Wren Investment Office Limited (Wren) is authorised and regulated by the Financial Conduct Authority, registration number 648953. Wren’s registered office is 66 Lincoln’s Inn Fields, London, WC2A 3LH and its place of business is 84 Eccleston Square, London, SW1V 1PX. Wren is registered with the Information Commissioner’s Office under number ZA206260.
Wren is committed to the security, confidentiality, and protection of personal data. This policy explains how we use personal data and should be read in conjunction with any other documentation provided directly to you.
This policy was last updated on 1st September 2021 and may be amended from time to time.
DATA PROTECTION REGULATION
The Data Protection Act (DPA) 2018 superseded the Data Protection Act (1998). Under the DPA 2018, the definition of personal data was expanded, and individuals were given the right to control and choose how their personal data is used.
According to the Information Commissioner’s Office (ico.org.uk) the DPA 2018 applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier. The data we collect is detailed below.
A controller determines the purposes and means of processing personal data. For the purposes of this policy, Wren is a data controller in respect of any personal information we hold about you.
in relation to personal data, a data processor means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
HOW WE OBTAIN YOUR PERSONAL DATA
We collect personal data through services that we provide and receive. Typically, it comes from the following sources:
PERSONAL DATA WE COLLECT
If you are a customer, we collect information to assist in the provision of services to you. This information may include:
If you are a business associate, we collect information to monitor services we have contracted for, or to assess services that are available to us. This information may include:
Please note, we do not request any special categories of personal data. Under the DPA 2018, special category data is more sensitive and therefore needs more protection. Categories include race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; sexual orientation.
When requested, you are not required to provide personal information, however, in doing so, we may not be able to proceed with a business relationship.
OUR USE OF YOUR INFORMATION
We collect and use information to provide services to you, or to receive services from you, in accordance with contractual obligations. We only use your information for our legitimate interests or, in certain circumstances, for those of a third party.
Our legitimate interests are:
Personal information may be disclosed to third party associates who provide us with professional, legal, accounting, or other services. This may include providing personal data to third parties to comply with anti-money laundering regulations. Such processing may involve the use of automated decision making to confirm your identity.
All third parties are required to maintain the confidentiality of your personal data and to treat it in accordance with the law. Third parties are not permitted to use your data for any purpose other than that covered by their contractual arrangements with us.
We may disclose your personal information as required by, or to comply with, legal, regulatory, or statutory requirements, or at the request of supervisory or governmental bodies.
Your personal data is not shared with any other organisations for marketing purposes and will not be used by us for marketing purposes unless explicit consent has been provided by you.
Data protection laws provide you with the following rights:
Please note, under the DPA 2018, there is scope for these rights to be ignored if compliance with them seriously impacts our ability to carry out functions when processing data for scientific, historical, statistical, and archiving purposes.
To exercise any of these rights, please get in touch using the contact details at the bottom of this policy.
Please note, if you are a client, by executing some of these rights, we may not be able to continue providing services to you.
If you are not satisfied with how we have handled your information you have a right to complain to the Information Commissioner’s Office (ico.org.uk).
We can retain your personal information for as long as required to provide services to you. After the termination of contracts, we may retain data for a period of six years to comply with legal and regulatory requirements. After the expiration of six years, your personal data will be deleted.
If compelled to do so by statutory, regulatory, or governmental bodies, we may retain your personal data for longer than six years.
The DPA 2018 recognises that children need particular protection as they may be less aware of the risks involved with their personal data. We may collect children’s personal data for the provision of certain accounts, such as a Junior ISA (JISA). Under such circumstances, we only collect limited personal data such as full name including title, date of birth and residential address.
Children have the same rights as adults over their personal data.
THIRD PARTY WEBSITES
Our website may include links to others, but we are not responsible for the accuracy or completeness of information supplied by third party sites. We suggest you read the individual privacy policies for any websites visited.
When accessing our website and client portal, cookies, small text files placed on your computer, may be used. Browsers recognise when a cookie is offered and permit you to refuse or accept it. We cannot see your IP address when you access our website, however, it may be used by Google Analytics to track user behaviour.
The DPA 2018 imposes restrictions on the transfer of personal data outside the UK.
We may, at times, under agreements with third party business associates, transfer or store your personal data outside the UK or other countries deemed to have adequate levels of protection in place; however, this would only happen if the third-party business associates we are contracted with adhere to similar protections provided by the DPA 2018.
If you have any questions or wish to exercise any of the rights detailed above, please email firstname.lastname@example.org or write to: Chief Operating Officer, Wren Investment Office Limited, 84 Eccleston Square, London, SW1V 1PX.