Altus Wealth Management Privacy Policy - Altus Wealth Management

Privacy Policy

Last updated: August 2018

Altus Wealth Management (“us“, “we“) respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Policy only applies to personal information that we collect through www.altus.co.uk (“our Website“).

For personal information that we collect when you use or interact with our services, please see our Data Protection Statement which is available at www.altus.co.uk/data-protection-statement.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

Quick Links

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

The data controller of personal data collected via the Website is Perspective (North East) Limited registered at Paradigm House, Brooke Court, Wilmslow, Cheshire SK9 3ND with company number 04163906. Perspective (North East) is registered as a data controller with the Information Commissioner’s Office under registered number Z7167367.

What personal information do we collect via the Website and why?

When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered to be personal information under applicable data protection laws.

Specifically, we will collect the IP address of the device (e.g. your phone, mobile, laptop or desktop computer IP address) you are using to access our Website. From this we may be able to identify the approximate location of the device you are using to visit our Website and the domain that it is using to access the Internet.

We may also collect information about how your device has interacted with our Website, where it comes from, and what content on our Website is of interest to you. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to visitors.

Some of this information may be collected using cookies and similar tracking technology. A cookie is a small file of letters and numbers that is sent to your browser and stored on the hard drive of your computer (or internet enabled device) when you visit a website. Our Website use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use our Website and also allows us to improve our Website. We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Website – we need them to make our Website work properly and to keep the Website secure.

Analytical/performance cookies. These cookies collect information in an anonymous form about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using them. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences.

Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

The following table sets out some additional information about the cookies we use on our Website:

Type of Cookie	Purpose	Expiry
Google Analytics Cookies	Used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve our Website. The cookies collect information in an anonymous form, including the number of visitors to our Website, where visitors have come to our Website from, the pages they visited and the type of device and browser/operating system they used to do so.
	_ga is used to distinguish users	24 months
	_gid is used to distinguish users	24 hours
	_gat is used to throttle requests made of our Website (helping to limit congestion)	10 minutes
DoubleClick (IDE)	IDE is used for serving targeted advertisements that are relevant to you across the web. Targeted advertisements may be displayed to you based on your previous visits to our Website. For example, advertisements about a topic you have expressed an interest in while browsing our Website may be displayed to you across the web. In addition, these cookies measure the conversion rate of any advertisements presented to you.	18 months
pfglcookie	This cookie is used to establish whether a user is a repeat visitor to the Website.	1 day

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed and can be used by websites to recognise your computer when you later re-open your browser and browse the internet again.

We use the services of Google Analytics to optimise our Website. Google Analytics is a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses cookies, text files stored on your computer, to help us analyse how visitors use our Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google in their data centres. We use Google Analytics with an anonymisation add-on so that the IP addresses later transmitted to Google are modified in advance to prevent any direct references to particular people. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity on our Website for us, and providing other services relating to activity on the Website and internet usage to us. Your IP address, which has been transmitted by Google Analytics, will not be associated with any other data held by Google. You can prohibit Google from collecting and analysing the cookie generated data about your use of the Website (including your IP address) by downloading and installing the browser plugin available here: http://tools.google.com/dlpage/gaoptout?hl=en.

You have the right to choose whether or not to accept cookies. You can block cookies by changing your browser settings so that cookies from our Website cannot be placed on your computer or mobile device. The “help” portion of the toolbar on most internet browsers will tell you how to change your browser cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Please note that if you choose not to accept cookies you may not have may not have access to certain features that make your experience of our Website more efficient and some of the features on our Website may not function properly.

If you visit our Website using a mobile device (e.g. a smartphone or tablet) you can refuse the future use of Google Analytics via the link below.

Click here to opt-out of Google Analytics.

By activating the link, we will put a cookie in your browser, which signals to us that we should prevent Google Analytics from using your device. Please keep in mind that you will have to repeat the refusal process if you remove the cookies from your browser.

Who do we share your personal information with?

We may disclose your personal information to the following categories of recipients:

to our third party services providers who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website);
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; and
to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will usually be that the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. However, in general, the relevant legal basis will depend on the personal information concerned and the specific context in which we collect it. We may also collect personal information from you via our Website where we have your consent to do so or where we need the personal information to perform a contract with you. In some cases, we may also have a legal obligation to collect personal information from you.

International data transfers

We will only process your personal data inside the European Economic Area.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Cookie data is retained in accordance with the timescales listed in the table above and is automatically deleted at the end of the periods specified.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below http://www.altuswealth.co.uk/contact-us/
In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below http://www.altuswealth.co.uk/contact-us/
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below http://www.altuswealth.co.uk/contact-us/
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will check whether you are happy for us to continue processing your personal information following any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact Trevor Clark either by telephoning us on 0191 2173340 or by emailing us at enquiries.northeast@pfgl.co.uk.

All calls to and from our landlines and mobiles are recorded to meet regulatory requirements. For more information about call recording, please see our Data Protection Statement at http://altus.co.uk/data-protection-statement.

Terms of Use

Browse at your own risk

Please note that you access and use the Website at your own risk. Altus Wealth Management is not responsible for any type of loss or damage which you may sustain as a result of accessing and using the Websites. Altus Wealth Management assumes no responsibility for the contents of any other Websites to which the Websites have links and if you access any such linked Websites you do so at your own risk. Altus Wealth Management’s inclusion of links to such websites does not imply any endorsement by Altus Wealth Management of the materials on such Websites. Altus Wealth Management does not permit any third party to operate a link to any of the Websites nor does it permit any third party to frame the Websites without obtaining Altus Wealth Management’s prior written consent.

The Websites are accessed via the world-wide web (“WWW”) which is independent of Altus Wealth Management. Your use of the WWW is at your own risk and subject to all applicable national and international laws and regulations. Altus Wealth Management has no responsibility for any information or services obtained by you on the WWW. Altus Wealth Management reserves the right to modify, supplement, move or delete portions of or add to the Websites at any time with or without notice.

Intellectual Property

All copyright and other rights (including database rights, trademarks (whether registered or unregistered) and all other intellectual property rights) in and to the Websites and their contents (which for the avoidance of doubt shall include all information contained in or available from the Websites (“the Contents”)) are owned by or licensed to Altus Wealth Management or are otherwise used by Altus Wealth Management as permitted under applicable laws. Unless Altus Wealth Management explicitly states otherwise in writing, you may use, view, download, copy or print textual or graphic content of the Websites provided that it is solely used by you for the purpose of enquiring about the services provided by Altus Wealth Management and provided that you do not change or delete any copyright, trademark or other proprietary notices on such content. Under no circumstances may you use any Content in a manner that may give a false or misleading impression of Altus Wealth Management.

You agree not to copy, reproduce, store in any medium (including in any other websites), distribute, transmit, modify, alter, disseminate, create derivative works from all or any part of any of the Websites or edit any part of any of the Websites other than as permitted above without obtaining Altus Wealth Management’s prior written consent.

Specific Prohibitions

You may not use any device, software or routine to interfere or attempt to interfere with the proper working of the Websites nor may you attempt to decipher, de-compile, disassemble or reverse engineer any of the software comprising or in any way making up a part of any of the Websites.

You agree to use all Websites for lawful purposes only and in a manner that does not infringe the rights of, or restrict the use of any of the Websites by, any third party.

Liability

The Websites and the Contents are provided for general information purposes only and whilst Altus Wealth Management has taken every care in the preparation of the Websites and the Contents, Altus Wealth Management cannot guarantee that the Contents will be completely up to date and free of mistakes. To the extent permitted by applicable law Altus Wealth Management makes no warranties, representations and/or undertakings (express or implied) in respect of the Websites and the Content (including the accuracy, reliability, suitability, quality, availability or completeness thereof). Altus Wealth Management excludes all liability (other than for death or personal injury caused by its negligence) in relation to the Websites and the Contents, whether such liability arises in contract, tort, negligence, breach of statutory duty or otherwise (including, without limitation, liability in respect of any losses, damages, costs or expenses of any nature whatsoever incurred or suffered by you of an indirect or consequential nature, such as loss of profits, data, business or goodwill). Altus Wealth Management makes no claims or representations that any or all of the Contents may be lawfully viewed or downloaded outside England and Wales and unless otherwise specifically stated, the Contents and these Websites are directed solely at consumers and/or businesses that access these Websites from England and Wales. Access to such materials may not be legal by certain persons or in certain countries. If you choose to access the Websites from outside England or Wales, you do so at your own risk and are responsible for compliance with the laws of your jurisdiction.

Computer Viruses and Errors

Whilst Altus Wealth Management will use reasonable endeavours to ensure that the Websites do not contain or promulgate any errors, viruses, bugs, other malicious code or harmful components and will be uninterrupted Altus Wealth Management makes no warranty or representation that this will be the case. However it is recommended that you should virus check all materials downloaded from the Websites and regularly check for the presence of errors, viruses, bugs, other malicious code, and harmful components.

Altus Wealth Management excludes to the fullest extent permitted by applicable laws all liability (other than liability for death or personal injury caused by Altus Wealth Management’s negligence) in connection with any damage or loss caused by errors, viruses, bugs, other malicious code or harmful components originating or contracted from the Websites and any interruptions in the running of the Websites.

Termination

Altus Wealth Management shall have the right to immediately terminate your use of the Websites if Altus Wealth Management determines in their sole discretion that you have breached these terms and conditions or have otherwise been engaged in conduct which they determine in their sole discretion to be unacceptable.

Altus Wealth Management Ltd Privacy Policy