OUR PRIVACY POLICY

Alliance Trust Savings is a member of the Alliance Trust group of companies (Alliance Trust Group) which also includes Alliance Trust PLC, and Alliance Trust Equity Partners Limited. Further details of the Alliance Trust Group are set out in the report and accounts for Alliance Trust PLC which are available at www.alliancetrust.co.uk.

Alliance Trust Savings Limited (hereinafter referred to as “Alliance Trust Savings”, “we” or “us”) and the other members of the Alliance Trust Group are committed to maintaining the personal information of every current, former and prospective customer in accordance with the requirements of data protection and data privacy legislation applicable in the UK (Data Protection Laws).

This Data Protection and Privacy Policy describes the type of personal information we may collect, the purposes for which we use the information, the circumstances in which we may share the information and the steps we take to safeguard the information to protect the privacy of you and/or the Authorised Users as applicable (the “Data Subject”). Details of how we process Client personal information is set out in the Client Terms and Conditions.

The personal information that we collect and how we collect it

The personal information of Data Subjects will be held and processed by Alliance Trust Savings as a data controller for the purposes of Data Protection Laws.

We will only retain personal information for as long as is necessary to carry out the purposes stated below (see ‘How we use personal information’) or as is required by applicable legislation or other regulation.

We will treat personal information as private and confidential and we will not disclose the information except in the circumstances set out under the ‘How we share personal information’ section below.

We will collect personal information about the Data Subject including, name; residential correspondence and email address; phone number, National Personal Identifier, tax reference number; passport number, date, town and country of birth; and, payment and bank account details; any authorised person nominated or appointed by the Data Subject, employer details; and the internet protocol (IP) address used to connect the computer to the internet and geographic location.

We may also collect details of how the Data Subject uses our Website and the attachments they may open with newsletters that are sent to the Data Subject electronically.

We will collect personal information about the Data Subject during the course of our relationship with you. We may collect this information in various ways including, from:

  • applications or forms that the Data Subject may complete or agreements that the Data Subject may enter into with us;
  • emails, letters and during telephone calls; and

other Alliance Trust Group companies and from other organisations such as fraud prevention agencies.

We may also use cookies and similar technologies on our Websites and in our emails. These technologies do many different things, such as letting the Data Subject navigate between web pages efficiently and remembering the Data Subject’s preferences. In emails they help us to understand whether the Data Subject has opened the email and how they have interacted with it. Our cookies policy located on the right gives the Data Subject more information on these technologies, how and where we use them and how they can control them.

The Data Subject is not obliged to supply any of the personal information that we may request. However, failure to do so may result in us not being able to act on their instructions or provide our services to the Data Subject or may result in us having to report the Data Subject to a competent authority such as HM Revenue and Customs.

How we use personal information

We will use personal information for the following purposes:

  • checking the identity of the Data Subject (please refer to ‘How we check the identity of the Data Subject’);
  • responding to requests and processing applications;
  • providing our services in accordance with the terms and conditions for the relevant product;
  • complying with regulatory requirements and our other legal obligations including the prevention of fraud and money laundering;
  • complying with a request for disclosure by a competent authority;
  • developing and improving our services, and to tell Data Subjects about changes to our services;
  • providing by letter, telephone, email or Website with:
    • any information that we consider that we need to send in order to comply with regulatory and other legal requirements including details of regulatory changes affecting our services;
    • market news and investment information; and
    • carrying out market research and analysis and obtaining feedback from the Data Subject on our services.

We may use information from third parties and/or aggregate personal information with data from third-party sources for these purposes.

We rely on the following legal bases to process and use personal information:

  • processing is necessary for the performance of our obligations under the Terms;
  • processing is necessary for the purposes of our legitimate business interests including:
    • where processing enables us to enhance, modify, personalise or otherwise improve our services for the benefit of our customers;
    • to develop new products and services;
    • to enhance the security of our network and information systems
    • to better understand how people interact with our Websites
    • to determine the effectiveness of promotional campaigns and advertising; and
    • to promote further sales of our products and services;
  • processing is necessary for compliance with a legal obligation; and
  • processing is carried out where the Data Subject has provided consent.

The Data Subject should contact us using the details in the Contact section below if they wish to receive marketing of products and services by us or other companies in the Alliance Trust Group. The Data Subject may also update their marketing preferences (including where the Data Subject no longer wishes to receive marketing materials from us) using our Preference Centre available when the Data Subject log in to their account.

How we share information

We may disclose and share personal information with:

  • other companies within the Alliance Trust Group;
  • third parties including, credit referencing, fraud prevention, regulatory and law enforcement agencies to investigate or prevent crime;
  • our agents and sub-contractors who administer or process the information on our behalf;
  • market research companies who may assist us in improving our products and services;
  • any providers of IT solutions including platform support, cloud based storage and applications for sales, services and marketing;
  • our bankers and other companies to facilitate payments, including direct debit payments;
  • our professional advisers; and
  • our insurers and any intermediary brokers.

We may also need to disclose some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. The recipient of the information will be bound by confidentiality obligations.

Personal information may be transferred to or accessed from other countries (including those outside the European Economic Area) and processed for us in those countries on the basis that anyone we pass it to will provide a level of protection equivalent to the Data Protection Laws. Such information may be accessed by local law enforcement agencies and other authorities to prevent and detect crime and comply with legal obligations. Further details as to where we may be transferred and the basis for such transfers can be found at www.alliancetrustsavings. co.uk/non-eea-processing.html. We use automated decisions based on personal information we have or collect about Data Subjects in order to verify their identity or to comply with antimoney laundering legislation. The use of such systems is only undertaken for Website Applications and will not result in an automatic refusal of a Website Application.

How we check the identity of the Data Subject

We are required to verify the identity and address of the Data Subject in order to comply with applicable anti money laundering legislation. We may require to obtain independent documentary evidence confirming details on identity and permanent residential address. This will involve an electronic check of the information we hold.

To help us meet our antimoney laundering obligations, we may disclose personal information to licensed credit reference agencies and/or fraud prevention agencies who may record the fact that a search has been made and share the fact of the search and the results (including the information that we may provide about the Data Subject) with other organisations.

When the Data Subject provides us with personal details of a third party, the Data Subject must ensure that the third party is aware that we may verify their name, address and date of birth.

Recording and monitoring phone calls

We will record and monitor phone calls in case we need to check that we have carried out the Data Subject’s instructions correctly, to resolve queries or complaints, for regulatory purposes, to help improve our services and to help detect and prevent fraud.

Monitoring may also be undertaken for staff training purposes.

Data Subject rights

This section explains the rights Data Subjects have under Data Protection Laws with respect to how their personal information is held and used by us. If the Data Subject wishes to request to exercise any of these rights, they can contact us using the details set out in the Contact section below. We will grant a Data Subject request only to the extent that it follows from our assessment of the request that we are allowed and required to do so under Data Protection Laws.

Where we rely on the Data Subject’s consent as the legal basis for processing personal information, the Data Subject has the right to withdraw their consent at any time. This will not affect the lawfulness of any processing of their personal information that we carried out before the withdrawal.

The Data Subject has the right to access the information we hold about them, free of charge. The Data Subject has the right to ask us (and third parties to whom we transfer their personal information) to rectify the Data Subject’s personal information if it becomes inaccurate. In order for us to do so, the Data Subject must inform us of any changes to their personal information so that we can keep it up-to-date.

The Data Subject has the right to ask us to erase their personal information if:

  • you withdraw your consent to our processing of your personal information; or
  • your personal information has been processed unlawfully by us; or
  • your personal information is no longer necessary for the purposes for which it was collected by us; or
  • you object to us processing your personal information on grounds relating to your personal situation.

We do not have to comply with a request to erase personal information if we need to use that personal information for our overriding legitimate business interests or as may otherwise be required by law. We may not be able to provide our products or services to you if the Data Subject asks us to erase their personal information.

The Data Subject has the right to restrict our processing of their personal information if:

  • they contest the accuracy of the personal information held by us (for a period enabling us to verify the accuracy of the information);
  • our processing activities are unlawful;
  • we no longer need the personal information but the Data Subject would like us to retain it to ensure its continued availability in connection with any legal claims; or
  • the Data Subject objects to us processing their personal information on grounds relating to their personal situation and it is still to be confirmed whether our legitimate grounds override their right to object.

If the Data Subject believes our processing of their personal information does not comply with Data Protection Law, the Data Subject can make a complaint to the Information Commissioner’s Office (ICO) using the following details:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
T: 0303 123 1113
W: https://ico.org.uk/

Keeping information up-to-date

Please let us know if the personal information that we hold about the Data Subject needs to be updated or is incorrect.

Keeping personal information secure

We will take reasonable technical and organisational security measures to safeguard all personal information. Personal information is stored securely on our computer system and/or in a secure filing system, and we restrict access to those who have a need to know. We provide training and education to our staff on Information security.

However, the Data Subject acknowledges that the use of the internet is not entirely secure and for this reason we cannot guarantee the security of any personal information which is transferred through the internet or email.

Internet communications are not secure unless the data being sent is encrypted. We cannot accept any responsibility for unauthorised access by a third party or the corruption of data sent to us. For security purposes we may monitor emails received or issued by us.

Contact

If you have any questions, would like to talk to someone about this Data Protection and Privacy Policy, access your personal information or make a complaint about how we’ve handled your information, please contact us at:

Alliance Trust Savings Limited
PO Box 164
8 West Marketgait Dundee
DD1 9YP
T: 08000 326 323
E: advisersupport@alliancetrust.co.uk

How we use cookies

By using the Alliance Trust Savings website and checking the box, you're confirming that you're happy to accept our use of cookies. Here you can find out more about how we use them.

What are cookies?

Cookies are small, harmless files placed on your computer's hard drive or in your browser memory when you visit a website.

What do cookies do?

Cookies help to make the interaction between users and websites faster and easier. For example, when you apply for a Alliance Trust Savings account online, cookies help our site remember the information you give us as you move through your application. Some of the cookies we use help us understand how our customers use our website, for example the pages they visit and the links they click on, while others enable us to learn which advertisements bring customers to our website. What our cookies don't do is store any personal or confidential information about you.

Are cookies safe?

Yes, cookies are harmless text files. They can't look into your computer or read any personal information or other material on your hard drive. Cookies can't carry viruses or install anything harmful on your computer. Why should I keep cookies switched on?

We advise you to keep cookies active during your visits to our website because parts of the site rely on them to work properly. For example, you may not be able to access your account or apply for new products if your cookies are disabled.

Types of cookies we use

The Alliance Trust Savings website uses only a small amount of cookies. These are listed below

Session cookies

We use session cookies, which last only for the duration of your visit and are deleted when you close your browser. No personally-identifiable data is collected. These simply enable us to identify that the same person is moving from page to page.

Third party cookies

As well as using cookies from our advertising partners, from time to time we may also embed external content from other third party websites within our website. These include sites such as Google Analytics, whose cookie usage policy you can view on their own websites.

Cookies currently used on our website

Cookie Category Cookie Owner Cookie Purpose
Improving online experience and website visit information Google Analytics Google Analytics uses cookies to help us to track which pages are accessed. This allows us to understand how popular our site is and record visitor trends over time. The cookies contain no personally identifiable information but some of them do use your IP address to help determine where in the world you are accessing the site from and to track pages you visit within the site.
Flash Banner tracking Advertising agency We use these cookies to manage our marketing activity. The information tells us which advertisements, websites and paid for keywords are the most effective but they don’t contain any personally identifiable information about you.
Adviser Disclaimer Alliance Trust Savings Alliance Trust Savings uses this cookie to identify that visitors to the Adviser section of the site are professional Independent Financial advisors. Accepting this cookie grants visitor access to Adviser site. If not accepted the visitor is taken to the Alliance Trust Savings public site. This cookie expires after 30 days.

How to turn cookies on or off

You have a number of options when it comes to receiving cookies.

You can set your browser either to reject all cookies, to allow only ‘trusted’ sites to send them, or to accept only those cookies from websites you are currently using.

We recommend that you don’t block all cookies because parts of our website rely on them to work properly.

To find out how to turn cookies on and off in your browser, please see the instructions from your browser vendor below:

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