Date last updated: 29.12.2020
WHO WE ARE
Solace Online (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the General Data Protection Regulation, the Data Protection Act and the Privacy and Electronic Communications Regulations. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data. Your privacy is important to us and we are committed to protecting and safeguarding your data rights.
The registered office for Solace Online Limited is at Level 17 Dashwood House 69 Old Broad Street, London, EC2M 1NA and we are a Company registered in England and Wales under registration number 12172903.
CHANGES TO THE PRIVACY NOTICE
We may update our privacy notice to ensure that we are keeping in line with the data protection legislation. We shall of course notify you if any changes are made.
INFORMATION WE COLLECT AND PROCESS
Solace Online Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our corporate services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than already specified in this notice.
The personal data that we may collect from you is:
Full name including any titles and contact information such as your home and business address, email address and telephone number(s);
Date of birth;
National insurance number;
Tax identification number;
Copies of identification verification – this may include a passport, ID card, nationality card, driving licence, utility bill and bank statements;
Trust deeds including details of beneficiaries, settlor(s), trustee(s) and protector(s) – if applicable;
Education and employment history; and
Financial information– if relevant, this would be included in a source of wealth statement and would detail your salary, details of other income, details of savings, investments, expenditures and bank account information.
HOW WE COLLECT YOUR PERSONAL DATA
This may be collected via the following means:
Directly from you in person or by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
Through any agents, advisers and intermediaries to whom you have provided authorisation to;
From other companies in the group;
When you fill out an online form on the website;
From publicly available sources or from third parties, most commonly where we need to conduct background checks about you; and
Via cookies when you visit the website, data is collected automatically and inline with your cookie settings in your browser. Please review our cookies policy on this website.
WHAT DO WE USE YOUR PERSONAL DATA FOR?
Solace Online Limited takes your privacy very seriously and we are committed to protecting and safeguarding your data privacy rights. We only retain your data for as long as is necessary and for the purposes specified in this notice. If you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.
The purposes and reasons for processing your personal data are detailed below:
Establishing a business relationship with you in order to provide our services and products;
Assessing client take on in accordance with our risk matrix;
Fraud prevention and detection;
Managing the services we provide to you;
To comply with legal and regulatory obligations, requirements and guidance; and
Internal record keeping – we may use the information to improve our products and services
WHAT ARE THE LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION?
We collect your personal data with relation to the performance of a contract to provide you with the services you require.
To comply with our legal obligations to enable us and other companies in our group to make decisions about you and any related person for fraud prevention and anti-money laundering purposes.
Here is a list of the rights that you have under the data protection legislation:
The right to be informed about the processing of your personal information;
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
The right to object to processing of your personal information;
The right to restrict processing of your personal information;
The right to have your personal information erased (the “right to be forgotten”);
The right to request access to your personal information and to obtain information about how we process it;
The right to move, copy or transfer your personal information (“data portability”); and
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request. This is to ensure that your data is protected and kept secure.
SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Solace Online Limited may use a third party to provide the below services and business functions, however all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
In order to competently provide our services to you, we may provide your data to the following third parties:
Other companies within our group;
Our agents and service provider intermediaries;
Any law enforcement agencies in connection with any investigation to help prevent unlawful activity;
Professional consultants to obtain specific advice on areas of expertise which concern your business;
Third parties who assist us in conducting background checks;
Fraud prevention agencies;
Market research organisations who help us to develop and improve our products and services; and
Our data storage and data disposal providers.
IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE THE EEA?
We may need to transfer your personal data to third parties which are located outside the European Economic Area, for the purpose set out in this policy.
Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data, for example:
The country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data and the rights of a data subject;
The transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
You have explicitly consented to the transfer; or
The recipient has entered into European Commission standard contractual clauses with us.
Solace Online Limited takes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
Access to your account is controlled by a password and username that are unique to you;
We store your personal data on secure servers;
Payment details are encrypted using SSL technology;
Physical security of premises, e.g. locked office;
Confidential documents kept in locked cabinets;
Reduced access privileges to only those needed;
Access granted to only such personnel who need to have access in connection with their duties; and
We dispose of confidential documents using a confidential waste disposal company.
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure.
CONSEQUENCES OF NOT PROVIDING YOUR DATA
You are not obligated to provide your personal information to us however, we are unable to provide our services without it. In cases where providing some personal information is optional, we shall make this clear.
HOW LONG WE KEEP YOUR DATA FOR
Solace Online Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under certain legislation to keep your basic personal data (name, address, contact details) for a minimum of five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings. Retention periods are in line with legal and regulatory requirements or guidance.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
LODGING A COMPLAINT
Solace Online Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the ICO.
OUR CONTACT DETAILS
If you have any questions regarding the information provided in this policy, please contact us using the following:
Solace Online Limited
Level 17 Dashwood House
69 Old Broad Street