Privacy Policy

LFP Limited trading as LFP Asset Management –
PRIVACY POLICY

LFP Limited takes the privacy and security of your personal information very seriously, and we’re committed to protecting and respecting your privacy.
Our Privacy Policy explains which personal information we collect from you, how we store it and use it. It also covers how we treat information you give to us, and information we take from third parties. It contains important information about your rights. Please read the policy carefully so that you understand how we treat your personal information. By using our services, you confirm that you have read and understood the entirety of this Policy, as it applies to you.
If there are any parts of our Privacy Policy that you do not understand, it is important that you contact us for further information before using our services.

Who we are

LFP Limited is registered in England and Wales registered number: 4732588.
We are authorised and regulated by the Financial Conduct Authority and our registered number is 225099.
Our registered offices are at: Merchants House, 70 Mutley Plain, Plymouth PL4 6LF.
Our full contact details can be found at the end of this Policy.

Collecting your information

As part of our fact-finding process, we collect detailed information from you including (but not restricted to):
  • Your name, address and contact details
  • Your assets and liabilities including your investments and pensions
  • Your income and expenditure
  • Details of your will
  • Bank account details
  • Any other data that we deem relevant in order to provide you with financial advice and to meet our obligations under Financial Conduct Authority, or other regulatory body rules.
Some of the personal information that we collect about you or which you provide to us about you or your family members may be special categories of data. Special categories of data include information about your physical and mental health. We take special care with this data.

How we use your information

We use your personal information in the following ways:
  • To improve the quality of our services.
  • To let you know about any changes we make to our service.
  • To tell you (by mail, email, telephone or otherwise) about products and services we think you could be interested in, based on services or products you already have or have shown an interest in. You can opt out of this communication at any time.
  • To confirm your identity and address, which includes using automated decisions when we carry out financial crime checks.
  • To request your feedback on a product or service.
  • Gathering data for analysis and research, and to provide management information or other services internally.
  • To monitor, record, store and use any telephone, email or other communication with you. We’ll update your records with any new information you or a third party give us, and we’ll add it to any information we already have.
  • To deal with any enquiries or issues you have about how we collect, store and use your information, or any requests made by you for a copy of the information we hold about you.
  • For internal reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities and to identify and implement business efficiencies.
  • To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
  • To get quotations or arrange investments or insurance for you with regulated entities.
  • If you apply for an account with us for someone else, acting with power of attorney, we’ll use the information you give us about the applicant (including information about the applicant’s mental health) and your role as the attorney to provide the product or service you request.
  • To comply with our legal and regulatory obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime.
  • If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
  • To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.

Information security

We take the security of your personal data very seriously, and we use appropriate technologies and procedures to protect your personal information.
We keep our data security policies and procedures up to widely accepted international standards. In addition, we review our policies regularly and update them whenever needed to protect you, and to meet our business needs, changes in technology, and regulatory requirements.
Here are examples of the ways we protect your data:
  • We have appropriate technical and organisational measures in place to protect you against accidental loss and unauthorised access, use, destruction or disclosure of your data.
  • We have a business continuity and disaster recovery plan that is designed to help us offer our services and protect our people and assets no matter what happens.
  • We place appropriate restrictions on access to personal information.
  • We implement measures and controls, including monitoring and physical measures, to store and transfer data securely.

Our legal basis for using your information

Our legal basis for collecting and using your personal information depends on the exact type of information and how and when we collect it. However, we’ll normally only collect personal information from you where one of the following applies:
  1. We need your personal information to perform a contract with you.
  2. It is in our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
  • Run, grow and develop our business
  • Marketing and business development
  • Provide client services
  • We have your consent
  • We may use your special categories of data (such as health information) where you have provided your consent (which you may withdraw at any time after giving it, as described below).
  • We may also process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us and we will stop doing so.
  • We have a legal obligation to collect your personal information (such as for H.M.R.C. reporting).
When we collect personal information to comply with a legal requirement or to enter into a contract with you, we’ll let you know at that time. We’ll also tell you if providing your personal information is mandatory or not, and what the consequences would be if you don’t provide it.

How and when we share your information

  • To help us to better understand your needs, run your accounts and improve our services.
  • Contact you to tell you about the products and services we provide and think you could be interested in.

We will also disclose your information to third parties:

  • Where it is in our legitimate interests to do so to run, grow and develop our business.
  • If we sell or buy our business, we may disclose your personal information to the prospective buyer of our business.
  • If we are under a duty to disclose or share your personal information: in order to comply with any legal obligation, any lawful request from government, judicial bodies or agencies to make sure we comply with our legal and regulatory obligations; with law enforcement officials; and as may be required to meet national security or law enforcement requirements or prevent illegal activity; to work with fraud prevention agencies, other companies and organisations to prevent or detect financial and other crime.
  • In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.
  • To protect our rights, property, or safety and that of our staff, our clients or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
When we share your information with third parties, we make sure the appropriate safeguards are in place to protect your personal information.
We will never sell, trade, or rent your personal information to anyone.

How long we store your personal information

We keep the personal information we collect from you, and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
We keep all records indefinitely, from when you stop being a client with us. We can use it to respond to any questions or complaints, to maintain records according to rules that apply to us, or for fighting financial crime, including fraud.
When we have no ongoing legitimate business need to hold your personal information, we will delete it. If we can’t do this (for example, because your personal information is stored in backup archives), we’ll securely store your personal information, only use it for a purpose we’ve already communicated to you.
Where we process information on behalf of other organisations we apply the same procedure.

Marketing

We may collect and use your personal information for undertaking marketing by email, telephone and post.
We may send you certain direct marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.
However, we will always obtain your consent to direct marketing communications where we are required to do so by law.
You have the right to ask us not to process your personal information for marketing purposes. You can do this by contacting us by post or email. You can also unsubscribe from emails by following the unsubscribe instructions included in every email.

Your rights

  • Right of access: You have the right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area.
  • Right of to update your information: If any of the information we hold is inaccurate, you can ask us to make any necessary amendments.

Complaints

If you have any complaints or concerns about our handling of your personal information, please get in touch with us and we will do our best to resolve these.
In accordance with Article 77 of the General Data Protection Regulation, you have the right to complain about our collection and use of your personal information to the Information Commissioner’s Office or the data protection authority in the country where you usually live or work, or where the alleged infringement of the General Data Protection Regulation has taken place. For more information, please contact the data protection authority at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by phone on 0303 123 1113.
You may also seek a remedy through local courts if you believe your rights have been breached.
In certain specific circumstances you also have following further rights:
  • Right of deletion: You have a right to ask us to delete any personal information which we are holding about you.
  • Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information.
  • Right to data portability: You have a right to ask us to provide your personal information to a third-party provider of services.
  • Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
  • Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request, unless we tell you we are entitled to a longer period required by applicable law).
Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request.
We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Your rights to object

You have various rights in respect of our use of your personal information. Two of the fundamental rights to be aware of are that you may:
  • Ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  • Ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.

Updating the privacy policy

We will update or amend this Policy from time to time, to comply with law or to meet our changing business requirements. You should bookmark and periodically review this page to make sure that you are familiar with the most current version and so you’re aware of the information we collect, how we use it and under what circumstances we disclose it.
You can see when our most recent update to this Privacy Policy was by checking the “Last updated” note at the top of this Privacy Policy. If we need to make substantial changes to this Policy, we will notify you, if we hold your contact details, by post or by email, before we make any changes unless we are required to make the change sooner (for example regulatory reasons).

Contacting us

If you have any questions about your privacy with us or this Policy, our contact details are as follows :
Telephone:      01752 603232
By e-mail:        info@lfpassetmanagement.com
In writing:       LFP Limited, Merchants House, 70 Mutley Plain, Plymouth PL4 6LF