Brian Dennehy (T/A FundExpert) is committed to protecting your personal information.
Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.
We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know.
This version of our Privacy Policy was last updated 25 May 2018.
Who we are
FundExpert is an Appointed Representative of Dennehy Weller & Co. Registered Office: 303 High Street, Chislehurst, Kent, BR6 0NN
This Privacy Policy applies to www.cluelessthebook.co.uk
How to contact us
If you have any questions about our Privacy Policy or the information we collect or use about you, please contact;
FundExpert
3 High Street
Chislehurst
Kent
BR7 5AB
Email: support@fundexpert.co.uk using the subject line “Privacy Policy”
Information we collect and use
Information about you that we collect and use includes:
- Information about who you are e.g. your name, date of birth and contact details
- Information about your contact with us e.g. emails, letters
- Information that is automatically collected e.g. via cookies when you visit one of our websites
You may visit the website without revealing any information about yourself.
Where we request specific information (e.g. if you decide to register), we will always respect the personal information you send us. We strictly follow the principles set out in the Data Protection Act 1998 and we take all reasonable steps to ensure your personal data is protected against unauthorised access. We will not request information unless it is necessary and will ensure appropriate measures are taken to keep information accurate, up-to-date and to prevent disclosure.
Who we may share your information with
We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.
These third parties may include:
- Website management systems or customer relationship management systems for the purposes of providing our service to you
- The Information Commissioner’s Office for the UK (the ICO)
- Law enforcement, credit and identity check agencies for the prevention and detection of crime
- HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
The information we collect from you will never be sold to any other companies.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
- you have given us your permission [consent] to send you information about products and services offered by FundExpert
- it’s necessary to provide the product or service you have requested
- it’s necessary for us to meet our legal or regulatory obligations e.g. tell you about changes to Terms and Conditions or for the detection and prevention of fraud
- it’s in the legitimate interests of FundExpert e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome; where we need to process your information to better understand you and your needs so we can send you more relevant communications and to develop new products and services
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.
We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the information that you receive. We use automated decisions in the following ways:
- When designing and enhancing our online services to help meet your requirements
- When contacting you about information relevant to your interests
We use software to monitor what parts of this website customers visit so that we can continue to improve the service that we provide. This does not store any data about you personally.
We will only keep your information for as long as is necessary for the provision of the relevant services to you and for the purposes of compliance with our obligations in respect of tax and good practice as regards the keeping of business records.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States and India.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
Your individual rights
You have several rights in relation to how FundExpert uses your information. They are:
Right to be informed
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy.
Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for FundExpert to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. 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.
Right to object
You can object to FundExpert processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
Rights related to automatic decision making including profiling
You have the right to ask FundExpert to:
- give you information about how we process your personal information
- request human intervention or challenge a decision where processing is done solely by automated processes
- carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact us using the details shown above under “Contact Us”.
If you are still unhappy, you can complain to our Supervisory Authority using the process laid out on their website (https://ico.org.uk/concerns/)
What are cookies?
A cookie is a small file – it’s saved onto your computer or other device when you visit our website.
Cookies store small pieces of information. For example – they will remember you’ve visited our website or performed a certain action.
We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don’t have to keep entering it.
Cookies also let us know which pages of our website you visited; they help us develop and market our products and services. They also help us track sales.
- Persistent cookies – these stay valid, and will work until their expiry date (unless you delete them before they expire)
- Session cookies – these expire when you close your web browser
FundExpert uses cookies in a general way to help us to understand how our website is used and also to improve the user experience. With the exception of storing your login email in a cookie to enable you to login more easily next time we do not use data from which you can be individually identified.
Our website occasionally makes use of “embedded services” such as YouTube, Twitter, Facebook, AddThis and Google Maps. These third party services may also save cookies on your computer whilst you use our website. We have no control over these cookies and you should seek advice from these services if you wish to understand more about how they use cookies.
You may wish to visit www.aboutcookies.org which contains comprehensive information on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
The table below sets out what cookies we use and why:
| Cookie | Brief description |
| __atuvc | The __atuvc cookie is created and read by the AddThis social sharing site JavaScript on the client side in order to make sure the user sees the updated count if they share a page and return to it before our share count cache is updated. No data from that cookie is sent back to AddThis and removing it when disabling cookies would cause unexpected behavior for users. |
| __utma | Google Analytics |
| __utmb | Google Analytics |
| __utmc | Google Analytics |
| __utmz | Google Analytics |
| ASP.NET_SessionId | ASP session cookie – deleted when you end your visitor session |
| ii_Globalisation | System setting – contains no personally identifiable information |