Privacy Policy

Wake up your Wealth LLP Privacy Policy

Wake Up Your Wealth (WUYW) takes the privacy of your data seriously. We are committed to safeguarding your privacy while providing a personalised and valuable service. This Privacy Policy explains the data processing practices for WUYW.

We ask that you read this privacy notice carefully as it contains important information about WUYW; how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and the supervisory authority in the event you have a problem or complaint.

Italicised words in this privacy policy have their meaning set out in the Glossary of Terms at the end of this document.

Who is Wake Up Your Wealth

WUYW collects, uses and is responsible for certain personal data about you. WUYW is required to comply with data protection regulation, and we are responsible as a data controller of that personal data for the purposes of those laws.

Wake Up Your Wealth is registered in England and Wales (OC404121) and our registered office is at Unit 10, Southbrook Mews, Southbrook Road, Lee, London, SE12 8LG. We are authorised and regulated by the Financial Conduct Authority, our Financial Services Register number is 746535 and we are registered with the Information Commissioner’s Office under Registration No: ZA227628

The personal data Wake Up Your Wealth collects and uses

WUYW collects personally identifiable information about you through:

The use of enquiry and registration forms.
Your use of any WUYW services.
The provision of your details to WUYW either online or offline.

In the course of providing our services to you WUYW may collect the following personal data when you provide it:

contact information
identity information
financial information
employment status
details of your dependants and/or beneficiaries under a policy (If you are providing information about another person, we expect you to ensure that they know you are doing so and are happy for their information to be provided to us. You might find it helpful to show them this privacy policy and if they have any concerns please contact us in one of the ways described below.)
products

Special categories of data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data, bio-metric data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

WUYW may process:

health information and lifestyle information
details of any vulnerability;

and/or

criminal conviction or offence information when providing our services in relation to a range of products

WUYW doesn’t use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver our services and we have obtained your explicit consent to do so.

Information Wake Up Your Wealth collects from other sources

WUYW also obtains personal data from other sources in the course of providing our services. Where WUYW obtains this information from another party, it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information.

The personal data WUYW obtains from other sources may include the following:

Your employer
Product providers/scheme administrators
Professionals such as your Solicitor or Accountant
Identification and verification checking agencies
- identity information
- sanction check information

How Wake Up Your Wealth uses your personal data

In order to deliver our services to you effectively WUYW may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers, WUYW also uses Client Relationship Management systems (CRMs). Where third parties are involved in processing your data, WUYW 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 care in processing your data and that they’ll only act in accordance with our written instructions.

WUYW also extracts certain information from your data for the purpose of generating statistics, but it is not possible to identify you from these statistics.

The table below sets out:

How WUYW uses your personal data.
The lawful bases upon which WUYW uses your personal data.
Who WUYW routinely shares your personal data with.

Rationale/Reason for Processing	Lawful Basis for Processing	Third party recipients linked to that activity
To provide you with our services.	Performance of a contract	· Product providers/scheme administrators · Compliance support services · IT Systems and software providers · Accountancy, regulatory or legal services
Improving our services.	Legitimate interest	· Compliance support services · IT Systems and software providers · Accountancy, regulatory or legal services
To retain records of our services or advice provided to you by WUYW in order to defend potential legal claims or complaints.	Legitimate interest	· Compliance support services · IT Systems and software providers · Accountancy, regulatory or legal services
To provide you with details of products and our services from WUYW and third parties that may be of interest to you in accordance with your preferences. For more information see ‘WUYW marketing’ below.	Consent	· IT systems and software providers · Marketing agencies

Automated decision making and profiling

WUYW uses automation to make some decisions without any human WUYW uses automation to make some decisions without any human involvement. These decisions are generally based on factual data and can lead to quicker and more consistent decisions, particularly where large volumes of data need to be analysed. When you use WUYW, your personal data will be gathered through the information that you give us, your data is then processed by WUYW to carry out our services to you. If you’re unsure about the outcome of WUYW’s automated processes or require more information about these; you can contact us to discuss or to challenge the outcome.

Use of Cookies and other tracking devices

As is common practice with almost all professional websites, WUYW uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. The WUYW’s Cookies Policy describes what information we gather, how we use them and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored, however this may downgrade or disrupt certain elements of our functionality. The WUYW Cookies Policy can be viewed here.

WUYW uses tracking on some web pages, which records user movements, including page scrolling, mouse clicks and text entered. The data collected in this way helps to identify usability issues, to improve the assistance and technical support we can provide to users and is also used for aggregated and statistical reporting purposes.

Telephone calls

WUYW may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve the quality of our services, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.

Wake Up Your Wealth marketing

WUWY may use personal data held about you to help identify, tailor and provide you with details of products and our services from WUYW that may be of interest to you. We will only do so where there is a legitimate business reason to do so and will do this in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us.

How long will Wake Up Your Wealth hold your personal data?

WUYW will not hold your personal data for longer than is required under the terms of our contract for our services with you. WUYW is subject to regulatory requirements to retain data for specified minimum periods. In addition, we are obliged to treat our customers fairly in the event of a future complaint and therefore we reserve the right to retain data for longer than these specified minimum periods in order to allow us to investigate such complaints and, if necessary, defend a future claim against us, currently 7 years. However, we may keep your data for longer than 7 years if we cannot delete it for legal or regulatory reasons; for example, WUYW has to hold pension transfer information indefinitely.

WUYW will therefore keep your personal information securely for as long as we need to for the purpose of providing you with financial advice under the terms of our services or for as long as we are required to by relevant regulations. WUYW regularly reviews the legal and regulatory obligations around the retention of your personal information.

Keeping your personal data secure

WUYW takes measures to ensure the security of your data, industry best-practice is followed at all stages of the data life-cycle. We are always working to improve the methods employed to secure your data, for example, data is encrypted when in transit across public internet links and stored in an encrypted format in our systems. WUYW limits 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.

WUYW has 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.

You are responsible for your secure use of our services and for choosing a secure password when we ask you to set up a password to access our services. You should keep this password confidential and should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, WUYW cannot guarantee the security of any personal data sent to our site while still in transit and so you provide this at your own risk.

Transfer of your information out of the European Economic Area (EEA)

WUYW does not routinely transfer or authorise the transfer of your personal data to countries outside the EU and/or the European Economic Area (EEA).

If WUYW needs to transfer your personal data from a country within the European Economic Area to a country outside the European Economic Area, we shall ensure that your personal data is adequately protected. To achieve this we will use EU approved standard contractual clauses or any other EU approved transfer mechanism for the transfer of this data.

Wake Up Your Wealth and your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out in the table below:

Your right to…	What this means for you
access personal data	You can ask WUYW to confirm whether we have and are using your personal data. You can also ask for a copy of your personal data from us and for information on how we process it. We may ask you for proof of identity when making a request to exercise these rights. WUYW does this to ensure we only disclose information or change your details where we know we are dealing with the right individual. WUYW will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request. WUYW aims to respond to all valid requests within one month. It may however take longer if the request is particularly complicated or you have made several requests. WUYW will always let you know if a response will take longer than one month. To speed up the response, we may ask you to provide more detail about what you want to receive or are concerned about. WUYW may not always be able to fully address your request, for example if it would impact the duty of confidentiality of others, or if we are otherwise legally entitled to deal with the request in a different way.
correction or erasure of personal data	You can ask that WUYW rectify any information about you which is incorrect. We will be happy to rectify such information but may need to verify the accuracy of the information first. You can ask that WUYW erase your personal data if you think we no longer need to use it for the purpose we collected it from you. You can also ask that we erase your personal data if you have withdrawn your consent to us using your information (if we originally asked for your consent to use your information). Please note; WUYW may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
restrict how WUYW uses personal data	You can ask that WUYW restrict the use of your personal data in certain circumstances, for example: where you think the information is inaccurate and we need to verify it; where our use of your personal data is no longer required, but you do not want us to erase it; where the information is no longer required for the purposes for which it was collected, but we need it to establish, exercise or defend legal claims; or where you have objected to our use of your personal data, but we still need to verify if we have overriding grounds to use it. WUYW can continue to use your personal data following a request for restriction where we have regulatory obligations; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
object to how WUYW uses personal data	You can object to any use of your personal data, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interest to use the information.
to transfer personal data to another organisation	You can ask WUYW to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company). You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right only applies to data that: is held electronically, and you have provided to Wealth Wizards.
object to automated decisions	If WUYW made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where WUYW is authorised by law to make such decisions and has adopted suitable safeguards in the decision-making processes to protect your rights and freedoms.
find out more about how WUYW uses personal data	If you are not satisfied with the level of information provided in this privacy notice, you can ask WUYW: What personal data we have about you and where we got your data from; What we use your information for and what automated decision were made; Who we disclose your information to and whether we transfer it abroad; How we protect your information and how long we keep it for; What rights you have and how you can make a complaint.

If you wish to contact WUYW, please send us an email: greg@wakupyourwealth.com or write to Wake up Your Wealth, The Powerhouse 21, 21 Woodthorpe Road, Ashford, Middlesex
TW15 2RP

Making changes to the Wake Up Your Wealth Privacy Policy

WUYW reserves the right to add to or change the terms of this Privacy Policy without prior notice. If WUYW changes this Privacy Policy, we will post the new Privacy Policy on the Service, and it will become effective from the time of posting. Please visit the our Privacy Policy on a regular basis to ensure you have read the latest version to understand what we do with your personal data.

Glossary of Terms

*WUYW, we, us or our*	Wake up Your Wealth, The Powerhouse 21, 21 Woodthorpe Road, Ashford, Middlesex, TW15 2RP
*contact information*	These are details that can be used to contact a person, including title, first name, surname, personal telephone number, email address, home address, postcode or city of residence. This may also include work contact information such as a works telephone number or a company email address.
*data controller*	A natural or legal person (such as a company) which determines the means and purposes of the processing of personal data. For example, WUYW is a data controller as we determine how we will collect personal data from you, the scope of the personal data which will be collected, and the purposes for which it will be used in the course of us providing you with our services.
data protection regulation	The applicable data privacy and protection laws, including the Data Protection Act 2018 in the UK and the GDPR in Europe and local implementing laws.
*employment status*	This is information about whether you are; employed, self-employed, unemployed, a student or retired.
Financial Conduct Authority	The Financial Conduct Authority, being the independent watchdog that regulates the financial services industry.
*financial information*	This is information relating to your financial status, including salary/income, outgoings/expenditure and tax status.
*health information*	This is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history.
*identity information*	This is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, passport, drivers’ licence and national insurance number.
*legitimate interest*	Legitimate interests is one of the six lawful bases for processing personal data. WUYW must have a lawful basis in order to process personal data in line with the ‘lawfulness, fairness and transparency’ principle. When processing personal data on the basis of legitimate interests, WUYW will complete a legitimate interests assessment to judge the purpose, need and balance (is the legitimate interest overridden by the data subjects’ interests, rights or freedoms?) of the processing.
*lifestyle information*	This includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits.
*our services*	This is the financial advice WUYW gives you and the services we provide to you in relation to products.
*products*	These can include an investment, pension and/or protection product in respect of which we provide our services to you.
product providers/scheme administrators	These are companies which provide or administer investment, pension and/or protection products or schemes.
sanction check information	This is information relating to your “politically exposed persons” (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering.
*vulnerability*	A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence).