As part of Plurimi Wealth LLP (“Plurimi”) tradition of trust, the confidentiality of personal information is paramount, we are committed to maintaining the privacy of every current, former and prospective client. We recognise that you entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. You can visit our website without telling us who you are or revealing any information about yourself.
Information We Collect
We may collect information about you when you apply for services offered by Plurimi in the following ways:-
- We will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information.
- We may also collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us. If you decline to provide us with the personal information we require then we may not be able to make investment products available to you or to provide other services to you.
- Telephone calls to and from Plurimi Wealth may be recorded for regulatory and training purposes.
Security of data transfers
Please note that data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. Plurimi cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace an existing bank account or relationship or one that is subsequently created. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile.
Your data may be lost during transmission or may be accessed by unauthorized parties. We do not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.
Protection, Processing and Use of Personal Data
We use your personal information to enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal. We restrict access to personal information about you to those employees, agents or other parties who need to know that information to provide products or services to you or in connection with your investments through us. We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls, individual passwords and encryption and authentication technology. We do not use for purposes other than as set out above, or disclose to any third party any personal information about our clients or former clients, except with such clients consent or as otherwise permitted or required by law, for example, by a court order or for the purposes of prevention of fraud or other crimes. In cases where we believe that additional products and services may be of interest to you, we may share your personal information with affiliates of Plurimi to the extent permitted by applicable law. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.
How long is information retained?
Plurimi is regulated by the FCA, we have a legal obligation under MiFID II to hold records of processing activities for five years (with an option to extend it to seven years) and this would take precedence over your request for any erasure of those records before the period has expired. 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 three years after your death. We will not sell or share your information to third parties for marketing purposes.
Who has access to your information?
We will not sell or share your information to third parties for marketing purposes.
Your rights in relation to your information
The accuracy of your information is important to us. Where we are providing an ongoing service we will update the information as appropriate when we undertake a review with you. If between reviews you change your contact information please notify us and we will update our records.
General Data Protection Regulation (GDPR), under the new EU requirements you have a number of specific rights, which are summarised for you below:
Access – You may ask for a copy of the information Plurimi hold about you and we will provide this within one month of your request.
Rectification – You may ask us to correct any information that we hold that is inaccurate or incomplete.
Erasure – You may ask us to delete or cease processing data in certain situations. Please note that we will have regulatory obligations to retain information for certain time periods and we will retain such information as we believe is necessary to fulfil these obligations.
Restrict processing – You may ask us to cease processing information. This means that we will be able to retain it but no longer act upon it. In the event that you no longer need our services and terminate them we will automatically cease processing information.
Portability – You may have the right to have your data transferred to another service provider in an appropriate electronic format. Please note that we will have regulatory obligations to retain copies of the information as outlined previously.
Objection – You may have the right to object to us processing information or using it for marketing purposes.
This is a brief summary of your rights and there may be restrictions on some of them. If you wish to explore any of these rights at any time please contact us on the addresses above and we will be pleased to assist you.
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it is retained securely and processed in a confidential manner. Your information may be accessed by your Relationship Manager and our support staff for the purposes of providing our services to you. In addition, it may be accessed by senior managers and our compliance team (or the Financial Conduct Authority) for the purposes of ensuring compliance with our regulatory obligations and reviewing the quality of our advice. Information may also be provided to individuals to whom you have given authority to receive this, which can include personal representatives, legal entities etc.
Information may be transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information that passes between us, and you should consider the risk of this. Once we receive your information, we make our best effort to ensure its security on our systems.