Privacy policy

Privacy policy

Willis Owen Limited is an Execution Only Investment Service; this privacy policy explains how we use any personal information we collect about you.

We take protecting your data very seriously and it is important for us to get this right. The General Data Protection Act requires us to make it clear what data we hold about you and how we use it.

What information do we collect about you?

Information about you that we collect and use includes:

  1. Information about who you are, including your name, address, date of birth, nationality, gender and contact details
  2. Information connected to the opening or operation of the products or services we provide to you, including your residency status, bank details and National Insurance number
  3. Information to allow you to access our online services including your email address, any usernames and passwords
  4. Information used to verify your identity, such as details relating to your passport
  5. Sensitive personal data relating to your state of health and medical conditions (for further details see below)
  6. Information that is collected automatically when you visit our website, including your Internet Protocol address (commonly known as the IP address), geographic location, the web browser you are using, and your operating system. We may also collect information on the full click path you use while on our site. For further details see the 'cookies' section below
  7. Information that is collected automatically when we send emails to you, such as whether or not you have opened an email, and, if it was opened what kind of device was used and, if viewed in a web browser, which software was used.
  8. Information about your contact with us for example from telephone conversations or other forms of written and non-written correspondence
  9. Information about you which is provided to us by certain third parties.

How we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • When you complete an application to use one or more of our online services
  • When you use our online services or interact with us via social media
  • When you contact us via telephone
  • When you contact us using email, secure messages, live chat or by letter
  • When you participate in surveys to help us understand you better and improve our products and services
  • When you enter into competitions we may run from time to time
  • When you request literature or marketing emails.

We may also collect personal information about you from commercially or publicly available sources, for example, to verify your identity, check the accuracy of information we hold about you or to obtain contact information if we have lost contact with you.

Our legal basis for using your information

Willis Owen will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws.

Our legal basis for collecting and using your personal information depends on the exact type of information and how and when we collect it. The following legal bases will apply to our processing of your personal data:

  1. Where processing is necessary for the performance of a contract which you ask us to undertake. For example, if you wish to register for our online services or open an investment product, we will require some personal information such as your name, address, date of birth and bank details
  2. Where the processing is necessary for us to comply our legal obligation, such as information which is required by law to open or operate an investment product (for example the collection of your National Insurance Number as a condition of opening an Individual Savings Account (ISA))
  3. Where you have given us your consent for us to process your personal data for a specific purpose, such as receiving marketing material or for processing special category data (in particular details related to your state of health). You may withdraw your consent at any time and for details of how to do so, see below
  4. Where the processing is in the legitimate interests of Willis Owen i.e.
    • To deliver appropriate information and guidance so that you are aware of the options that will help you get the best outcome from our products and services
    • To make you aware of enhancements to our online services which may be made available to existing Willis Owen customers
    • Where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products and services we provide to you
    • To develop new products and services and tailor existing products and services
    • To conduct research and collate management information to improve the products and services we offer.

Where we rely on the 'legitimate interests' basis for processing your data, we will always carry out an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be.

How will we use the information about you?

We have set out below how we use the information we collect about you:

  1. We collect information about you to process your application, manage your account and, if you agree, to email you about other products and services we think may be of interest to you
  2. Where, with your consent, we collect and use sensitive personal information such as that relating to your state of health, this information will only be collected and used for the purposes of tailoring our products and services to better account for any special circumstances or needs you may have
  3. We may pass on your personal information to other companies we have chosen to support us in the delivery of products and services we offer to you or companies who can help us in our contact with you, for example those who may help us to validate your contact details. We will not share your information for marketing purposes with other companies
  4. In processing your application, we may send your details to, and also use information from, identity verification, credit reference and fraud prevention agencies
  5. If you apply for an account when acting for someone else, such as under a power of attorney, we will use the information given to us about the account holder (which will include details of the status of their health) and also the role of the attorney to provide a product and/or service
  6. When you call our office number we will retain a copy of that call for training and security purposes or to help us in the ongoing management of your products and services
  7. If you have provided your consent, we may send you information about products and services which may be of interest to you. When providing your consent, you can choose which types of products, services or information you would like us to share with you.

Who we may share your information with

We will never sell, trade, or rent your personal information to others however, we may share your information with selected third parties including;

  1. Companies we have chosen to support us in the delivery of the products and services we offer to you
  2. Selected third parties who we have chosen to work with which we believe may be of benefit or interest to you (in which case your consent will be obtained)
  3. Companies you ask to share your data with
  4. Credit reference agencies
  5. Fraud prevention agencies
  6. Agencies whose services we use to verify your identity
  7. HM Revenue & Customs
  8. UK regulatory bodies, such as the Financial Conduct Authority and the Information Commissioner's Office
  9. Research, consultancy or technology companies who we have chosen to support us in delivering our products and services to you
  10. Organisation that introduce you to us
  11. The UK Financial Services Compensation Scheme
  12. The Financial Ombudsman Service
  13. Law enforcement and other appointed agencies who support us in the detection and prevention of crime.

Data Retention

Willis Owen will retain all data for as long as necessary for the purpose it was collected for, taking into consideration any potential legal claims as well as any legal and regulatory requirements. Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary but we review our data retention arrangements regularly to ensure that data is only retained for an appropriate period.

How we protect your personal data

We'll always go the extra mile to protect your personal data and take information and system security very seriously. We will always ensure that we have appropriate safeguards in place to protect your information in line with our obligations under the data protection laws. You can find more details about the arrangements we have in place on our data security page.

Withdrawing your consent

Where you have given us your consent to send you information relating to investment markets, personal investing insights or about other products and services offered by Willis Owen or our selected third parties, you have the right to withdraw your consent at any time.

You may also withdraw your consent to our processing of any 'special category' data we may collect or hold about you.

If you wish to withdraw your consent for our use of your data in this way, please contact us by any of the methods set out under 'How to contact us' below.

Individual rights

You have a number of rights under the data protection laws. These are set out below:

  1. You have the right to be informed that your personal data is captured and processed, as laid out in this policy
  2. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate
  3. You have the right to ask us to delete any personal information which we are holding on your behalf
  4. You have the right to ask us to restrict the way we use process your personal information
  5. You have the right to data portability, which means that you have the right to ask us to provide your personal information to a third party provider
  6. You have the right to ask us to object to us using your personal information
  7. You have the right to ask us to object to us using your personal information for marketing purposes
  8. You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address.
    • Willis Owen Limited, PO Box 766, BOREHAMWOOD, WD6 9JS

We will consider all requests and will respond within one month unless your request is complex or we have received a number of requests from you, in which case the response period may be extended by up to a further two months. We will not charge a fee for processing your request but a reasonable administration fee may be charged if:

  • Your request is clearly and obviously unfounded, malicious or excessive; or
  • You request further copies of your data following a previous request.

Data protection law allows us to withhold certain information when dealing with requests for copies of your personal data, such as data relating to financial crime or information relating to legal advice or proceedings. We will let you know if we are lawfully withholding any information when we respond to your request.

Complaints

If you have any complaints or concerns about our handling of your personal information please get in touch with us and we will do our best to resolve. You can contact us by using any of the methods detailed in our 'How to contact us' section.

In accordance with the General Data Protection Regulation, you have the right to complain about our collection and use of your personal information to the Information Commissioner's Office.

  • In writing: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  • By phone: Telephone 0303 123 1113

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on our website. This privacy policy was last updated in September 2019. If there are important changes to how we handle your personal information, we may contact you to let you know.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • In writing: Willis Owen Limited, PO Box 766, BOREHAMWOOD, WD6 9JS
  • By phone: Telephone 0800 597 2525(from overseas 020 8236 1240)
  • By email: enquiries@willisowen.co.uk

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result. The table below sets out how and why we use cookies in the operation of our online services:

Type Name Purpose
Necessary PHPSESSID Preserves user session state across page requests.
Necessary cookieconsent_status Holds the status of whether the Privacy Notice has been viewed.
Necessary message_viewed Used to hold the status of whether a website maintenance/information message has been cleared from view.
Necessary SubscribedToInsights Tracks if the current user has subscribed to insights whilst viewing our ISA Guide.
Necessary FundBasket Holds the funds currently in an Explore Basket to enable purchase journeys.
Necessary FundBasketISIN Holds a single fund selected for a purchase journey.
Necessary risk_level Holds the currently selected Risk Level to enable a Starter Portfolio to be purchased.
Necessary selected_funds Holds the currently selected funds in purchase journey when looking to add more funds.
Necessary inspecie_funds Holds the list of funds added to a Transfer In Instruction to stop duplications.
Necessary FundType Supports the Starter Portfolio and Multi-Asset Fund purchase journeys.
Necessary FundProductID Supports the Starter Portfolio and Multi-Asset Fund purchase journeys.
Necessary Debit_Card_Page Supports the processing of Debit Card Payments.
Necessary Debit_Card_Funds Supports the processing of Debit Card Payments.
Functional Campaign_FirstName Allows the sending of a returning link to visitor.
Functional Campaign_LastName Allows the sending of a returning link to visitor.
Functional Campaign_Email Allows the sending of a returning link to visitor.
Functional hblid Olark Chat - a visitor identifier used to remember visitor between visits
Functional wcsid Olark Chat - a session identifier that used to keep track of a single chat session
Functional olfsk Olark Chat - storage identifier used to maintain chat state across pages (e.g. message history)
Functional _okbk Olark Chat - extra state information (e.g. chat box being open/closed)
Functional _ok Olark Chat - most recent Olark Chat site ID (security measure)
Functional _oklv Olark Chat - the Olark Chat loader version (for improved caching)
Functional _okla Olark Chat - used for caching purposes to improve performance
Functional _okgid Olark Chat - group id the visitor is locked to
Functional _okac Olark Chat - used for caching by setting a hash for assets to determine if they have changed and if they need to be refreshed
Functional _okck Olark Chat - used to test whether the visitor's browser allows cookies to be stored
Functional __top_level Feedbackify
Functional _fby_site_ Feedbackify
Statistics _ga Google Analytics - unique visitor ID
Statistics _gat Google Analytics - used to throttle request rate
Statistics _gid Google Analytics - user ID used to geneate statistical data on how the visitor uses the website
Statistics r/collect Google Analytics - used to send data about the visitors device and behaviour.