About Us

Our privacy notice

Introduction

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from you or about you. It applies to all our products and services, and any instances where we collect your personal data.

About us

Portunus Investment Solutions Ltd is a company registered in England and Wales (registration number 07048055 – Incorporated on 19 October 2009), whose business address is at, Office 4 8 Percy Street, London W1T 1DJ. Portunus Investment Solutions Ltd is authorised and regulated by the Financial Conduct Authority with firm reference number: 629943

For the purposes of the General Data Protection Regulation (‘GDPR’), Portunus Investment Solutions Ltd (Portunus) is the data controller under the Regulation, which means that we determine the purposes and means of processing personal data. We are registered with the Information Commissioner’s Office with registration number: A8280103

If you have any questions in relation to this privacy policy or how we collect, use or store your personal information, you can contact us by phone at: 0203 411 9575, by post at Portunus Investment Solutions Ltd, 8 Percy Street, London W1T 1DJ or by email at: jeffcornish@portunusinvestments.co.uk

Future changes to this privacy notice

We may change this privacy notice occasionally in order to reflect changes in the law, as well as our privacy practices. While we encourage you to check this notice on our website regularly, we will notify you should any substantial change take place.

Responsible Person (RP)

Due to the size or our organisation we have a Responsible Person who is Jeff Cornish. You can get in touch with Jeff using the contact details provided above.

What personal information about you do we process?

Independent Financial Advisers

Personal information that we will process in connection with our products and services includes:

IFA company details (eg address, telephone number, email address)
Personal contact details (e.g. title, full name, email address, mobile, telephone number)
Records of your contact with us (including telephone number, e-mail address and IP address)
Products and services that you have transacted through us, as well as products and services you have been interested in
Information about your employment status

Clients of Independent Financial advisers ie applications made into providers products marketed by us

Although we don’t process this information, it is often passed to Portunus before being forwarded on to the product provider, their receiving agent or administrator, so we do hold this information often in the form of application forms mainly in our files and on our email system. Personal information that we will hold in connection with our products and services includes:

Personal contact details (e.g. title, full name, current address and address history)
Your date of birth, gender and age
Your nationality
Details of beneficiaries and anyone legally authorised to act on your behalf
Records of your contact with us (including telephone number, e-mail address and IP address)
Information about your employment status
Information about your source of income and source of wealth (to comply with anti-money laundering requirements)
Payment related information, such as sort code and bank account number and credit or debit card information (to comply with anti-money laundering requirements)

Where does your personal information come from?

We will collect personal information from the following sources:

IFAs and advisers

From you directly, the FCA website, the product providers we work with, their receiving agents and administrators
Information generated about you when you use products and services marketed by us.
From a Financial Services Network or umbrella organisation (for example, Openwork, or St James’s Place) who we work with to market products or services to you
Business partners (for example, financial services institutions, insurers), or others who are a part of providing your products and services or operating our business
From publicly available information such as the internet

Clients of IFAs and advisers

As an FCA authorised firm, our permissions only authorise us to market products only to professional clients (these are primarily IFAs, advisers and DFMs) and not to retail clients.

From you directly, and any information from family members, associates or beneficiaries of products and services
Information generated about you when you use the products and services we market for our product providers
From a broker or other intermediary who we work with to provide products or services to you
Business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are a part of providing your products and services or operating our business
From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, publicly available directories and information (for example, tele-phone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies

What do we use your personal data for?

We use your personal data for the following purposes:

Checking and forwarding to a product provider, receiving agent or administrator an application for a product or service, including the price, the risk of doing so, availability of payment method and the terms
Managing products and services relating to that the product or service, or application for one.
Managing any aspect of the product or service
To perform and/or test the performance of, our products, services and internal processes
To improve the operation of our business and that of our business partners
To follow guidance and best practice under the change to rules of governmental and regulatory bodies
For management and auditing of our business operations including accounting
To monitor and to keep records of our communications with you and our staff (see below)
To administer our good governance requirements such as internal reporting and compliance obligations or administration required
For market research and analysis and developing statistics
For direct marketing communications to IFAs and advisers and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by email, phone, and post. Offers may relate to any of our products and services.
To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
To develop new products and services and to review and improve current products and services
To comply with legal and regulatory obligations, requirements and guidance
To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
To share information, as needed, with business partners (for example, financial services institutions, including debt recovery agencies), account beneficiaries, service providers or as part of providing and administering our products and services or operating our business
To facilitate the sale of one or more parts of our business

What are the legal grounds for our processing of your personal information, and when can we share it with others?

We rely on the following legal bases to use your personal data:

Where it is needed to provide you with our products or services, including:

Managing products and services that you have with one of our business partners, or an application for one
Updating your records, tracing your whereabouts to contact you about your account or application and doing this for recovering debt (where appropriate)
Sharing your personal information with business partners and services providers when you apply for a product to help manage your product
All stages and activities relevant to managing the product or service with our business partners including enquiry, application, administration and management of accounts, illustrations, requests for transfers of equity, setting up/changing/removing guarantors

Where it is in our legitimate interests to do so, such as:

Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
To follow guidance and recommended best practice of government and regulatory bodies
For management and audit of our business operations including accounting
To carry out monitoring and to keep records of our communications with you and our staff (see below)
To administer our good governance requirements, such as internal reporting, compliance obligations or to meet other administrative requirements
For market research and analysis and developing statistics
For direct marketing communications to IFAs and advisers, and related profiling to help us to offer relevant products and services. We will send marketing to you by email, phone, and post.
Subject to the appropriate controls, to provide insight and analysis of our IFAS and advisers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses
For some of our profiling and other automated decision making
Where we need to share your personal information with people or organisations to run our business or comply with any legal and/or regulatory obligations

To comply with our legal obligations:

We are authorised by the Financial Conduct Authority (FCA), and as such may be required to process data to comply with the FCA’s rules. This may mean that we are unable to erase your data in certain circumstances, if to do so would result in a breach of the FCA’s record keeping requirements.

With your consent or explicit consent:

For some direct marketing communications
For some of our profiling and other automated decision making
For some of our processing of special categories of personal data such as about your health, if you are a vulnerable customer or some criminal records information

When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

Business partners (for example, other financial services institutions and debt recovery specialists)
Governmental and regulatory bodies such as The Financial Conduct Authority, HM Revenue & Customs, the Prudential Regulation Authority, the Financial Ombudsman Service, the Information Commissioner’s Office and the Financial Services Compensation Scheme
Other organisations and business who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and other suppliers
Credit Reference and Fraud Prevention Agencies

How and when can you withdraw your consent?

Where we rely upon your consent to process your personal data, you can withdraw this at any time by contacting our Data Protection Officer (details above).

Is your personal information transferred outside the UK or the European Economic Area?

Portunus Investment Solutions Ltd is based in the UK, but sometimes your personal information may be transferred outside the European Economic Area. If we do so, we will make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

What should you do if your personal information changes?

You should tell us as soon as possible so that we can update our records. You can do so via the ‘contact us’ section of our website.

Do you have to provide your personal information to us?

You do not have to provide your personal information to us should you not wish to. However, we are unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we will make this clear.

Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

How long do we retain your personal information?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
Retention periods in line with legal and regulatory requirements or guidance, in particular in conjunction with FCA rules.

What are your rights under data protection legislation?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

The right to be informed about the processing of your personal information
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
The right to object to processing of your personal information
The right to restrict processing of your personal information
The right to have your personal information erased (the “right to be forgotten”)
The right to request access to your personal information and to obtain information about how we process it
The right to move, copy or transfer your personal information (“data portability”)
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.

Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.

What are your marketing preferences and what do they mean?

We may use your home address, phone numbers, email address to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.

How can you contact us?

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact our DPO, you can contact us via the methods listed above in the ‘Responsible Person’ section.

Complaints

All individuals have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if they have concerns about how Portunus IS has handled their information. Any concerns can be reported via the ICO’s website https://ico.org.uk/concerns/ or over the telephone, by calling 0303 123 1113.