PRIVACY NOTICE

Scottish Widows Platform is a trading name of Embark Investment Services Limited (EISL), a company incorporated in England and Wales (company number 09955930). Registered office at 100 Cannon Street, London, EC4N 6EU. Embark Investment Services Limited is authorised and regulated by the Financial Conduct Authority (Financial Services Register number 737356).

The Scottish Widows Platform Privacy Notice applies to:

• Financial advisers
• Customers
• Prospective customers
• Former customers

of Scottish Widows Platform (a trading name of Embark Investment Services Limited, a wholly owned subsidiary of Embark Group Limited and Lloyds Banking Group). This details how we will collect and process the personal data that we hold about you and your rights under the UK GDPR and UK Data Protection Act 2018 in respect of the data held.

Embark Investment Services Limited will be the Data Controller as defined under UK Data Protection legislation.

We will only process your personal data where we have a legal basis for doing so under the UK GDPR. Here are our lawful reasons for processing:

Contract:

We need to collect and use your personal information to be able to provide you with and administer the Scottish Widows Platform product that you want to open and use. This includes your contact details and bank account information.

Consent:

We rely on explicit consent to process sensitive personal data. We need your permission to record information about any health issue or other vulnerability that affects how you interact with Scottish Widows Platform. This information informs our staff the best way to support a client with additional needs. For example, we may wish to record that an individual has dementia so that we know to provide additional context at the beginning of a letter or phone call.

We also rely on consent to send marketing about Scottish Widows products and services to financial advisers.

Consent can be withdrawn at any time and once we receive this retraction, we will cease to process your data for this purpose immediately.

Legal Obligation:

We must collect and process your data to comply with our legal and regulatory obligations. For example, we need to check your identity, address, and source of funds to comply with Money Laundering Regulations. If you are suffering from serious ill-health and wish to withdraw your pension funds early tax-free, we will need to record this and evidence from a registered medical practitioner in line with the UK Government Pensions Tax Manual.

Legitimate Interests:

We rely on legitimate interests for the following purposes:

• Training and monitoring
• Testing and improving our services
• Data sharing with our parent company Lloyds Banking Group, for example, to enable us to make use of services that are shared across the Group to increase efficiency, or to enable marketing, and marketing profiling activities to take place where this is lawful.

We will collect personal data from you at the outset of your relationship with us, from your application as well as from other third parties such as your financial adviser and any providers that are transferring money or assets to us on your instruction.

Scottish Widows Platform obtain personal data from you and other third parties you instruct on your behalf throughout the course of your relationship with us.

We also collect information provided to us by Lloyds Banking Group, for example, information on your contact details to pre-populate your application form for products, to make them easier for you to complete, or information on any support needs you have informed them of, so we can interact with you in a way that meets those needs.

We need to collect and use your personal information to be able to provide you with the product(s) that you want to use, and to administer them. We cannot provide the service if you don’t give us the information we ask for. This personal data will include:

• Contact information such as name and address, telephone numbers and email addresses.
• Information from your contact with us; voice recordings from telephone calls, letters and emails. We also record your contact preferences so that we know how you would prefer to communicate with us.
• Socio-demographic information; age, employment status, profession, earnings, gender, other sources of wealth.
• Family circumstances information; marital status, beneficiary information.
• Transactional information; account transactions, access to our online client portals.
• Legal; national identifiers, copy documents relating to your identity, nationality and citizenship such as birth certificate, passport, proof of address documents, marriage certificates.
• Information relating to your health, such as a medical condition or disability, or personal circumstances, such as a bereavement, if it is necessary to support you in your communications with Scottish Widows.

Scottish Widows Platform receives limited personal data from other organisations, such as fraud agencies, to meet regulatory obligations around preventing financial crime and to administer your account.

Scottish Widows Platform may share your personal data with the following organisations. These data transfers will only be completed when strictly necessary and any transfers outside of the UK will only take place when we are certain that the personal data is afforded the same level of protection as is required under UK Data Protection legislation.

• Other companies in the Embark Group who provide administration and oversight services. For example, our legal or software development teams.
• Lloyds Banking Group (LBG) as our parent company, to enable a consistent experience across the Groups’ products, utilise shared resources and enable the business to be run efficiently. They may also use this data for marketing purposes where you have previously consented to, or not refused marketing from one of the LBG entities; this may also include profiling for these purposes, for example assessing whether a product may be suitable for you, or you meet the product eligibility criteria. Please see their privacy notice here for further details on how your data is stored, shared and protected in LBG, and which entities make up the Group.
• Credit reference agencies to check your identity, address, and source of funds, and to prevent fraud. Any checks performed may be recorded on your credit history.
• Any governmental, legal, or regulatory body if required to do so by applicable law and regulation. For example, the Financial Ombudsman Service (FOS) or the Information Commissioner’s Office (ICO).
• Your appointed financial adviser, third parties appointed by your financial adviser, third party investment managers, and product providers with whom you or your financial adviser instructs us to invest.
• Companies which provide services in connection with the administration of your account. For example, maintaining our client database or securely storing files.

We will otherwise keep your personal information confidential and never use it for any other purpose or pass your details to any third parties without your knowledge or consent.

We will retain your personal data for no longer than is necessary to provide the services under the Terms and Conditions applicable to the account and to meet any legal or regulatory obligations that may apply. Usually, your personal data will be kept for no longer than seven years after your end of relationship with Scottish Widows Platform. However, we may keep your data for longer if we cannot delete it for legal, regulatory, or technical reasons.

If we store data on you relating to a support need that you have, eg. Having had a recent stroke, this information will be destroyed when one of the following conditions is met:

• You withdraw consent for Scottish Widows Platform to hold this personal data. You can contact us to do so.
• You end your relationship with Scottish Widows Platform.
• Scottish Widows Platform become aware that the support is no longer required.

You have a number of rights over your personal data under the UK General Data Protection regulation (GDPR). To Enact one of your subject rights please contact Scottish Widows Platform.

1. 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 Data Subject Access Request (DSAR). 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.
2. The right to data portability, where Scottish Widows Platform can have personal information we hold about you transferred securely to another service provider in electronic form.
3. The right to have any inaccurate personal information corrected.

4. The right to have any personal information erased if there is no lawful reason for Scottish Widows Platform to keep it. This is sometimes known as the right to be forgotten. You can also withdraw your consent to process any personal data where this is our lawful reason to collect and process it.
5. The right to object for example, where we are relying on legitimate interest as our lawful basis (as detailed earlier in this notice). We are only required to uphold this right where we do not have compelling grounds to continue the processing, having assessed it against the reasons for your objection.
6. The right to restrict some processing, for example, you can ask us to stop processing for some activities while you are waiting for data to be corrected or have objected and are waiting for us to assess whether we have compelling grounds to continue the processing. This right only applies in limited circumstances.

Scottish Widows Platform does not conduct any automated processing of personal data that produces legal or significant effects so the UK GDPR right relating to decisions based solely on automated processing, including profiling, which produces a significant effect does not apply.

If you have any questions regarding how we use the data that we collect, please contact:

The Group Data Protection officer
Embark Group
100 Cannon Street
London
EC4N 6EU

If you are not satisfied with any aspect of how we have managed your data, you have the right to complain to the Information Commissioners Office. For further details of your rights under the UK’s data protection legislation and regulation please contact the Information Commissioner’s Office here.

By signing our product application form, you are agreeing to the use of your Personal Information for the purposes and on the terms set out above.

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Any changes we make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to marketing@embarkgroup.co.uk.