All personal information processed in connection with this Privacy Notice (the “Privacy Notice”) is controlled by Delio Ltd, a company registered in England and Wales under company number 09092423 (from now on "we", "our" or "us"). Our registered office is at Cardiff Business Technology Centre, Senghennydd Road, Cardiff, Wales CF24 4AY. We are a "data controller" for the purposes of the Data Protection Act 1998 ("DPA") and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 ("GDPR"). This means that we are responsible for, and control the processing of, your personal information.
By “personal information” we mean all information that identifies or may identify you.
We are committed to protecting and respecting your privacy. We collect, store and use personal information in accordance with all laws in any relevant jurisdiction that relate to data protection, privacy, the use of information relating to individuals, and/or the information rights of individuals including, without limitation, (prior to 25 May 2018) the DPA and any other laws in force from time to time which implement the Data Protection Directive 1995/46/EC and (from 25 May 2018) the GDPR, and the equivalent in any other relevant jurisdictions all as amended or replaced from time to time.
This Privacy Notice applies to all personal information we gather or use in connection with your relationship with us as a customer or potential customer. This includes when you use our websites, http://deliowealth.com/ and https://connect.deliowealth.com/ (from now on referred to as our "Websites"), our mobile apps (including our iPhone and Android apps) (from now on referred to as our "Mobile Apps"), services provided by us or others acting on our behalf, and when you interact with us. We will only use your personal information in accordance with this Privacy Notice.
Please review this Privacy Notice carefully as it contains important information on:
- the personal information we collect about you;
- what we do with your information; and
- who your information might be shared with.
By using our services, our Websites or our Mobile Apps and by providing any personal information to us, you acknowledge our use of your personal information as set out in this Privacy Notice. Please do not provide us with any personal information if you do not want that information to be used by us in this manner.
3. Your Privacy Rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights, please contact our Data Protection Officer at DPO@deliowealth.com or by post to Data Protection Officer, Delio Ltd, Cardiff Business Technology Centre, Senghennydd Road, Cardiff, Wales CF24 4AY.
Access to your personal information: The DPA gives you the right to request access to information held about you. Please make all requests for access in writing and provide us with evidence of your identity.
The following rights will apply from 25 May 2018:
Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision-making. Please make all requests for access in writing and provide us with evidence of your identity.
Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
You can make a complaint to us by contacting the Data Protection Officer or to the data protection supervisory authority, the Information Commissioner's Office, https://ico.org.uk/.
4. How we Collect and Receive Personal Information
We may collect and/or receive personal information from you when you:
- fill in forms on our Websites or Mobile Apps, including when you register, create or modify an online or in app account with us;
- communicate with us, such as by mail, telephone, in writing or through our websites or social media;
- access our Websites or Mobile Apps, including where you perform actions; or
- respond to surveys or questionnaires we ask you to complete.
We may also collect your personal information from publicly available information such as information on third party websites or from our business partners. Such examples may include the details of any criminal convictions or court orders that we identify via our anti-money laundering checks.
5. Types of Personal Information
The types of personal information we receive, store and use may include:
- your title, name, gender, address, telephone numbers, email address and date of birth;
- details of the organisation you work for;
- your account information (including your username and password);
- information about your clients, including their names and e-mail addresses for the purposes of providing them with system access;
- your bank account details or credit or debit card number;
- information about your investment preferences;
- information about interactions you may have with us and our staff, including interactions via email, telephone or through our Websites or Mobile Apps; and
- information regarding your personal or professional interests, demographics, experiences with our products, and contact preferences in order to provide you with further services or information about our products and services.
Additionally, we automatically collect the following information when you visit our Websites:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We use this automatically collected information to maintain and improve our services and our site.
6. Use of Personal Information and Legal Bases
We use the personal information to help us understand your needs, to help us provide you with our products and services and to meet our legal and regulatory obligations. In particular, we collect, store and process your personal information for the following reasons and legal bases set out below:
Sometimes where we ask for personal information necessary to enter into a contract with you (for example, your bank account details) or to meet a legal obligation, we will not be able to provide our products or services without that personal information.
7. Sharing Personal Information
When providing you with our products and services, we will disclose personal information we collect or receive:
- to you or those acting on your behalf; and
- to third parties to provide a service to, or perform a function for, us or you or who are otherwise appointed by us in connection with the services we offer you including those who are acting as our agent or sub-contractor, including, without limitation, data processing service providers and our legal and professional advisors.
We may also disclose personal information more occasionally, for example:
- to third parties in connection with a proposed or actual financing, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or part of our business or to anyone whom we may transfer our rights and/or obligations for the purposes of evaluating and performing the proposed transaction; and
- to third parties, including law enforcement officials, law courts and government and regulatory authorities: (a) if we believe disclosure is required by any applicable law, regulation or legal process (such as to respond to subpoenas or judicial orders); or (b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.
8. Statistical Information
We may aggregate information about you with information about other users of our Websites or Mobile Apps to create statistical data about users.
9. Marketing Communications
We would like to send you information by post, email, telephone or text message (SMS) about our products and services and special offers which may be of interest to you, such as subscribing to additional software functionality or industry events that we are participating in.
If you are a corporate customer, we will send these marketing communications to your company email address unless you have opted out. You can change your marketing preferences at any time by clicking on the "unsubscribe link" in any of our marketing communications or by contacting us at email@example.com.
For non-corporate customers, we will only send you marketing communications to your personal email address by electronic means (e-mail, via our apps or text) if those communications relate to goods, services or opportunities which are similar to those that you have previously purchased or expressed an interest in or if you have consented to us contacting you in this way. We will only permit third parties to send you marketing communications by electronic means if you have specifically consented to this. You can change your marketing preferences at any time by clicking on the "unsubscribe link" in any of our marketing communications or contacting us at firstname.lastname@example.org.
10. Data Storage
We will take all steps reasonably necessary to keep your data secure. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to our Websites or Mobile Apps via the internet.
We will generally retain your personal information for seven years unless we are required by law to retain your personal information for a longer period.
11. Transfers of your Personal Information out of the EEA
We will not transfer Personal Information to any country outside the European Economic Area without your prior written consent and such consent may be subject to and given on such terms as you may in your discretion prescribe (acting reasonably and in compliance with Data Privacy Laws). Any transfer of your data outside the EEA will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
- recognise you whenever you visit our Websites (this speeds up your access to the Websites as you do not have to log in each time);
- obtain information about your preferences and use of the internet;
- carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests;
- target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and
- make your online experience more efficient and enjoyable.
Description of cookies
The table below provides some information on the cookies which we use on our Websites:
Turning off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our Websites. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
13. Third Party Links
Our Websites and Mobile Apps may contain links to enable you to visit third-party websites, mobile sites and mobile applications. Please note that we do not have any control over these third-party websites, mobile sites or mobile applications. Therefore, we are not responsible for the protection and privacy of any information that you provide whilst visiting such sites. Such sites are governed by their own privacy policies and not this Privacy Notice.
14. Contact Us
If you have any questions or comments on this policy or you would like to request a copy of your personal information, you can contact our Data Protection Officer at us at: DPO@deliowealth.com.
Post: Data Protection Officer, Delio Ltd, Cardiff Business Technology Centre, Senghennydd Road, Cardiff, Wales CF24 4AY
15. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. You should check this Privacy Notice occasionally to ensure that you are aware of the most recent version that will apply each time you access our websites.
Where we have made any changes to this Privacy Notice which affects the manner in which we use your personal information, we will notify you of this change.