We are committed to protecting and respecting your privacy.

As part of this commitment, we want you to know our principles and practices for collecting, using, storing, and disclosing your personal information.

Please read this notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information generally, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Succession Wealth Management Limited (“Succession”) is part of the Aviva group of companies and is authorised and regulated by the Financial Conduct Authority. Aviva Administration Limited (“Aviva”) acts as an introducer to Succession for financial advice. The financial advice services are provided by Succession, not Aviva.

You may have spoken with the Aviva Customer Wealth Engagement Team before making an appointment with Succession. The Customer Wealth Engagement Team is operated by Aviva.

Succession is the main company responsible for your personal information. Aviva will also be responsible for the personal information it collects about you. Each company is a ‘controller’ of your personal information.

Succession Wealth Management Limited is registered in England (company number 07882611. Registered office address: The Apex, Brest Road Derriford Business Park, Derriford, Plymouth, United Kingdom, PL6 5FL. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number: 588378.

Aviva Administration Limited is registered in England (company number 03424940. Registered office address: Aviva, Wellington Row, York, YO90 1WR. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number: 185746.

Aviva Administration Limited and Succession Wealth Management Limited are subsidiaries of Aviva Life Holdings UK Limited.

Scope

This notice relates to all data subjects whose personal information is processed by Succession and Aviva in relation to our whole of market financial advice.

Our collection and use of your personal information

When we mention “we”, “our” or “us”, we mean the relevant company in the Succession group that processes your personal information.

We collect personal information about you when you enquire about or use one of our services. This information may be provided by you directly.

We receive personal information about you from Aviva, for example when the Aviva Customer Wealth Engagement Team makes an appointment for you with Succession.

We may also obtain personal information about you from third parties, including:

• Third parties involved in the relevant product or plan, including product providers, financial advisers, trustees, banks and other financial institutions, e.g. mortgage brokers;

• Healthcare providers and medical practitioners;

• Your attorney acting under a power of attorney or nominated representative;

• Legal advisers, accountants, auditors and professional services firms who act on our or your behalf or on behalf of your employer (past and current);

• Service providers in relation to the relevant product or plan, including experts, property surveys, valuations and, in limited circumstances, private investigators;

• Aviva group companies who may provide information in relation to other products you or people you live with hold, previous claims, policies or quotes;

• Credit reference agencies;

• Financial crime detection agencies, databases and sanctions lists;

• Government agencies and regulatory bodies, including the police, the courts, the Office for National Statistics, Companies House and HM Revenue & Customs (HMRC);

• Regulators who regulate how we operate, including the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and Financial Ombudsman Service (FOS);

• Third parties who provide us with details of individuals who have expressed an interest in hearing about products;

• Third parties that help us maintain the accuracy of our data, e.g. by identifying individuals who are deceased, updating contact details for individuals who have moved;

• Other third party suppliers, including actuaries, auditors, legal advisers and other professional services firms and sanctions-checking service providers;

• Providers of marketing and advertising services;

• Data suppliers;

• Publicly available sources, including the Office for National Statistics (e.g. census data) and other data made available under the Open Government Licence, internet searches, news articles, online marketplaces and social media sites, apps and networks (e.g. Twitter, Facebook and Instagram);

• Third parties in connection with any acquisition of a business by us.

We are committed to ensuring that the personal information we collect and use is appropriate and does not constitute an invasion of your privacy.

We may process both manually and by electronic means your personal information, including details of your name, address, date of birth, nationality, your marital status and details of your spouse or partner and dependents, your health and lifestyle, your employment status, your income and expenditure, property, investments, pensions and liabilities, your bank details, your tax status and other associated tax details, any previous bankruptcy or insolvency, any life assurance you hold or inheritance tax plans, details of your will, powers of attorney or other legal documents, any identity verification documentation or any other information necessary to provide the service you have requested.

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

• for the purposes of providing advice, administration, transacting and management or any other purpose necessary for the service you have requested; and

• to meet any necessary legal and regulatory obligations.

We may, with your explicit consent, contact you or pass your details to other companies associated with us to contact you (including by telephone) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.

We will only process special category personal information with your explicit consent. Special category personal information means information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data and data concerning health, sex life or sexual orientation.

If you provide personal information about another person, you should show them this notice.

Our use of children’s personal information

Generally, we would only process a child’s name and date of birth, unless further details were required to fulfil a service that you have specifically requested, such as to establish investments for or on behalf of the child, school planning purposes or to establish health or life insurance. We consider that children are people under 18 years of age. Whenever we collate information for children, we would always explain why the information is needed. Where a child is party to the contract, we would always consider the child’s capacity to understand the contract they are entering into.

We will never use the child’s personal information for marketing purposes.

Our legal basis for processing your personal information

We are required by law to have a specific reason for collecting and using personal information. We will only process personal information where we have a valid reason to do so under data protection legislation as follows:

• Contract - we will process personal information for the purpose of fulfilling contractual obligations or to meet a pre-contractual request.

• Consent – we will request explicit consent for the following purposes;
  
  - processing and sharing special category personal information in connection with product applications
  - provision of marketing information to make you aware of our products and services which may be of interest

• Legal obligation - in some circumstances we are permitted by law to process your personal information.

• Legitimate interests - we may use your personal information for our, or a third party’s legitimate business interest. When we process personal information to meet our legitimate business interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Who we share your personal information with

We use more than one company in our group to deliver our services. We may share your personal information with other Succession group companies and Aviva group companies as part of our commitment to offer you services.

We may share your personal information with product providers, our compliance consultants, the FCA or any other regulatory, statutory, governmental, industry bodies including, where relevant, solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.

We use third party companies to provide services so we can deliver a service to you. For example, IT systems and software and associated support services to ensure they continue to operate effectively and compliance consultants.

We may disclose your personal information to anyone in the future who may buy or merge with our business. If we merge with another company or if we are sold, then we will need to share your information with the other party.

In the event of a sale of any part of our business we may have to pass your personal information to another party in a transaction where it is not possible to separate it from the information, we need to pass to them. We will only do this where there is not a viable alternative.

Where we store your personal information

We take the security of your data very seriously and follow best practice on data security.

If personal information is processed outside of the UK, we will ensure that we put in place appropriate safeguards to protect personal information, such as, appropriate contractual arrangements and assurances including (but not limited to) recognised certification schemes.

Steps are taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures are also taken to safeguard against unauthorised or unlawful processing, accidental loss, destruction, or damage to the data.

Product providers, lenders and investment managers may administer your policy, any existing policies you may have with them and provide other services, from centres in countries outside of the UK that do not always have the same standard of data protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the General Data Protection Regulation.

How long will you keep my personal information?

We will keep your personal information securely for as long as is necessary for the purpose it was collected.

Generally, we will retain most personal information for the duration of the relationship and time limits are applied thereafter, based on the type of data. Some records need to be retained indefinitely to meet FCA regulation.

Our Data Retention Policy is available upon request. Actual retention periods may vary depending on each individual’s circumstances, but we would always inform you as part of our privacy information obligations.

How Aviva uses your personal information

Aviva uses your personal information for several purposes, including providing products and services and for fraud prevention. Aviva uses profiling and other data analysis to understand customers better, for e.g. what kind of content or products would be of most interest and to predict the likelihood of certain events arising, such as to assess risk or the likelihood of fraud. Your personal information may be shared with other Aviva group companies and third parties (including service providers and regulatory and law enforcement bodies). Aviva may transfer your personal information to countries outside of the UK but will always ensure appropriate safeguards are in place when doing so. Aviva may use personal information held about you across the Aviva group for marketing purposes, including sending marketing communications in accordance with your preferences.

This notice explains the most important aspects of how Aviva uses your personal information, but you can get more information by viewing Aviva’s full privacy policy at aviva.co.uk/privacypolicy or requesting a copy by writing to Aviva at: The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth PH2 1JR.

Your rights

Succession and Aviva are each ‘controllers’ of your personal information. Under the General Data Protection Regulation, you have a number of important rights. In summary, those include rights to:

• access to your personal information and to certain other supplementary information that this notice is already designed to address

• require us to correct any mistakes in your information which we hold

• require the erasure of personal information concerning you in certain situations

• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• object at any time to processing of personal information concerning you for direct marketing

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

• object in certain other situations to our continued processing of your personal information

• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.

Contact Us

Succession and Aviva would be happy to answer any questions, comments, requests or concerns you may have about the way we use your personal information.

If you wish to contact Succession’s Data Protection Officer, please send an email to dataprotection@successionwealth.co.uk or write to Succession Wealth, 60 Church Street (7th Floor), Birmingham B3 2DJ or call 0121 212 9212.

If you wish to contact Aviva’s Data Protection Officer, please send an email to dataprt@aviva.com or write to The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth, PH2 1JR.

You also have the right to lodge a complaint to the Information Commissioner’s Office at www.ico.org.uk or by calling 0303 123 1113.