Silo Privacy Policy
29/04/2019
Please read this Privacy Policy carefully. It applies to you when you visit killik.com, MyKillik.com and client.killik.com (our sites), use our mobile applications (apps), telephone our branches or open and operate a Killik & Co account. It sets out how we use and protect any information that you give us.
We take your privacy very seriously and are committed to ensuring that your privacy is protected. Whenever we ask you to provide us with information about you, be assured that it will only be used in accordance with this Privacy Policy. We do not share data with other organisations unless the law permits us to do so. We do not sell individuals’ information.
For the purpose of this Privacy Policy and the General Data Protection Regulation (GDPR), Killik & Co (we and us) of 46 Grosvenor Street, London W1K 3HN is a ‘data controller’. We are registered with the Information Commissioner under registration number Z5711970. Our Data Protection Officer can be contacted at: [email protected].
What we collect information you give us
If you express an interest in us and our services, we may ask you for basic contact information such as your name, email address, telephone number, postal address. We may ask you some questions about your circumstances and the nature of your enquiry, to improve our response. We may also survey visitors of our website or individual pages for the purpose of research to understand more about their needs and use of the site to improve user experience.
When you apply for an account with us we shall ask you for information that will include: your name; contact information including email address, mobile phone number, and address; National Insurance Number; bank account details; information about your financial situation including income, expenditure and spending patterns; and copies of personal identification documents (such as your passport or driving licence).
Before you submit any information, we will notify you as to why we are asking for it and it is up to you whether or not
you provide it. The majority of the information is necessary for us to be able to provide our services and/or fulfil our legal obligations and we won’t be able to open or maintain an account for you if you choose not to provide it.
Information we collect about you
We collect information from you about the computers, phones or other devices you use where you install or access our Site or App. We may use this information to help us provide consistent experience across your devices. Here are some examples of the information that we collect:
- Device attributes such as the operating system, hardware version and geographic location based on your internet service provider
- Connection information such as the name of your mobile operator or internet service provider, browser type, language and time zone
- Behaviour such as viewing a specific page, opening a statement or downloading a document.
When you telephone us, calls are recorded and your phone number will be searchable within our call recording system.
Correspondence with you will be stored in our prospect/customer database.
Uses made of the information
We must have a good reason, known as a “lawful basis” to use your information. The table on page 3 explains more about the type of information we collect, how we use it and why, and the lawful basis for doing so.
Where the stated lawful basis for processing your data is “our legitimate interests,” this may be for the purpose of:
- Keeping in contact with you if you have expressed an interest in our services
- Marketing other services to current clients and sharing other relevant content or better browsing experience of our website
- Marketing services to people who look or behave similar to our existing clients
- Prevention of fraud and financial crime
- Ensuring network and information security
- Inter-group transfers
- Monitoring our services for regulatory compliance,customer satisfaction and complaints and future business strategy.
See also Appendix 1 – Cookie Policy.
In our Silo service and as detailed in the table below, we use some of your information to reach an automated decision about which of our investment strategies is suitable for you. The automated decision is based on a numerical score that attaches to certain information you have provided and the answers given to a series of questions about risk. The automated decision making process has been carefully designed to choose a suitable investment strategy. We also carry out regular reviews of the results of the automated decision-making to ensure it is working correctly. If you have queries or concerns about the investment strategy that has been selected for you, please contact [email protected]
Disclosure Group companies
Killik & Co LLP, Killik & Co Trustees Limited, Killik Intelligent Savings Limited.
Data Processors
Carefully selected third parties necessary in providing the services, e.g. ID verification services, payment services, bank account aggregation services etc.Analytics Services
Services that assist with optimisation of our Site or App and help us to understand how visitors use/navigate our Site or App.Business Acquirer
Prospective or actual acquirer of some or all of our business in the event that any part of our business were to be sold (information about clients and prospects will be a business asset).Authorities
To comply with legal obligations; to enforce our legal agreements; to protect our rights, property or safety and that of our clients and others. This could include exchanging information with other companies for fraud prevention purposes.Security and where we store your personal data
We are committed to ensuring that your information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place strict procedures and security features around the App, our sites and our internal systems and databases. All information you provide to us is stored on our secure servers and payment transactions will be encrypted using SSL technology. Where you use Intelligent Siloing and provide us with your bank login details, these are stored encrypted. Where you have chosen a PIN which enables you to access our Site or App, you are responsible for keeping the PIN confidential. We ask you not to share your login details with anyone.
You should remember that transmission of information via the internet is not completely secure. We may use encryption as way of protecting attachments to emails that may contain your personal information. However, we cannot guarantee the security of information that you transmit to us via our sites or by email. Any transmission is at your own risk.
Data provided to third party partners such as online platforms, will be aggregated (groups of people rather than individuals) and either anonymised (removing personally identifiable information for privacy protection) or pseudonymised (a data management process where personal information is de-identified by replacing it with artificial identifiers or pseudonyms again for privacy purposes). We may also use third party cookies, which are managed by partners and governed by your interactions and consents with those individual third parties as well as our own website.
Before we share your information with any Data Processors or Business Partners we make sure that they have appropriate technical and organisational security measures in place to keep your information safe and that they have undertaken to comply with data protection law and regulations. Typically, the data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. If for any reason we need to transfer and store your data outside the EEA, we will do so only where we have assessed that equivalent data protection measures are in place. By providing us with your personal information, you agree to this transfer, storing or processing.
How long we keep your personal data
We will retain your personal data for the duration of our contract with you and for a reasonable period of time afterwards. We are bound by financial regulation to keep our records for set periods of time and will also wish to retain enough information where we have a legitimate interest in doing so.
Links to other websites
Our site may contain links to other sites of interest. However, once you have used these links to leave our sites, you should note that we do not have any control over those other sites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting other sites and such other sites are not covered by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the sites in question.
Controlling your personal information you may choose to restrict the collection or use of your personal information in the ways
Consent
If you have previously agreed to us using your personal information for our own marketing purposes, you may change your mind and withdraw this consent at any time.
Access
You may request details of the personal information which we hold about you. We must provide this to you free of charge within 30 calendar days of your request.
Correction
If you believe that any information we are holding about you is incorrect or incomplete, please tell us as soon as possible. We will promptly correct any information found to be incorrect.
Objection, Restriction or Deletion
You may have the right to object to the way in which we process your data, you may ask us to restrict the processing of your data, or you may ask us to delete it.
Please direct all enquiries concerning your control over your personal information to [email protected]
The supervisory authority for data protection in the UK is the Information Commissioners Office. You have the right to complain to them about the way in which we process your data and their helpline number is 0303 123 113
See also Appendix 1 for details on how you can manage the way that Cookies use and store information about you.
Updates to this Privacy Policy
We may change this policy from time to time by updating this page. You should check this page periodically for any changes.
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