At Hanover Pensions Limited, The Hanover Trustee Company Limited and Culver Financial Management Limited, we are committed to protecting the privacy of your personal data in accordance with Data Protection legislation. This Privacy Policy sets the basis on which we will process your personal data when you visit our website at hanover-pensions.co.uk (“Site”).
For further details about us, see the How to contact us section at the end of this Privacy Policy.
What personal data do we collect from you?
If you contact us with an enquiry about our professional services through the Site, we will ask you to supply essential contact details which we need in order to identify you and deal with your enquiry:
- Name
- Contact information including email address
- Phone number
- Where applicable, country of residence, and
- Where applicable, the company or other entity you represent and your job title.
Depending on the nature of your enquiry, we may collect from you further details, such as the circumstances in which you are making the enquiry, the professional services that may be of interest to you, or where you are interested in a possible position with us. In each case, we will only ask you to provide the information which is necessary and appropriate.
If you make a payment through the website’s payment portal, your credit or debit card number will be collected and used to make the payment, but we do not store such information.
What do we do with the information we gather?
We will process the personal data that you give us, or we collect from you, so that we can supply you with the information about the firm’s professional services (including information about the Ince Group plc and our affiliates within the group) that you ask us to provide or we consider it appropriate to do so, understand your needs and provide you with a better service. The legal basis on which we do so is normally that it is necessary for our legitimate interests in promoting and marketing the firm and our professional services. Where we need to process special categories of data (`sensitive data’) or criminal records relating to you, we will only do so with your explicit consent or where this is necessary for the establishment, exercise or defence of legal claims.
If you proceed to instruct us, or the entity you represent does so, we will process the personal data in order to provide our professional services, to understand your needs and provide you with a better service, in accordance with our Terms of Business and the Retainer letter than we will issue to you. Further details of how we process personal data within the Ince Group are set out in our Data Protection Notice.
We provide a wide range of additional services for our clients and contacts, such as updates on legal developments and seminars. We would like to use the details on our database in order to inform you of these, and the different legal services we provide. If you do not wish us to use your personal data in this way, please tick the relevant box situated on the form on which we collect your data. All future marketing communications will also contain a simple way to opt out of receiving such further communications from us.
Your personal data will not be used for any other purpose, unless we are required to do so by law, or if you consent to that use.
How long do we keep personal data for?
If you contact us with an enquiry but do not enter into a contract with us, we will normally delete your personal data after two years unless you consent to our keeping your details for a longer period. If you become a client (or the company or other entity that you represent becomes a client), we will normally retain contract information (including personal data) for a minimum of 6 years after the end of the relevant contract or relationship, or for longer where it is necessary for us to do so for the establishment, exercise or defence of legal claims or for compliance with regulatory or other legal obligations or we agree with you to do so. In certain cases, it may not be physically possible to delete certain data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.
Your rights as a data subject
As a data subject you have certain legal rights (subject to certain exceptions under the applicable Data Protection legislation) including the right:
- To access the personal data held about you;
- To ask us not to process your personal data for marketing purposes;
- To withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
- To ask us to rectify inaccurate personal data about you;
- To ask for the restriction of personal data concerning yourself that is inaccurate, unlawfully processed, or no longer required;
- To ask for the transfer of your personal data in a structured, commonly used and machine readable format where the processing is based on your consent;
- To ask for the erasure of personal data concerning yourself where processing is no longer necessary, or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject; and
- To make a complaint to the Information Commissioner’s Office.
Statistical data, cookies and third party websites
When you visit the Site, we collect anonymous statistical data to help us to improve our marketing activities. We do not link this data to anything that identifies you personally.
We use a third-party tool from Google to provide our marketing team with statistical reports. The privacy policy for the tool is available here: https://support.google.com/analytics/answer/6004245?hl=en
You may have reached our Site from an advertisement on Google’s advertising network. Google have published the privacy policy for this advertising network here: https://policies.google.com/privacy?hl=en-GB&gl=uk
You may have reached this site from an advertisement from a provider called AdRoll whose privacy policy is available here: http://www.adrollgroup.com/privacy
Our online payment system uses a tool provided by an organisation called NetPay whose privacy policy is available here: https://www.netpay.co.uk/privacy-policy/
The Site uses cookies in a number of ways, as explained in the Cookie Policy linked to in the footer of our Site.
The Site is hosted within the European Economic Area and any data that you send directly to us online will be processed by these servers.
How to Contact Us
If you have any questions, comments or requests about this Privacy Policy, or would like to exercise any of the rights you have, as set out above, please contact us:
- by email to: dataprotection@incegd.com; or
- by post to: The Data Protection Manager, Hanover Pensions/ Culver Financial Management, 33 Charles St. Cardiff CF10 2GA