Privacy Notice

This privacy notice explains how we use personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to usage of our website is collected using cookies.  These are text files placed on your computer to collect standard internet log information and visitor behaviour information.  We may use your information collected from the website to personalise your repeat visits to the site.

Why do we need to collect and use personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively.  In addition, without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations.

Where special category data is required, we will obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may contact you about other products or services that we think may be of interest to you.

If you agree, we will pass on your personal information to other deVere Group companies, especially if you move jurisdiction, so that you will receive ongoing services; they may also offer you their own products and services. This consent to transfer your data to a new controller will be obtained at the time of your relocation and will require you to sign a Data Transfer Form.

We will not share your information for marketing purposes with companies outside our group of companies.

In order to deliver services to you effectively we may send your details to third party providers, such as those we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you and as long as it is in connection with relevant transactions.

Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit.  This could include password protection and/or encryption of data. Administration services are outsourced and provided by the deVere Group based in Malta.

To fulfil our obligations in respect of prevention of money laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

How long do we keep hold of your information?

In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.  In any case, we will not retain your personal data for longer than 10 years past the time of your death.  
You have the right to request deletion of your personal data.  We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you.  If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date.  Please ask us to correct or remove any information that you think is incorrect.   

Marketing

We would like to send you information about our products and services and those of other companies in the group which may be of interest to you.  If you have agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving information to other members of the group.  If you no longer wish to be contacted for marketing purposes, please contact us by email or post by writing to the address given.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have the right to lodge a complaint with the supervisory authority for data protection.  

In Spain this is: Reglamento General de Protección de Datos

Changes to our privacy policy

We keep our privacy policy under regular review and we will inform you of any changes when they occur or we will place any updates on our website.
This privacy policy was last updated on 23rd May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

Email:                
data.request@devere-spain.es

Address:            
Data Controller
deVere Group
Centre Point, 1st Floor
Dun Karm Street
Birkirkara By Pass
Birkirkara, Malta
BKR 9037