Privacy Policy

Goodwin Barrett Ltd company number 09294215, registered in England & Wales. Authorised and regulated by the Financial Conduct Authority 830495. Goodwin Barrett Ltd is registered with the Information Commissioner's Office under registration reference ZA085532

At Goodwin Barrett we are committed to safeguarding the privacy of our customers.  The privacy policy has been established to inform you as to how we use your personal data, who we share it with, our legal obligations and legal bases for processing your personal data aswell as what this means.  This policy should be read in conjunction with our Cooke Policy and the Terms and Conditions of our service.

If you have any questions about this privacy policy or our treatment of your personal data, please contact us:

• by email to enquiries@goodwinbarrett.co.uk
• by post to Goodwin Barrett Ltd, Mikar Business Park, Northolt Drive, Bolton BL3 6NJ
• by telephone on 01204 471280

Controller

Goodwin Barrett Ltd is the controller of personal data submitted and is responsible for the security and safety of your personal data.

What data do we collect

We collect, use, store and transfer different kinds of personal data about with regard to the services we provide.

Identification data such as your first and last name, maiden name, marital status, title, date of birth and gender

Contact data such as your current and previous addresses, email address and telephone numbers

Financial Data such as investment and pension details and account history for the purposes of investigation your potential mis selling claim

Claims related data such as information provided by yourself for the purposes of investigating your potential mis selling claim

Transaction data such as details of products and services you have engaged us for

Technical data includes internet protocol (IP) addresses, browser type and version, time zones setting and location and other technology and devices you use to access our website

Usage data such as information about you use our website, products and services

Marketing and communications data includes your preferences in receiving marketing/communications from us and our 3^rd parties and your communication preferences

Your Rights

You can control, access or restrict the use of your data.  You can withdraw your consent for us to contact you at any time. However, if you have signed a contract our contractual rights will still apply and we may contact you in relation to a cancellation fee or any outstanding monies owed to us.

Failure To Provide Data To Us

Please note, we require certain personal information to be able to complete our services. If you do not provide this, we may not be able to fulfil our contract with you. In this event, we will explain what data is required and why. If you do not wish to provide this, we have the right to terminate your contract with us in accordance with our Terms and Conditions.  We will inform you should we fail to terminate your contract with us.

Legitimate Interests

In respect of our legitimate interests, we have a legitimate interest in keeping you updated about any further services offered by us which may be of interest to you both during and after the conclusion of your contract with us, including communication of any developments that may have an impact on your original service (e.g. a change in rules or processes which may enable us to help you with a claim where previously we could not). We will use the details you have provided to contact you including by telephone and post. If you do not wish for us to contact you in this manner, or by a specific method, you will be able to unsubscribe at any time to one or all contact methods.

Furthermore, we may offer other services in areas of financial mis-selling.  As part of this service, we can provide a direct referral to 3^rd parties. We will always ask for your consent before doing so and this is entirely your choice.

We also have a legitimate interest in using your data to help us to review our services and obtain analytics in respect of our customer base.

We may also be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling. In these circumstances, we may be required to keep your data by law.

How do we collect your data

We use different methods to collect data from and about you, including:

Direct Interactions: You may provide us with your personal data and product/policy information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you engage our products and services, request marketing to be sent to you or to provide some feedback on our services.

Automated Technologies or Interactions: You may provide us with your personal data when you interact with our website, we may automatically collect technical data about your equipment, browsing actions or patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookies Policy for more information.

Third Parties: We may receive personal data about you from various third parties, which may be obtained from technical data under analytics providers such as Google and identity and contact information from data brokers by which you have provided your consent to receiving your personal data for the purpose of contacting you about our services.

How do we use your personal data

Purpose/activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client	(a)     Personal data (b)     Contact information (c)     Policy information	Necessary for the purposes of the contract
To process and deliver our service to you such as:   Investigating your claim Requesting information from other financial institutions and dispute resolution providers on your behalf	(a)     Identity (b)     Contact information (c)     Financial details (d)     Claims related details (e)     Marketing and communications	Necessary for the purposes of the contract
To manage our relationship with you:   Notify you of changes to our terms and conditions To ask for a review or complete a satisfaction survey	(a)     Identity (b)     Contact information (c)     Profile information (d)     Marketing and communications	(a)     Necessary for the purposes of the contract (b)     Necessary to comply with a legal obligation (c)     Necessary for our legitimate interests (which includes maintaining accurate and up to date records and to study how our products and services are used)

Recipients of Your Data

We control the use of your data as you have directed.

To allow us to provide our services to you, the following third parties provide critical functions to our business and will process your personal information as directed by us and in accordance with strict data security arrangements:

• Our Services: during our services we will provide your data, under your specific instruction, to named financial institutions, and, if required, the Financial Ombudsman and FSCS
• Our Systems and IT: we use third party firms who provide essential storage arrangements (including call recordings), software and support to our infrastructure;
• Post and Printing: we use an outsourced print-house who manages our printing, they receive a copy of postal communication and print and send this on our behalf;
• Our Regulators: we may be required to provide your data to our Regulators, who include theFinancial Conduct Authority, the Legal Ombudsman Service and the Information Commissioner’s Office; and
• Our Professional Services: we use professional legal, consultancy and accountancy services to help us fulfil our legal obligations.

We do not sell your data to third parties in any circumstances. We have carefully selected our third parties due to their commitment to keeping your data safe, and all data is processed within the UK. If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.

If you require details of the third parties we use please contact us.

We may also disclose your information with:

•  HM Revenue & Customs, The Financial Conduct Authority, Regulators and other authorities acting as processors based in the United Kingdom who require the reporting of processing activities in certain circumstances
•  Accountants, Solicitors, Compliance Consultants and other like services acting as processors, based in the United Kingdom who require reporting of processing activities in certain legal and/or compliance circumstances
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change such as this occurs, the new owners may use your personal data in the manner set out within this Policy.

Cookies

A cookie consists of information sent by a web server to a web browser, and is stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.If you want to know more general information about cookies, there is a website: http://www.aboutcookies.org/

To learn more about behavioral targeting and advertising visit: http://www.youronlinechoices.com/uk/your-ad-choices

Introduction

Our website uses cookies. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either:

(a)   persistent cookies - will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date

(b)   session cookies - will expire at the end of the user session, when the web browser is closed

(c)   first party cookies – set by the web server of the page and shares the same domain

(d)   third party cookies – stored by a different domain, this can occur when webpages reference a file (such as Javascript), located outside of its domain

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

(a)    we use cookies to identify you when you visit our website and as you navigate our website - cookies used for this purpose are preference cookies

(b)    we use cookies to help us to determine if you are logged into our website - cookies used for this purpose are necessary cookies

(c)    we use cookies to store information about your preferences and to personalise our website for you -cookies used for this purpose are statistical cookies

(e)    we use cookies to help us to display advertisements that will be relevant to you – these are marketing cookies

COOKIE NAME	EXPIRY	CLASSIFICATION	PURPOSE	LAWFUL BASIS
_cfduid	1 Year Peristent	Third Party	Strictly necessary to the functioning of the website	No consent required
_livechat	3 Years Peristent	Third Party	To store preferences upon use of the website	Consent
_adiCookieCheck	Session	First Party	Anonymous collection and reporting of statistical information	Legitimate Interest
_adroll	1 Year Peristent	Third Party	Marketing	Consent
_adal_first_visit	1 Year Persistent	First Party	Stores first time entering website	Consent

Adalyser

We also use Adalyser - An analytics platform that is used to measure response to TV advertising.

COOKIE NAME	TYPE	DATA STORED	PURPOSE
__adal_ca	Persistent	Traffic source / campaign data	Store which advertising campaign drove a user to visit
__adal_cw	Persistent	Visit timestamp	Tie back conversion events to earlier visits
__adal_id	Persistent	Device ID (generated)	Uniquely identify a device

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Google Chrome)

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Mozilla Firefox)

(c)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)

(e)    https://support.apple.com/kb/PH21411 (Safari)

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Our details

This website is owned and operated by Goodwin Barrett Ltd. We are registered in England and Wales under registration number 09294215 and our registered office is at Mikar Business Park, Northolt Drive, Bolton BL3 6NJ

Our principal place of business is as above

You can contact us:

(a)    by post, to the postal address given above

(b)    by using our website contact form

(c)    by telephone, on 01204 471280 or the number published on our website from time to time; or

(d)    by email, using enquiries@goodwinbarrett.co.uk

Withdrawing Your Consent

You can withdraw your consent (opt-out) for us to contact you at any time. Please note: if you have signed a contract to complete a claim, our contractual rights will still apply and we can contact you in relation to a cancellation fee or any outstanding monies owed to us.

Disclosures

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy.

In addition, we may disclose information about you:

• to the extent that we are required to do so by law;
• in connection with any legal proceedings or prospective legal proceedings; and
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Third Party Data Transfers

We do not specifically transfer your data to countries outside of the European Union. However, some of our third party service providers may provide services which mean your data is transferred outside of the European Union. In any case, we ensure that there are appropriate security measures in place such as technical security, including encryption and restricted access to your data. The only circumstance in which this may happen is if one of our third party data processors backs up their systems (to keep their data secure) outside of the European Union. In any event, we have strict contracts in place to make sure your data is kept safe and your data is always under our control. If you have any questions, please feel free to contact us for further information.

Policy Amendments

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes, although anything that will affect you will be communicated directly to you.

Your Rights

Under certain circumstances you have rights with regard to the use of your data, as described by the Data Protection Act 2018.

In exercising any of your rights, we will take action within one month. However, should the request be complex we can extend this by a further two months. We will inform you of this in this event. We will need to confirm your identity before completing any action on your behalf, and reserve the right to not complete action until we are satisfied that you are making the request. If we cannot complete your request, we will inform you within one month and explain why.

These rights are as follows:

Data Access

You can access your data at any time by submitting a Subject Access Request (“SAR”). We will confirm what data is being processed and provide you with a copy of your data in addition to confirming your data rights. We will provide this free of charge. However, if you make a repeat request, we will charge an administrative fee of £10.

You can make this request using reasonable means, including by telephone, post or email. If you make the request by email, we will provide your information in a commonly used electronic format unless you instruct us otherwise.

Data Rectification

If you wish to amend any inaccurate data that we hold, please notify us specifically by telephone, post or email, or during the course of the provision of our services. We will make the amendment as soon as possible. If any data held is incomplete, you can complete this at any time. We may require this to be completed to allow us to provide our services (e.g. if we do not have your full address).

Data Erasure

We can erase or “forget” your data when requested by you in the following circumstances:

• We no longer require your data (when we have finished providing any services requested by you);
• You withdraw your consent and there is no other reason for us to hold your data (please note: if you have signed a contract to complete a claim, our contractual rights will still apply and we can contact you in relation to a cancellation fee or any outstanding monies owed to us);
• You object to the processing, as described below;
• You believe your data has been unlawfully processed; or
• There is a legal obligation to erase your data.

You can make this request using reasonable means including by telephone, post or email. If you request for your data to be erased, we will confirm whether this can take place and the next steps that we will take. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Data Restriction

You can restrict us from processing your data in the following circumstances:

• You believe your data is inaccurate;
• You believe your data has been unlawfully processed but do not want us to delete your data;
• We no longer need your data but it is required by you for making or defending a legal claim; or
• You object to the processing, as described below, but we are verifying this.

If you make a restriction request, we will still store a copy of your data but cannot use this. We will inform you if the restriction needs to be lifted. You can make this request using reasonable means including by telephone, post or email. If you request for your data to be restricted, we will confirm whether this can take place and the next steps that we will take. If we cannot restrict your data, we will explain why and confirm any actions required to allow us to do so.

Object To Data Processing

You can object to the processing of your data at any time. This right will only apply if we are using your data in relation to a legitimate interest. If you object, we will no longer process your data unless we have a compelling and legitimate reason not to do so (e.g. a legal obligation). In this case, you will be informed why we cannot stop processing your data.

You can always object to receiving marketing from us and we will stop processing your data for marketing purposes at any time.

Data Portability

You can request your data in a commonly used electronic format, and for us to transfer this to another entity or person, where we are processing your data with your consent or in accordance with a contract. This will only apply to information which is processed by automated means (e.g. by a computer). Where feasible, we will send your data directly to another entity or person.

Lodge a Complaint With Our Regulator

We are Regulated by the Information Commissioner’s Office (ICO) in respect of our obligations to protect your data. You have the right to make a complaint about our use of your data to the ICO, who will investigate this on your behalf. The ICO will only investigate complaints made within three months of your last contact with us.

You can contact the ICO through their website: https://ico.org.uk or by telephone: 0303 123 1113.