KLO Financial Services Privacy Policy

Introduction

To provide you with financial planning services, KLO Financial Services Ltd (henceforth referred to as “we” and “us”) will collect and hold personal data about you.

We are required to comply with the Data Protection Act and the UK General Data Protection Regulation (also known as UK GDPR), a UK law which came into effect on 01 January 2021.

This legislation sets out the key principles, rights, and obligations for most processing of personal data in the UK.

The lawful basis and purpose for the processing of your personal data

We will only process your personal data where we have a legal basis for doing so.

This includes:

• Where you have provided written consent to us for doing so.
• Where processing is necessary for the performance of a service between you and us or to take steps to enter a contract.
• Where processing is necessary for compliance with a legal or regulatory obligation.
• Where we have a legitimate interest upon which the data may be processed. Any decision to process data based on legitimate interest will be made on a case-by-case basis and in line with the guidance set out in UK Data Protection legislation.

Why We Need Your personal data

We need your data for us mostly to:

• Provide financial planning services to you which may include, but not be limited to, giving you financial advice, and making recommendations as to investments and financial products which are suitable for you, considering current financial markets and economic conditions, availability of products and services and the providers of those products and services, as well as a detailed analysis of your personal circumstances and requirements.
• Comply with the regulatory obligations set by the Financial Conduct Authority regarding the relevant ‘Know Your Client’ requirements when onboarding new clients, including combatting fraud, money-laundering and criminal activities.
• Comply with the Financial Conduct Authority’s requirements for record-keeping for the purposes of audits and reviews, records of transactions undertaken, and customer histories for prescribed periods of time as directed, as well as to investigate and resolve complaints.
• Respond to any legitimate legal requests for information about you coming from any governmental, legal, or regulatory body if required to do so by applicable law and regulation.

The information that we collect

We will collect personal data from you at the outset of your relationship with us.

We will also collect personal data from you and other third parties you instruct on your behalf throughout the course of your relationship with us.

This personal data will include:

• Contact information such as name and address, telephone numbers and email addresses.
• Socio-demographic and financial information such as age, employment status, profession, gender, earnings, other sources of wealth.
• Family circumstances information such as marital status, dependants, beneficiaries.
• Transactional information such as account transactions, access to online client portals.
• Legal information such as copy documents relating to your identity, nationality, and citizenship such as birth certificate, passport, proof of address documents, marriage certificates.
• Special category data if necessary, such as information relating to your health, medical conditions, and disabilities.

Our company’s website https://klofinancialservices.com/  also uses cookies to help us to provide you with a good experience when you browse our website and to allow us to improve our site performance and functionalities.

Sharing Your personal data

To carry out our legitimate business and to provide you with financial planning services, as well as for the purposes of compliance, IT systems security, data management and control and auditing, we have entered into agreements and might share your information with the financial services and products providers listed below. This personal information sharing would be based exclusively on legitimate business reasons and if required by applicable law and regulations.

Full details of these companies’ address and contact details are available on request:

Aegon	Aviva	Brooks MacDonald	Canada Life
Canaccord Genuity	Curtis banks	Edge Creative	FE Analytics
Fidelity	Genovo	HSBC	Intelligent Office
Insignis Cash Solutions	Intelliflo Planning	IPM	Margetts
Octopus	Prudential	Quilter	Rathbones
RBC Brewin Dolphin	Scottish Widows	Standard Life	Triple Point
Outsourced Paraplanning	Royal London	The Exeter	Utmost

Retention of Your personal data

We undertake to review the data we hold about you on a regular basis to ensure compliance with data protection law.  During any review, we will:

• Delete any data which is trivial or transitory in nature or, which in our opinion, is no longer required for the purposes set out above.
• Update the data to ensure that any errors or inaccuracies are corrected and to take account of any change of circumstances.
• Archive data. Where in our opinion data has ceased to be active, we will archive it and process it only as archived data. Any data which is deemed archived data will only be processed in limited circumstances.
• Subject to the data retention periods, as detailed below, securely delete the data when it is identified that we no longer need to hold it.

We may retain and process your data for the following periods.  If more than one period applies to the same data, we will retain the data to the last such period to expire:

• We will hold any agreements between you and us for a period of six years from the termination or expiry of the agreement unless we have been notified of any claim or circumstance which might give rise to a claim under or by reference to such agreements.
• We will process data relating to investments which we have provided advice on and / or arranged for you. We will process such data throughout the entire period you are and remain a client of the firm and for a period of not less than six years following our ceasing to provide service to you regarding those investments.  In the case of long-term investments, we may process your data until the date of maturation of such long-term investments.
• We will hold data as required by any Regulator until the end of any limitation period imposed by the Financial Conduct Authority. The general principle is that records should be retained for as long as is relevant for the purposes for which they are made. Records should generally be retained for a minimum of five years (unless otherwise stated). Five years generally for investment business and related activities covered in the FCA’s Conduct of Business Sourcebook (COBS). Indefinitely for Pension Transfers and opt outs and Free Standing Additional Voluntary Contributions (FSAVCs). Three years for mortgage or insurance advice.
• We will hold data as required by any relevant third party until the end of any limitation period imposed by that relevant third party, which in the case of HMRC shall be seven years, unless we are notified that any period is considered “open” by HMRC in which case it will be until we are notified the period is “closed”.
• We will hold data as required for the purposes of any legal proceedings for a period of six years following the conclusion of any such proceedings unless a longer period is required pursuant to any court rule or enactment. Proceedings will be taken to have concluded on the expiry of any period given for appealing any final judgment or on the date of concluding any settlement staying all relevant claims if the proceedings were settled before judgement.
• Save for the above, we will hold data for a maximum of 50 years from the date we receive the data.

All storage of data, whether active data or archived data will be in accordance with standard industry practices and will be undertaken in accordance with organisational systems and procedures, which will be regularly reviewed, to maintain the security of data.

Data Portability

On the termination or expiry of any agreement to provide services to you and on your written request, we will, subject to our right to retain copies of data for the purposes set out above, agree to return any data you have provided to us in a structured, commonly used machine-readable format, or transfer the same to a new data controller nominated by you.

Your Data Protection Rights

You have a number of rights under the Data Protection legislation, including:

• The right to request a copy of the personal information we hold on you. When you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee.
• The right to have personal information we hold about you transferred securely to another service provider in electronic form.
• The right to have any inaccurate personal information corrected.
• The right to request data erasure.
• The right to have any out-of-date personal information deleted once there’s no business need or legal requirement for us to hold it.
• The right to object or restrict some processing, in limited circumstances and only when we don’t have legitimate grounds for processing your personal information.
• The right to object to your personal information being used to send you marketing material. We will only send you marketing material where you’ve given us your consent to do so. You can remove your consent at any time.

In addition to contacting your dedicated financial planner, if you have any questions regarding how we use the data that we collect, please contact:

By post:

KLO Financial Services Ltd

Pure Offices, Lake View House, Wilton Drive, Tournament Fields,

Warwick

CV34 6RG

By e-mail:

enquiries@klofinancialservices.com

By phone:

01926 492406

Where you exercise your right to request access to data of which you are the data subject, we will undertake to respond to you within 30 calendar days of receipt of your request.  There will be no charge for this service unless the request is manifestly unfounded or excessive, in which case we reserve the right to charge a fee or refuse to respond.

You may at any time, by giving notice to us in writing, request that we cease to process your data.  We will undertake to comply with any such request as soon as is reasonably practicable.

We shall not be obliged to provide you with the information:

• Where you already have this information
• Where we are subject to an obligation of professional secrecy prohibiting the disclosure of the information
• Where disclosure would render impossible or severely impair the achievement of the reasons for which the data is to be processed. In such cases, we will do what we can to protect your rights and freedoms with respect to our processing of the data.

You have the right to complain regarding any aspect of the processing of your data and any breach of the above rights to the relevant supervisory authority who, in the case of the United Kingdom, is the Information Commissioners Office, which may be contacted as follows:

• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF .
• Online: ico.org.uk
• Phone: 0303 123 1113

Legal Terms

If any provision, or part thereof, of this agreement is found by any court or administrative body of competent jurisdiction to be invalid, unenforceable, or illegal, the other provisions shall remain in force.

In the event of any change in Data Protection Law occurring after the date of this notice which requires the adoption of revised provisions dealing with data retention or portability, the parties will use all reasonable endeavours to agree such consequential changes to this document as may reasonably be required to comply with the requirements of Data Protection Law (“Compliant Terms”) and incorporate the same as an amendment to this Data Protection and Privacy Notice.