Hartley Pensions Privacy Notice

Hartley Pensions joined The Wilton Group in 2015.

The Wilton Group is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website you can be assured that it will only be used in accordance with this privacy policy.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

We take your privacy seriously. The following privacy policy covers the Hartley Pensions Limited (“Hartley”) web site at hartleypensions.com. Links to other web sites are not covered by this policy and we take no responsibility for external web sites accessed through the Hartley site.

Except where we specifically ask for information from you, this web site does not collect or store personal information. We do collect general anonymous technical information such as IP addresses (unique addresses of computers on the Internet) and pages viewed which we use for internal statistical reporting about our web site performance.

We may ask you for personal information if you want to take advantage of specific services that we offer, if you want to register for an event or if you ask to receive our email newsletter. In each case we will use the personal information you provide to deliver the service you have requested. The Wilton Group does not sell or rent data to third parties. We will only send personally identifiable information about you to other people or organisations when:

• We need to fulfil our legal obligations as Trustee.
• We respond to court orders or other legal processes.
• Where we are required by law to provide information to others.

What we collect

We may collect personally identifiable information about you, such as your full name, phone number and email address.

We require this information to understand your needs and provide you with a bette

What we do with the information we gather:

• Internal record keeping.
• To operate, maintain, enhance and provide services and information you have requested.
• We may be requested to use the information to comply with the current Laws and statutory obligations.
• We may use the information to improve our products and services.
• We may periodically send promotional email about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• We process client data solely in accordance with the directions provided by the applicable client or user.

How information is stored and processed
The Wilton Group is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised use or disclosure. We store the personal data you provide on computer systems that have limited access and are in controlled facilities. Your information collected through the Hartley website may be stored and processed in the EU or outside the EU. We may transfer information that we collect about you, including personal information, to affiliated entities.

Data Retention
We only retain the personal data collected for a limited period of time as long as we need to fulfil the purposes for which we have initially collected it, unless otherwise required by the law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Use of Data

• When you sign up to our email subscription list, we will store your data on our database.
• We will send you regular newsletters, information on specific and relevant subjects.
• We will send you information to fulfil our obligations as Trustee.
• We do not share user data with third parties outside the Wilton Group unless required by Law.
• We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter.

By providing your personal data, you agree to the storing and processing of your data.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law or to meet our obligations as Trustee. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

Controlling your personal information
You may request details of personal information which we hold about you under the General Data Protection Regulation (GDPR).

Contact us at any time to:

• Request access to information that Wilton Group has about you. You have the right to request access to the information we have on you. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.
• Correct or delete any information that Wilton Group has about you. If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed will be deleted. If at any point you wish for Wilton Group to delete information about you, you can simply contact us at the addresses below.

If you have any additional questions about Wilton’s collection and storage of data, please contact us at:

26 Grosvenor Street
Mayfair
London
W1K 4QW
+44 (0) 20 7355 3525
Email: wiltonit@wiltongroup.com

Lawful Grounds For Using Your Information

We have described the purposes for which we may use information about you, your Client Personnel or Other Relevant Individuals. We are permitted to process such information in this way, in compliance with the Data Protection Legislation, by relying on one or more of the following lawful grounds:

(a)          the processing is necessary to perform the agreement we have with you or them, or in connection to an entity to which we provide services with which you are connected, or to take steps to enter into such an agreement;

(b)          the processing is necessary for compliance with a legal obligation we have, or an entity to which we provide services with which you are connected has; or

(c)           the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:

(i)            to ensure that our services and business are well-managed;

(ii)           to fulfil our fiduciary duties and responsibilities (whether of ourselves or our employees) in relation to the entities to which we provide services;

(iii)         to prevent fraud and other crimes;

(iv)         to protect our business interests;

(v)          to comply with Court Orders, including but not limited to production orders and disclosure orders;

(vi)         to defend ourselves, or the entities to which we provide services, against claims;

(vii)        to ensure that complaints are investigated;

(viii)       to evaluate, develop or improve our products and services;

(ix)         to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so;

(x)          Or you or they have explicitly agreed to us processing such information for a specific reason.

Wilton’s Data Protection Officer
Wilton Group has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

Wilton (IOM) Limited
Attn. Data Protection Officer
Grosvenor House
66-67 Athol Street
Douglas
Isle of Man
IM1 1JE
+44 (0) 1624 675610
Email compliance@hartleysas.co.uk

Legal Basis for processing Data

• Legal obligations as Trustee – In specific situations, it may be necessary to process your data to enable us to comply with a our Legal obligations as Trustee
• Legal Compliance – If the Law requires us to, we may need to collect and process your data (for example to comply with our legal obligation to disclose employee salary details to HMRC).

Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Cookies
This site uses cookies. If you continue browsing this site, we’ll assume you’re happy with our use of cookies.

Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Website Disclaimer
The information contained in this website is for general information purposes only. The information is provided by The Wilton Group and whilst we endeavour to keep the information up-to-date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profit arises out of or in connection with the use of this website.

Through this website you are able to link to other websites which are not under the control of The Wilton Group. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them. The Wilton Group makes every effort to ensure that information provided on our web site is accurate. However, we cannot guarantee this and we accept no liability for any information or advice given or published via the web site.

Every effort is made to keep the website up and running smoothly. However, The Wilton Group takes no responsibility for and will not be liable for the website being temporarily unavailable due to technical issues beyond our control. The Hartley web site and all documents therein is copyright protected.

Copyright Notice
This website and its content is copyright of The Wilton Group Ltd – © Wilton Group Ltd 2018. All rights reserved.

Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:

• You may print or download to a local hard disk extracts for your personal and non-commercial use only.
• You may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material.

You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.

Company Details
The following operating companies are incorporated in England & Wales.

Hartley SAS Limited
Hartley SAS Limited is registered in England & Wales (06037774). Hartley SAS Limited a subsidiary of the Wilton Group.

Hartley Pensions Limited
Hartley Pensions Limited is registered in England & Wales (09469576). Hartley Pensions Limited is authorised and regulated by the Financial Conduct Authority. FCA Number 735936 and is a subsidiary of the Wilton Group.

This website is copyright protected.

Terms and Conditions
Welcome to our website. If you continue to browse and use this website you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern The Wilton Group’s relationship with you in relation to this website.

The term “The Wilton Group” or “us” or “we” refers to the owner of the website whose registered office is 26 Grosvenor Street, London, W1K 4QW. The term “you” refers to the user or viewer of our website.
The use of this website is subject to the following terms of use:

• The content of the pages of this website is for your general information and use only. It is subject to change without notice.
• Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
• Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
• This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
• All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
• Unauthorised use of this website may give to a claim for damages and/or be a criminal offence.
• From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
• You may not create a link to this website from another website or document without The Wilton Group’s prior written consent.
• Your use of this website and any dispute arising out of such use of the website is subject to the laws of England and Wales.