1. Introduction

    Protecting our clients’ personal information at Advisa Financial Services Limited is of paramount importance. Advisa Financial Services Limited is fully compliant with the General Data Protection Regulation 2018 (E.U) & Data Protection (Jersey) Law 2018.

    Advisa Financial Services Limited (“we” or “us”) respect your privacy and value the trust you place in us when you share your personal information with us. The way we may collect and use your personal information and the choices available to you in connection with our use of your personal information is discussed in this Privacy Policy.

    Our Privacy Policy details important information about your personal data and outlines what we collect and why we collect it. It also contains information regarding who Advisa Financial Services Limited may share your personal details with and why. Finally, our Privacy Policy informs you of your rights with regards to the personal information that you provide to us.

    1. Who Advisa Financial Services Limited are
    2. We are one of Jersey’s leading and most trusted firms of independent financial planning professionals.

      This Privacy Policy applies to Advisa Financial Services Limited, noted in this document as “Advisa”. Registered Office: Unity Chambers, 28 Halkett Street, St. Helier, Jersey JE4 4WJ. Tel. 01534 724241 are regulated by the Jersey Financial Services Commission.

    3. How to contact us
    4. If you have any further queries regarding our Privacy Policy or require any further information on the personal information that we collect, please do not hesitate to email or telephone us on:

      info@advisa.je
      01534 724 241

      Alternatively, you can find us located at:
      Unity Chambers
      
28 Halkett Place
      
St. Helier
      
Jersey
      
JE2 4WJ

  2. Your Personal Information

    Advisa may collect any of the following personal information:


    1. Generic Information about who you are (E.g. Name, Date of Birth, Address and Contact Details)
    2. Information connected to your Advisa service or product (E.g. Bank Account Details)
    3. Information regarding our communication (E.g. Emails, letters, telephone calls and face-to-face meetings)
    4. Information that is collected automatically (E.g. via cookies from our Advisa website)
    5. ‘Sensitive’ personal details – this information will only be collected when it is required to comply with our legal obligations or to provide the service/product requested (E.g. Health records or Marital details)
    6. Information you may provide regarding other relevant people for products you have with Advisa (E.g. Beneficiaries or joint applicants)
    7. Information of children who may be named as beneficiary on a policy taken out by a parent or guardian on their behalf (In these cases Advisa will only use the information required to identify the child (E.g. Name, Gender and Age)
  3. What are cookies?

    A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself. A cookie cannot read data from your hard disk or read cookie files created by other sites.

    Cookies, however, enhance our web site performance in a number of ways, including:

    • Providing a secure way for us to verify your identity during your visit to our web site
    • Personalising your experience on our site, making it more convenient for you
    • Using cookies so that we can serve you better

    This site uses visitor tracking software that will use cookies to track:

    • Information about how visitors come to the website
    • Which pages they visit
    • Other actions that visitors make whilst on the site

    This data is then used in order to improve the user experience of the web site. All user data collected in this manner is anonymous.

  4. Where your information is collected from

    Your personal information may be collected either directly from yourself or from a variety of other sources including:

    1. A service or product application form
    2. Telephone conversation with an employee/representative of Advisa
    3. Emails or letter correspondence
    4. Face-to-face meetings with one of Advisa‘s Financial Advisers
    5. Advisa’s online services e.g. our website
    6. Event registration for an Advisa event
    7. Research survey participation e.g. a feedback survey on our products and services to aid us in improving them or better understanding our clients

    Due to the regulations set out by the General Data Protection Regulation 2018 (GDPR), accuracy of your personal data is of high importance. Therefore, Advisa may also collect personal data from publicly available sources, in order to keep our personal records of you up to date and accurate.

    Please be aware that we may also be provided personal information on your behalf from your financial adviser and / or if you are a member of any employer’s schemes.

  5. What we collect and use your information for

    Advisa only collects and uses personal data from our clients when it is fair, lawful and absolutely necessary to do so. We, at Advisa, take our clients privacy very seriously.

    Advisa will collect and use your personal information in the following circumstances:

    1. If we have been given your permission (consent) to inform you about products and services which we believe may be of interest or benefit you. The information we send will only be products and services offered either by Advisa and / or selected third parties that we have chosen to work with.
    2. If we have a legal or regulatory obligation to do so. For example; we may need to inform you of changes to our Terms & Conditions; send you your Annual Review or for the prevention and detection of fraud.
    3. If sharing your personal information is in the legitimate interest of a third-party provider. For example; a company pension scheme would mean your employer’s adviser may need to be informed of personal information for the governance of the scheme.
    4. If we necessarily need your personal information (such as; your name, address, date of birth and bank account details) in order to provide you with the product or service that you have selected.
    5. If it is in Advisa’s legitimate interest to send you appropriate guidance and information to increase awareness of the ranges of product and services available, ensuring that you get the best outcome of your chosen product or investment. It may mean that we need to process your personal information to better understand you and your requirements in order for us to deliver you more relevant information about the products you have with Advisa and to better understand how to improve them if need be.

    If you choose for Advisa not to collect and use your personal data in any of the ways above, it may result in us being unable to provide you with products or services.

    On occasion, Advisa may use personal information that you have consented to be used, by ourselves or others, to make automated decisions about you. We use automated decision making in a number of ways. These automated decisions can affect the products, services or features in which we can offer you either now or perhaps in the future. Automated decision making includes:

    • When designing or enhancing our online services, in order to meet your requirements with regards to support and ongoing guidance
    • When tailoring our products and services to help meet your needs. We may place you within a group with clients who have similar interests and services to yourself in order to make decisions about products and services we provide
  6. Who Advisa may share your personal information with

    At Advisa, we work alongside many other providers to ensure our clients get the best services possible. It is for this reason, with your consent, that we may share your personal details with third parties (please see reason outlined Section 4).

    These third parties include:

    1. Your financial adviser or employer
    2. Companies that Advisa have selected to support us in our services and products that we provide, to you and other clients. For example; research, consultancy or technology companies such as – our internet service provider
    3. Our Supervisory Authority and Regulators such as; the Jersey Financial Services Commission (JFSC) and the Office of Information Commissioner in Jersey (OIC)
    4. Credit and identity check agencies for the detection and prevention of crime
    5. Law Enforcement
    6. The State of Jersey Income Tax Office – this would be necessary for the prevention of tax avoidance or for the processing of tax relief on pension payments

    Advisa will never sell your details to any other entity. Your personal information safety and security is our obligation to you and other clients. If your personal data is shared, please be assured that it will fully comply with data protection regulations such as GDPR 2018 (EU) and Data Protection (Jersey) Law 2018.

  7. Where your personal information is processed
  8. The majority, if not all, your personal information is processed only in the following countries:

    Jersey, Guernsey (Channel Islands), Isle of Man, and the European Economic Area (EEA)

    When your personal data is being processed outside of the EEA, we take extra care and added security steps to ensure that your personal information is protected to at least an equivalent level, as would be applied by Jersey / EEA data privacy legislation. This may mean we will implement additional legal agreements with that third-party supplier and carry out regular checks to ensure that they are meeting these obligations.

  9. How Advisa protects your personal information
  10. Advisa takes the security of our clients’ personal information very seriously and we always strive to comply with and fulfil our obligations to you. Any recorded, collected or used personal information whether it is a hard copy document, electronic (online) or any other media, please be assured that it has the appropriate safeguards and security measures in place to protect it. These safety measures and safeguards are applied in line with our General Data Protection Regulations 2018 (GDPR) obligations (EU and Jersey).

    In order to minimise loss or damage through negligent, accidental or deliberate actions of our clients’ personal data, our controls are designed to protect them. In addition to this, Advisa employees/representatives are required to undertake annual training. This is to ensure that they have a full understanding of how to successfully protect sensitive or confidential personal data once it is stored or when transmitting personal information electronically.

    Advisa is well adapted and capable of effectively managing risks to the confidentiality, integrity and availability of your personal information, in a controlled environment. These security controls are the equivalent of industry standards and good practice

  11. How long Advisa keeps your personal information
  12. At Advisa we will keep your personal information only where it is necessary to provide you with our products or services while you are a client.

    We may also keep your personal information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

  13. Your individual rights

    You have a number of rights in relation to how Advisa uses or processes your information. Advisa as an organisation will ensure that we provide the mechanisms to allow our clients to exercise these rights where possible. These rights also include and still apply to clients that we see occasionally or have done so as a one off meeting, who may have ongoing products through Advisa. Advisa will still hold your personal data in order to comply with our regulatory requirements and Advisa’s retention policy. They are as follows:


    1. Right to information
    2. This is your right to receive clear and easily understandable information on what personal information we have, why and who we share it with – we do this in our Privacy Policy.

    3. Right of access
    4. This is your right of access to your personal information after we have collected it. If you wish to receive a copy of your personal information Advisa may hold on you, you may make a data subject access request (DSAR). Advisa will aim to respond within the GDPR time frame of one month. If this is not possible, we will be in contact to inform you that it may take longer, as is our right under GDPR legislation.

    5. Right to rectification
    6. This is your right to rectify any personal data Advisa may have collected from you. It may be inaccurate, incomplete or outdated etc.

    7. Right to request erasure (right to be forgotten)
    8. This is your right to request to be removed or deleted. This can only be granted if Advisa have no compelling reason or legal obligation to hold it.

    9. Right to restriction of processing
    10. This is your right not to be processed if you do not wish to be. You may ask for Advisa to block or suppress the processing of your information for certain reasons. This means that we are still permitted to hold your information – but only to ensure that we do not use it in the future for those reasons you have outlined.

    11. Right to data portability
    12. This is your right to request a copy of your own personal information held by Advisa, for your own purposes across other services or providers. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.

    13. Right to object
    14. This is your right to object to Advisa processing your personal information where: it is based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

    15. Right to object to automated decision making including profiling

      This is your right to ask Advisa to:

      • Provide you with information about how it processes your personal information
      • Request a human being to intervene as opposed to a computer algorithm, when decisions are made solely by an automated process
      • Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should
  14. How to make a complaint
  15. At Advisa we always aim to collect, use and safeguard our clients’ personal information in compliance with GDPR legislation. If you are not satisfied or believe that Advisa has not adequately handled your information as set out in our Privacy Policy, please contact us and we will do our utmost to make things right. You can either email or telephone us on the following:

    info@advisa.je
    01534 724 241

    Or alternatively, you can find us located at:
    Unity Chambers
    
28 Halkett Place
    
St. Helier
    
Jersey
    
JE2 4WJ

    If you are still unhappy you may make a complaint to our Supervisory Authority. Their details are:

    Telephone: +44 (0)1534 716530
    Email: enquiries@dataci.org

    Address:

    Office of the Information Commissioner

    Brunel House

    Old Street

    St Helier

    Jersey

    JE2 3RG