Alliance Trust Savings Limited (hereinafter referred to as “Alliance Trust Savings”, “we” or “us”) and our group companies are committed to maintaining the personal information of every current, former and prospective customer in accordance with the requirements of applicable data protection and data privacy legislation applicable in the UK (Data Protection Laws).
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
- our group companies and from other organisations such as fraud prevention agencies.
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.
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.
We may disclose and share personal information with:
- other companies within our 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.
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.
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.
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
T: 0303 123 1113
Please let us know if the personal information that we hold about the Data Subject needs to be updated or is incorrect.
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.
Alliance Trust Savings Limited
PO Box 164
8 West Marketgait Dundee
T: 08000 326 323
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