with this Data Privacy & Protection Policy and all relevant legislation.

We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of the

Company its users or the public, as required or permitted by law.

Automated decisions are made on the basis of your location & advice type selected. This is necessary to be able to match you with an appropriate Advisor for your No Obligation Consultation.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Re Data Adequacy & International Data Transmission some overseas servers and SAAS products are that are used are considered to be data adequate locations

In terms of Data Minimization we only gather information essential to be able to accurately match you with a Financial Advisor to receive your no obligation consultation.

We use appropriate technological processes to protect large amounts of data transfers as required e.g. encryption, https, encrypted transfers etc.. Single packets of data, for example individual user data for a single enquiry, is not considered of high risk and is not redacted or pseudonymized to allow the service to be provided quickly by the financial adviser. We have no paper records to redact.

Our Data Protection Officer conducts GDPR & PECR training with all relevant employees to ensure proper handling of personal data.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

CONTROLLING YOUR PERSONAL INFORMATION

By law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [email protected] or write to: The Data Controller, Performance Leads Ltd, Blake House 2A St Martin’s Ln, York YO1 6LN.

Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected] or write to: The Data Controller, Performance Leads Ltd, Blake House 2A St Martin’s Ln, York YO1 6LN. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints:

We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see contact details section below).

If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Contact us:

You can e-mail us at [email protected] or write to us at the following address The Data Controller, Performance Leads Ltd, Blake House 2A St Martin’s Ln, York YO1 6LN.

To top