Privacy Policy

Customer privacy notice

At Just Us Financial Solutions Ltd we respect your privacy and the confidentiality of your personal information.

Who are we?

Just Us Financial Solutions Ltd is

➢ an appointed representative of Quilter Financial Services Limited and Quilter Mortgage Planning Limited

who is part of the Quilter Group of companies.

For further details on the companies in our group, please visit
https://www.quilter.com/about-us/our-brands/

This Privacy Notice explains:

➢ Who we are
➢ What personal information we collect
➢ How we use your personal information
➢ Who we share your information with and why
➢ How we keep your information secure
➢ Your rights
➢ How to contact us

Who we are

Just Us Financial Solutions Ltd provide financial planning solutions and advice through experienced and qualified advisers based in the UK.

Currently, Just Us Financial Solutions Ltd and Quilter Financial Planning (Quilter) jointly determine the purposes and means of processing personal client data relating to giving advice. This means we’re joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.

However, Just Us Financial Solutions Ltd is solely responsible for some activities, for example any direct marketing that we undertake.

What personal information we collect

Personal information includes your name, address, or phone number and other information that isn’t otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial advisor, visit a website we may have or register to
receive one of our newsletters (if applicable).

The type of personal information we collect will depend on the purpose for which it is collected and
includes:

➢ Contact details
➢ Information to verify your identity
➢ Family, lifestyle, health and financial information
➢ Payment details

We collect personal information directly from you. For example, we ask for personal information at the
start of our relationship and in subsequent communications, in order to check your identity and protect
you from fraud. This is a legal requirement and is important to help safeguard you against potential
crime.

SPECIAL CATEGORY INFORMATION
In some instances, it is necessary to collect more sensitive information (such as health or lifestyle
information) which is called special category data. This is to allow us to provide our financial advice
service to you. We will always obtain your consent during the advice process to gather this data and
explain what information we require and why it is needed. Sensitive personal information will always be
processed and stored securely. You can withdraw your consent at any time to us processing this data,
however, this may mean that you can no longer access the service or product the information was
gathered for.

Cookies
We also collect information about you from other sources. For example, our website automatically
collects information from your computer using “cookies” which provides us with limited personal
information. Cookies are small text files that are placed on your computer by websites that you visit.
They’re widely used in order to make websites work, or work more efficiently, as well as to provide
information to the website owners. For further information visit www.aboutcookies.org or
www.allaboutcookies.org.

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

Data retention

We keep your personal information only as long as is necessary for the purpose for which it was
collected and to meet regulatory or legislative requirements. Personal information will be securely
disposed of when it’s no longer required, in accordance with our Data Retention and Disposal Schedule.
A copy of this is available using the contact details below.

On what basis do we collect data?

The processing of your personal data is allowed under a number of lawful bases. The data required for
the provision of products and services is processed on the basis there’s a contract with you to do so. Any
relevant marketing activity we undertake is done because, as a firm, we have a legitimate interest to do
so. However, you have rights, as listed below, which impact how we can use and process your data.

How we use your personal information

We process your information in order to support and maintain our contractual relationship with you
and to comply with legal and regulatory requirements. This includes the following:

➢ Providing our advice, products or services to you
➢ Carrying out transactions you have requested
➢ Confirming and verifying your identity for security purposes
➢ Credit scoring and assessment, and credit management (where applicable)
➢ Detecting and preventing fraud, crime, money laundering or other malpractice.

We also process your data for specific business purposes to enable us to give you the best products
and services and the best and most secure experience. For example, we process your information to
send you marketing that is tailored to your interests.

Our business purposes include the following:

➢ Enhancing, modifying, and personalising our services for the benefit of our customers
➢ Providing communications which we think will be of interest to you
➢ Market or customer satisfaction research or statistical analysis
➢ Audit and record keeping purposes
➢ Enhancing the security of our network and information systems.

You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below.
Please bear in mind that if you object this may affect our ability to carry out the tasks above for your
benefit.

We may also process your personal data as part of an acquisition or sale. Should this happen, you will
be notified about any change to processing or data controller arising as a result of this activity.

Who we share your information with and why

We share your information with trusted third parties who perform tasks for us and help us to provide
the services you require these include:

➢ Quilter Financial Services Limited;
➢ Other adviser firms in the network for the purpose of providing you with advice (with your
knowledge);
➢ The Quilter Group of companies to enhance the services and products we can offer you;
➢ Third parties to verify your identity, in line with money laundering or other requirements (this
may involve carrying out checks with credit reference databases);
➢ Third parties who perform tasks for us to help us set up or service your plan (these third parties
may be based in countries outside the European Economic Area (EEA) but where they are, we’ll
undertake an assessment of safeguards in place);
➢ Other organisations, including regulatory bodies, the police and fraud prevention agencies, to
prevent and detect fraud;
➢ Third parties where required by law, court order or regulation; and
➢ Third parties as part of an acquisition or sale.

How we keep your information secure

We’re committed to ensuring the confidentiality of the personal information that we hold and we
continue to review our security controls and related policies and procedures to ensure that your
personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality
obligations on them to ensure that personal information is kept secure.

If we work with third parties in countries outside the EU, we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.

In limited circumstances, data may be accessed outside of the EEA i.e. by employees when they travel. In
these circumstances, we ensure there are appropriate information security measures in place to
safeguard your information.

Your rights

Just Us Financial Solutions Ltd tries to be as open as it can be in terms of giving people access to their
personal information and therefore have outlined your rights below. This privacy notice was drafted
with brevity and clarity in mind, therefore further information can be gathered by contacting us using
the details below, or more information about your data protection rights can be found here:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individualrights/

Marketing
You have the right to opt out of receiving marketing information and tell us what your communication
preferences are by contacting Quilter Financial Services using the details provided at the end of this
notice or by using the opt out option below or on any email marketing. You may opt out at any time if
you don’t want to receive any further communications of this nature.

Individual data rights and requests

➢ The right to be informed – You can request that we provide ‘fair processing information’,
typically through this privacy notice;
➢ The right of access – You may request a copy of the personal information we hold about you
using the contact details found on the end of this privacy notice;
➢ The right to rectification – The accuracy of your personal information is important to us. You
have the right to ask us to update or correct your personal information;
➢ The right to erasure – You may request the deletion or removal of personal data where there’s
no compelling reason for its continued processing;
➢ The right to object – You may object to the processing of your data based on legitimate
interests;
➢ The right to restrict processing – You have a right to request we ‘block’ or suppress processing
of your personal data;
➢ The right to data portability – You may request to obtain and reuse your data; and
➢ The right not to be subject to automated decision-making including profiling.

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data
subject rights listed above, please contact us at the number/address listed below.

How to contact us

If you have questions about this notice, need further information about our privacy practices, or wish to
give or withdraw consent, exercise preferences or correct your personal information, please contact us
using the following details. Quilter will liaise with Just Us Financial Solutions Ltd on your behalf to effect your requests.

The Office of Data Protection
Quilter Financial Planning Limited
Wiltshire Court
Farnsby Street
Swindon
Wiltshire
SN1 5AH

Telephone: 0161 488 3559
QFPDataGuardian@quilter.com

How to complain

If you wish to raise a complaint about how we have handled your personal data, you can contact The
Office of Data Protection who’ll investigate the matter.

If you’re not satisfied with our response, or believe we’re not processing your personal data in
accordance with the law, you can complain to our regulator:

Information Governance Department
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
www.ico.org.uk/concerns