Chartwell Financial Planners Limited are licensed by the Isle of Man Financial
Services Authority in the Isle of Man and is the controller for all personal data
processed and any information that you provide to us. We are committed to
protecting the privacy and security of your personal information in accordance with the
Data Protection Act 2018.

This Privacy Notice covers:

• How and why we process your personal information.
• The sources of information about you.
• The parties we may disclose it to.
• How long we will retain your information.
• What rights you have in respect of your personal data; and
• How you can contact us with any further queries or concerns.

What information we will collect?

We will collect personal information about you to provide financial planning and
financial advice related services that you have requested and for quotes for our
services.

We collect it from you when you initially provide it to us, every time you contact us
during the administration of your relationship with us, and from additional sources
such as background checks and/or references. Information is collected when you
meet with us, complete forms, correspond with us, telephone us, or send us an email.

We may also get your personal information from an intermediary such as for
example, a previous financial advisor.

This will be in relation to your personal and financial circumstances and may include
all, or a combination of any of the items listed below:

• General personal details including your name, date of birth, place of birth, nationality, gender, marital status.
• Your contact details (address, telephone numbers, e-mail).
• Employment details such as employment status, employer contact details, and benefits and salary information.
• Information about previous investments and accounts you may have had relevant to your current requirements.
• Financial details such as bank account details and/or tax information.
• Publicly available information (generally obtained through internet searches) such as news articles or public register information which is obtained from background searches or reference checks.

Sensitive Information

Certain types of personal information are classed as “sensitive” under the Data
Protection legislation, or otherwise referred to as “special categories” of data. This
includes information about your health, race, ethnic origin, political opinions,
religious or philosophical beliefs, sexual orientation, trade union membership and
genetic and biometric data.

We may collect data under special categories, such as information in relation to
your health that may be necessary for the provision of our services.

If this involves the collection of information about other members of your family,
please note that it will be your responsibility to ensure that you have their permission
to provide this information so that we can process this. You will need to ensure that
they know who we are and how this information is used (as detailed within this
Privacy Notice).

Why we use this information and who we may share this with?

We will process data to allow us to meet regulatory and legal obligations for
providing you with financial planning and financial advice related services, so that
we can carry out services effectively and perform our contract with you.

We will also process data to conduct administrative or operational processes within
our business, respond to requests, enquiries or complaints received, communicate
with you about our products and services including for instance newsletters, as well
as for staff administration purposes and to monitor and analyse our business.

This may include sharing this information to third parties who provide professional
compliance, accountancy, and legal services and furthermore, to verify your
identity and undertake due diligence. In most cases, we will not disclose data
without your prior knowledge. Information may however need to be shared in
response to a request from law enforcement/ regulatory authorities or in relation to
any legal/ regulatory obligations that we may have, to exercise or defend legal
rights or when any personal data breaches are recorded.

We will always ensure that the amount of information that we collect, and the
extent of processing activities does not go beyond what is required.

We do not engage in marketing activities.

How long do we hold information for?

We are required to hold data for periods of time, and this is subject to legal, tax and
regulatory requirements. We will not however retain data for longer than six years
after the termination of our relationship with you unless where regulatory or law
enforcement requirements state the need for us to retain data longer or indefinitely,
such as in relation to pension transfers or the duration of a life policy.

If you have been entered Terms of Business with us, but not proceeded with any
recommended business, we will your account as Not Taken Up business and retain
your personal information for a maximum of 12 months from the date we received it,
unless you give us permission to retain it for longer.

Once your information is no longer necessary in accordance with the above, it shall
be destroyed in line with Data Protection legislation.

Your data protection rights

• To access your data upon request, unless, and to the extent necessary, that the right of access is restricted.
• To have your data corrected if inaccurate or incomplete.
• Subject to statutory limitations to object to processing, to the erasure or restriction of processing, and to data portability.
• To claim compensation for damages caused by a breach of data protection legislation by Chartwell Financial Planners Limited.

Please note, no automated decisions or profiling are undertaken by Chartwell
Financial Planners Limited, and we do not engage in marketing activities.

Cookies

We may use cookies on our website to track the use by visitors and review activities.
If you wish to do so, you can set your browser not to accept cookies, but you may
be unable to use all our website if you do this.

Cookies are text files which identify users to our server. Our cookies do not store any
personal or sensitive information, or anything that makes you personally identifiable
to us. They are used for essential functionality such as security when processing form
data or for analytics which helps us use anonymous visitor data to gain a better
understanding of how people use our website.

IP address

When you visit our website, our server will record your IP address with the date, time,
and duration of your visit. This allows us to identify which organisations have visited
this website and statistical information may be compiled to track how users navigate
the site to allow us to evaluate and improve our site.

Security

Up to date storage and security techniques are used to protect your personal data
from unauthorised access, improper use or disclosure, unauthorised modification or
unlawful destruction or accidental loss. All our employees and any third parties that
may be engaged to process your personal information are obliged to respect the
confidentiality of your information.

Please note however, the transmission of information via the internet, email and post
is not completely secure. Although we will do our best to try and protect your
information, we cannot guarantee the security of your information and any
transmission is at your own risk.

How can you access information held about you?

You have a right to apply for a copy of information that we hold, and this is called a
data subject access request. We may require additional information to identify you
or the information you seek and would not normally charge a fee unless this
information has already been supplied and this is manifestly unfounded or excessive.

Should you wish to exercise any of your rights, or have any questions, this should be directed by email at emma@chartwell.co.im or write to us at The Data Protection Officer, Chartwell Financial Planners Limited, 17 Springfield Rise, Foxdale, Isle of Man, IM4 3JX.

If you are unhappy with how your personal data is collected or used, please bring
your concern to our attention.

You have a right to lodge a complaint with the IOM Information Commissioner, PO
Box 69, Douglas, Isle of Man, IM99 1EQ. Telephone number 01624 693260. Email
ask@inforights.im and to seek compensation through the courts.