Privacy Policy – Aberdein Considine & Co (AC)

Our Privacy Policy – your rights, your information and how we use it.

AC is committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect, what we do with that information, who we may share it with and why, and your choices and rights regarding the personal information you have given us.

We may need to change our Privacy Policy, so please check our website for updates occasionally. We will contact you to let you know if there are significant changes, such as where your data will be processed.

This version of our Privacy Policy was last updated January 2^nd 2024.

Who we are

Aberdein Considine & Company is a Partnership established under the Law of Scotland. Its Head Office is at 5 - 7 Bon Accord Crescent,Aberdeen, AB11 6DN and its place of business, inter alia , at 30 Cloth Market, Newcastle upon Tyne, NE1 1EE.

We are members of and authorised by the Law Society of Scotland. A list of the firm's Partners is available on request and displayed at the Head Office, situated at 5 – 7 Bon Accord Crescent, Aberdeen, AB11 6DN, and at 30 Cloth Market, Newcastle upon Tyne, NE1 1EE aforesaid.

We abide by the professional practice standards outlined in the Standards of Conduct of Practice Rules for Solicitors by the Law Society of Scotland. The standard of Conduct Practice Rules may be inspected by accessing the Law Society of Scotland website – www.lawscot.org.uk

We are authorised and regulated by the Solicitors Regulation Authority (SRA), the regulatory body for solicitors practising in England and Wales. Our Registration Number is 628245.

We are authorised and regulated by the Financial Conduct Authority (FCA), 12 Endeavour Square, London, E20 1JN. Our Financial Services Registers number is 142693. Our permitted business advises on and arranges pensions, savings and investment products, non-investment insurance contracts and mortgages. You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems- reporting/register or by contacting the FCA on 0800 111 6768.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact:

FAO Data Protection Officer

Aberdein Considine & Company

5-7 Bon Accord Crescent

Aberdeen

AB11 6DN

Email: DPO@acandco.com

Information we collect and use

Our Privacy Policy, which applies to this website (www.acandco.com) operated by AC, explains how and why we collect personal information about you. We are committed to responsible management of personal information by the UK General Data Protection Regulations and Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

To receive specific information and to use certain services on this site, you will be asked to provide personal information about yourself, such as your name, address, and email address. When you provide this information to us, you consent to our use of that information by the terms of this Privacy Policy. This information will be used to provide you with the services that you have requested and to provide you with news and information about our products and services. AC, its business partners, and its service companies may use your personal information and other information to provide legal services, credit checks, money laundering, marketing, administration, and training. AC may disclose information to our service providers and agents for these purposes. If you no longer want to receive such information, email us at DPO@acandco.com and we will stop sending it.

Information about you that we collect and use includes:

• Information about who you are - e.g., your name, date of birth and contact details
• Information connected to your product or services with us – e.g., your bank account details
• Information about your contact with us –e.g., meetings, phone calls, emails/letters
• Information is automatically collected, e.g., via cookies, when you visit one of our websites
• Information if you visit one of our offices – e.g., visual images collected via closed circuit televisions (CCTV)
• Information classified as ‘sensitive’ personal information – e.g., your health or marital or civil partnership status. This information will only be collected and used where needed to provide the product or services you requested or comply with our legal obligations.
• Information you may provide us about other people – e.g., joint applicants, proprietors, or beneficiaries for products you have with us.
• Information on children – e.g., where a child is named as a beneficiary in a Will or on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, and gender)

We are committed to processing your data legally, fairly, and transparently.

What are cookies?

Some websites use cookies, text-only strings of information that the website you are visiting transfers to the browser's cookie file on your computer. Cookies are used to identify users and enhance the user’s experience by customising web pages. A cookie will usually contain the name of the domain from which it has come, an expiry date for the cookie, and a value, which is usually a randomly generated unique number.

Use of Cookies on our site

The Website automatically gathers certain information such as IP addresses and the number and frequency of visitors to the Website and individual web pages. This is collected using cookies and is used by us for security and monitoring purposes, to manage the Website, track usage, improve the Website and ensure the Website is as appealing to as many visitors as possible. Cookies are pieces of information that are stored by the browser on your computer's hard drive. The Website also uses cookies to enable us to provide features such as remembering certain information about you and your preferences so that they and we can deliver targeted advertisements which will be of most interest to you. Cookies can be deleted from your hard drive, or configure your web browser to reject cookies. To learn more about cookies and how to reject them, visit www.aboutcookies.org.

Rejecting cookies will not prevent you from using most of the website's features. If you experience any problems after deleting cookies, you should contact the supplier of your web browser.

Where we collect your information

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

• an application form for a product or service
• phone conversation with us
• emails or letters you send to us
• meetings with one of our solicitors, estate agents, financial advisers or other member of staff
• registering for one of our events - e.g. retirement events, employment seminars
• participating in research surveys to help us understand you better and improve our products and services
• our online services such as websites, social media and mobile device application ('Apps')

If you have a financial adviser and are a member of your employer’s pension scheme, the information we collect, and use will most likely have been provided by them on your behalf.

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources, e.g., to check or improve the information we hold (like your address) or to give better contact information if we cannot contact you directly.

We take your privacy seriously and will only ever collect and use personal information where necessary, fair, and lawful. We will collect and use your information only where:

• you have given us your permission [consent] to send you information about products and services offered by us and selected third parties we have chosen to work with, which we believe may be of interest and benefit to you
• It’s necessary to provide the product or service you have requested. For example, if you wish to invest in one of our mortgage, pension, or savings products or market your property through us, we will require some personal information, including your name, address, date of birth, and bank account details
• We must meet our legal or regulatory obligations, e.g., to send you annual statements, tell you about changes to terms and conditions, or detect and prevent fraud and anti-money laundering
• It’s in the legitimate interests of AC – e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product, investment or services; where we need to process your information to understand you and your needs better so we can send you more relevant communications about the business and products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
• It’s in the legitimate interests of a third party – e.g., sharing information with your employer’s adviser to govern a pension scheme of which you are a member
• If you do not wish us to collect and use your personal information in these ways, we may be unable to provide you with our products and services.
• We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the types of business, products, services or features we offer you now or in the future. We use automated decisions in the following ways:
• tailoring products and services – e.g., placing you in groups with similar clients to make decisions about the types of business, products, and services we may offer you to help meet your needs
• when designing and enhancing our online services to help meet your requirements for ongoing guidance and support
• We also use technologies, such as the Facebook Pixel, to customise content and advertising, provide social media features, and analyse site traffic. We also share information about your site use with our trusted social media, advertising, and analytics partners.

Who we may share your information with

We may share your information with third parties for the reasons outlined in 'What we collect and use your information for'

These third parties include:

• departments within AC
• your adviser or employer
• companies we have chosen to support us in delivering the products and services we offer to you and other clients – e.g., research, consultancy, or technology companies; or companies who can help us in contact with you, for example, an internet service provider
• our regulators and any Supervisory Authority – eg the Law Society of Scotland, the Solicitors Regulatory Authority (SRA), the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) or the National Crime Agency (NCA) – e.g., for the processing of tax relief on pension payments or the prevention of tax avoidance
• We will never sell your details to someone else. Whenever we share your personal information, we do so in accordance with our obligations to keep it safe and secure.

Where information is processed

The majority of your information is processed in the UK and European Economic Area (EEA)

How we protect your information

We take information and system security very seriously and always strive to comply with our obligations. Any personal information collected, recorded, or used in any way, whether on paper, online, or in any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence, or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training

Our security controls are aligned with industry standards and good practice, providing a control environment that effectively manages risks to your information's confidentiality, integrity, and availability.

How long we keep your information

We will keep your personal information only where it is necessary to provide you with our products or services while you are a client.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your rights

You have several rights in relation to how AC uses your information. They are:

Right to be informed

You have a right to receive clear and easy-to-understand information about our personal information, why we have it, and who we share it with—we do this in this Privacy Policy and any privacy notices.

Right of access

You have the right to access your personal information. If you wish to receive a copy of the personal information, we hold on you, you may make a Data Subject Access Request (DSAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to erasure

You can ask for your information to be deleted or removed if AC has no compelling reason to keep it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for specific reasons. This means we are still permitted to keep your information – but only to ensure we don’t use it for future reasons you have restricted it.

Right to data portability

You can ask for a copy of your personal information across different services. In certain circumstances, you may move, copy, or transfer the personal information we hold to another company safely and securely, such as transferring your business to another Firm or your pension to another pension provider.

Right to object

You can object to AC processing your personal information where it’s based on our legitimate interests (including profiling), for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

Rights related to automatic decision making including profiling

You have the right to ask AC to:

• give you information about the processing of your personal information.
• request human intervention or challenge a decision where processing is done solely by automated processes
• carry out regular checks to make sure that our automated decision-making and profiling processes are working as they should.

How to make a complaint

We will always strive to collect, use, and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please raise your concerns in writing with our Client Relations Partner Anthony Quin, 23 Port Street, Stirling, FK8 2EJ.

Your complaint will be acknowledged within five working days; after a full investigation, you will usually receive a detailed response within ten working days.