As the operators of the Website (http://www.maslen.co.uk/property-financial-services), Maslen Financial Services ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

We are an authorised representative of the Best Practice IFA Group Limited (“Best Practice”), who assist us with various aspects of our compliance activity, including Financial Conduct Authority (“FCA”) compliance, anti-money laundering checks and Data Protection. In order that Best Practice can provide these services, we are required to send across personal data we have collected. More information about how Best Practice will use your personal data can be found in their Privacy Notice at https://www.bestpractice.co.uk/best-practice/privacy-policy.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all the following types of information from you in the course of providing our services.

• Information that you provide by filling in forms as part of the mortgage / insurance process. We may also ask you for information when you enquire about services.
• Specifically, personal details such as name, email address, date of birth or any information input by you, completing our survey/ feedback forms, using our Services
• If you contact Us, We may keep a record of that correspondence
• We may also ask you to complete survey / feedback forms that We use for research purposes, although you do not have to respond to them.
• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access

The provision of your name, address and date of birth, as well as other personal data is required from you to enable Us to fulfil our regulatory and legal obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information we collect from other sources

Where We receive referrals from introducers, We will also obtain personal data from other sources as follows:

• Name, address, email address, phone number and nature of enquiry from professional introducers.

USES MADE OF YOUR INFORMATION

Purposes of, and lawful basis for processing

We use information held about you for the following purposes:

• To provide you with our services and to carry out our obligations arising from any contracts entered between you and us, including:
  • To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you
  • To operate, protect and improve our services, our business, and our clients' experience
  • To respond to any enquiries you submit to us
  • As part of our efforts to keep our services safe and secure

Where we have a contract with you to provide our services, and where the processing of your data is necessary to perform such contract, we rely on “performance of a contract with the data subject” as the legal basis for the processing. In all other circumstances we rely on “legitimate interest” and our legitimate interests are improvement of our services and/or prevention or detection of fraud.

• Where you provide us with special category data, this will be used solely with your consent to research and advise on one or more products to suit your needs and to assist you with applications for and management of such products, and to provide such special category data to Best Practice and third party providers so that they can carry out the services that they provide to us
• To comply with our legal obligations as an authorised representative of an FCA regulated entity, including preparing and sending reports and submissions to Best Practice and/or regulatory authorities such as the FCA. “Compliance with a legal obligation” is the lawful basis on which we rely when we are carrying out regulated activities
• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. In these circumstances we rely on “legitimate interest” and the legitimate interest is the improvement of our services
• We also use your personal data where you have contacted us via the Website, by e-mail or telephone or participated in any surveys. In these circumstances we rely on “legitimate interest” and the legitimate interest is responding to and contacting you regarding the enquiries you have made in relation to the services we offer and may also include special category personal data relating to your health

Marketing

In addition to the above uses we may use your information to notify you about goods or services which may be of interest to you. If you do not want us to use your data in this way please either (i) tick the relevant box situated on your service charter on which we collect your data ; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

• We pass your information to Best Practice IFA Group Ltd (“Best Practice”), who provide us with various compliance services. Best Practice is a separate data controller, and details of what they do with your data can be found here: https://www.bestpractice.co.uk/best-practice/privacy-policy
• We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers)

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our client agreement/service charter; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the Website; or
• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to [email protected].

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

• We will hold personal data (e.g. name, address, date of birth and contact details) in line with our regulatory and legal obligations as set out by our regulator – currently a minimum of 5 years for investment business and indefinitely for occupational pension transfer or opt-out business
• If you contact us as a prospective customer using our e-mail address or via our Website contact form, requesting general information about our services, we will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact

Where we store your personal data

All of the information that We hold about you is stored on our secure servers within the European Economic Area ("EEA").

If you would like further information please contact US or The Data Controller at Best Practice, of which we are an Appointed Representative (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation ("GDPR") you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual's rights under theGDPR.

If you would like to exercise any of those rights, please:

• email, call or write to us, or write to The Data Controller at Best Practice
• let us have enough information to identify you (eg account number, username),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates, including any account or reference numbers, if you have them

HOW TO COMPLAIN

We hope that we or our Data Controller can resolve any query or concern you raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties' affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and allows us to improve the website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies we use include:

• “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily
• “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services
• “Functionality” cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region)
• “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose

Name	Expires	Information
PREF and NID	2 years from set/update	Google tracking and safe browsing cookies. Google’s NID and PREF cookies are set by browsers to protect users against known intrusive sites. Users can stop these cookies being set by turning off their browser’s ‘safe browsing’ mode.
__utma	2 years from set/update	Google Analytics - This cookie is typically written to the browser upon the first visit to our site from that web browser. If the cookie has been deleted by the browser operator, and the browser subsequently visits our site, a new __utma cookie is written with a different unique ID. This cookie is used to determine unique visitors to our site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.
__utmb	30 minutes from set/update	Google Analytics - This cookie is used to establish and continue a user session with our site. When a user views a page on our site, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a user visits a different page on our site, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals. This cookie expires when a user pauses on a page on our site for longer than 30 minutes.
__utmc	Not set	Google Analytics - this cookie operates in conjunction with the __utmb cookie to determine whether or not to establish a new session for the user. This cookie will expire when the user exits the browser.
__utmz	6 months from set/update	Google Analytics - This cookie stores the type of referral used by the visitor to reach our site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within our sites. The cookie is updated with each page view to our site.
search.thinkproperty.com ASP.NET_SessionId	Session end	This cookie is used to provide property search services from thinkproperty.com.  The partners' servers automatically record 'log files' containing information about the volume and characteristics of our website traffic e.g. IP address, numbers of pages viewed, length of time spent on site. Log files are used to build pictures of how our site is used that help us to monitor and improve the service. We cannot identify you from your log files.This cookie is deleted when you close your browser.
vebra.com ASP.NET_SessionId SQTSCSQA	Session end	This cookie is used to provide property search services from vebra.com.  The partners' servers automatically record 'log files' containing information about the volume and characteristics of our website traffic e.g. IP address, numbers of pages viewed, length of time spent on site. Log files are used to build pictures of how our site is used that help us to monitor and improve the service. We cannot identify you from your log files.This cookie is deleted when you close your browser.

Please note that third parties' affiliates may also use cookies, over which we have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to [email protected] write to The Data Controller, Maslen Financial Services, 39 Lewes Road, Brighton, BN2 3HQ. Alternatively, please write to The Data Controller, Best Practice IFA Group Ltd, Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP, telephone number 01403 334455, or via email at [email protected]