Privacy
We take our duty to safeguard your data seriously. Our Privacy Policy sets out our privacy commitment to you and explains your rights.
Who we are
IFGL Pensions is a brand name of IFG Pensions Limited.
Registered Office: Third Floor, Cotton House, Old Hall Street, Liverpool, L3 9TP United Kingdom.
Registered in England and Wales No 4826217.
IFGL Pensions is authorised and regulated by the UK Financial Conduct Authority No 458576
Where we collect personal information from
You may have supplied your personal data to us through:
- application form,
- emails and letters,
- phone,
- by consent through your IFA,
- via other companies within IFGL.
Your Financial Adviser should tell you when they pass your details on to us and you should have given your consent to allow your Financial Adviser to pass your details to us.
Your personal data
‘Personal data’ means any information that can be used to identify an individual person. IFGL Pensions in the course of its relationship with you will collect the following data about you and, in some circumstances, your spouse, civil partner, partner, beneficiaries or dependants: Client details (name, date of birth and so forth);
- Contact details (address, telephone, email);
- link Identification documents (passport);
- Marital status and other data, which is deemed special category of data regarding lifestyle, sexual orientation or religion (gender, marital or relationship certificate);
- National insurance number;
- Tax identification number;
- Bank details;
- Source of wealth
All personal data we collect and hold will be processed lawfully, fairly and in a transparent manner in relation to you as our data subject.
What is sensitive data?
In some circumstances we may collect sensitive information about you such as:
- details of your health
- your race / ethnic origin
IFGL Pensions will require your explicit consent to process sensitive information. If we do not receive this consent from you we may not be able to accept you as a member.
If you make any of your sensitive personal data public such as putting information on social media, we can process that data as this information will be in the public domain.
We can also further process your sensitive personal data in the exercise or defence of legal claims for or against IFGL Pensions or whenever we need to comply with a court order.
Biometric ID Verification
The processing of your information for Biometric ID Verification includes processing by use of the ID-PAL app supplied by ID-Pal Limited, a company incorporated under the laws of Ireland with company registration number 578727.Registered office is at 145 Pearse Street Dublin 2 D02 CP08. Processing of Your Information by ID-Pal is carried out as processor on behalf of IFGL Pensions as Controller.
Your explicit consent to processing of “special category” biometric data
In order to carry out ID verification with the ID-Pal App, we need your explicit consent to process your biometric data in the ID-Pal App. The ID-Pal App is offered for your convenience as a quick and efficient way to verify your identity. You are under no obligation to use the ID-Pal App and have your biometric data processed. You may withdraw your consent at any time - if you wish to withdraw your consent, please cease using the ID-Pal App and delete it. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
We may carry out automated processing of your ID when ID-Pal is used. Where an automated decision results in an outcome of non-standard rights or risk, human intervention is always undertaken.
How do we collect your information?
- directly from you; when you submit your information through the ID-Pal app, or if you contact us directly for any reason, for example calling us or emailing us; and
- from third party service providers or public sources, to conduct verification checks on the information you have provided to us.
How we use your personal information
As the controllers of your personal data IFGL Pensions may process your data:
a) to administer and operate policies
b) to fulfil IFGL Pensions legitimate interests, in particular in the course of the operation, support and development of our businesses, evaluating customer service, efficiency, cost and risk and for management purposes
c) carrying out anti money laundering and conflict checks for the prevention of financial crime or fraud
d) exercising and defending our legal rights, complying with regulatory authorities and legislation
e) for audits by national and regulatory enforcement
We will ensure that your personal data is processed in a manner that ensures it is appropriately secure and we will protect your information against unauthorised or unlawful processing, accidental loss, destruction or damage
Your data will not be further processed in a manner that is incompatible with the above purposes.
How the law protects you
Under the UK General Data Protection Regulation (UK GDPR) IFGL Pensions will process and retain your personal information only if we have a lawful bases to do so. This includes sharing your information outside of IFGL Pensions. We must have one or more of the following reasons to process and retain your data:
- To fulfil a contract we have with you
- When it is our legal duty
- When it is in our legitimate interest
- When you consent to it. (When you give your consent, it should be given freely by you along with an informed indication of your wishes which signifies your agreement of your personal data being processed).
The processing of your information is done so within the legitimate interests of business or commercial activities (these are not overridden by prejudice to your privacy rights). For IFGL Pensions to comply with applicable regulations it will be necessary, in some cases, to disclose your personal details which would be classed as a legal duty. We will also process your data in order that we can assist you with your policy under the terms and conditions set out in your policy of which IFGL Pensions consider this to be a contract between you and IFGL Pensions.
Sending data outside the European Economic Area (“EEA”)
Your personal data may be transferred to another country, which may also include countries outside of the European Economic Area (EEA) and countries that the European Commission has deemed adequate. This may be because you or your Financial Adviser live outside the EEA. In those cases where the relevant country has been checked to ensure it has an adequate level of data protection by the European Commission, or we need to make the transfer in order to perform a contract in your interests, we will ensure that the transferred personal data is protected.
In such case, the legal tool for international transfer is the standard contractual clauses drafted by the European Commission, a copy of which may be found at the following link: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? uri=CELEX%3A32021D0914&locale=en
How long we keep your personal information
IFGL Pensions shall retain your personal data for the entire duration of the contractual relationship.
After, IFGL Pensions shall retain data according to the applicable law, but no longer than what is required by the applicable law or the statute of limitation for civil liability.
Beyond, the data shall be destroyed or anonymised.
Your rights:
Unless legal exemptions apply, you shall have the right:
- To be informed about how we use your personal data;
- To access your data and obtain one copy free of charge in an electronic format;
- To have your data rectified promptly if it is inaccurate or incomplete;
- To have your data erased;
- To restrict processing; and
- To object to processing of your data.
Opt-out from legitimate interest
You have the right to opt-out at any time from legitimate interest-based processing, unless we can demonstrate a compelling legitimate ground (e.g., fraud detection). In case of marketing, you have always the right to opt-out.
IFGL Pensions is represented within the European Union by Holla N.V, thus the relevant data protection authority is the Dutch Data Protection Authority Information and Data Protection Commissioner.
Holla N.V
Stationsplein 101
5211 BM 's-Hertogenbosch
Postbus 396
5201 AJ ’s-Hertogenbosch
The Netherlands
How to complain
You can lodge complaints about our processing of your personal data to us here at pensions@ifglpensions.com
Should your complaint about our processing of your personal data not be resolved to your satisfaction you can then send your complaint to the ICO - Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Cookies
‘Cookies’ are text files, which are sent to your computer or other devices when you visit a website. To find out more about how we use cookies please see our Cookie Policy.
Sending your personal data onwards
If you wish to set up a policy with a competitor, it is your right to ask for us to send on your personal data to them. If you would like us to do this our customer service team will assist you as and when this happens.
Marketing
We do not use your personal data to directly market our products to you
Finally
This is our main statement. You will find parts of this statement broken down into smaller sections on our website and in pieces of our literature. Not all parts of the statement will relate to each client. Therefore, your application forms and literature you receive about us will be tailored to suit you.
The most important thing is that you feel in control of your personal data. We will help you to do this with us as much as we can.
If you are unsure or if you feel something is not clear you can contact our DPO who will be able to answer your questions by emailing Compliance@ifglpensions.com.