What we Collect
INFORMATION YOU GIVE US
If you express an interest in us and our services, we may ask you for basic contact information such as your name, email address, telephone number, postal address. We may ask you some questions about your circumstances and the nature of your enquiry, to improve our response. We may also survey visitors of our website or individual pages for the purpose of research to understand more about their needs and use of the site to improve user experience.
When you apply for an account with us we shall ask you for information that will include: your name; contact information including email address, mobile phone number, and address; National Insurance Number; bank account details; information about your financial situation including income, expenditure and spending patterns; and copies of personal identification documents (such as your passport or driving licence).
Before you submit any information, we will notify you as to why we are asking for it and it is up to you whether or not you provide it. The majority of the information is necessary for us to be able to provide our services and/or fulfil our legal obligations and we won’t be able to open or maintain an account for you if you choose not to provide it.
INFORMATION WE COLLECT ABOUT YOU
We collect information from you about the computers, phones or other devices you use where you install or access our sites or apps. We may use this information to help us provide consistent experience across your devices. Here are some examples of the information that we collect:
- Device attributes such as the operating system, hardware version and geographic location based on your internet service provider
- Connection information such as the name of your mobile operator or internet service provider, browser type, language and time zone
- Behaviour such as viewing a specific page, opening a statement or downloading a research note
- Information about what websites or social media platforms you found us on, how you navigated to us, as well as information those sites hold about you and the interactions you complete on our site
Information that allows us to recognise you as a returning user or client, who has access to one of our online account logins, associated to a different device or browsing session associated to your same IP address
Uses made of the Information
We must have a good reason, known as a “lawful basis” to use your information. The table below explains more about the type of information we collect, how we use it and why, and the lawful basis for doing so.
Where the stated lawful basis for processing your data is “our legitimate interests,” this may be for the purpose of:
- Keeping in contact with you if you have expressed an interest in our services
- Marketing other services to current clients and sharing other relevant content or better browsing experience of our website
- Marketing services to people who look or behave similar to our existing clients
- Prevention of fraud and financial crime
- Ensuring network and information security
- Inter-group transfer
- Monitoring our services for regulatory compliance, customer satisfaction and complaints and future business strategy.
In our Silo service and as detailed in the table below, we use some of your information to reach an automated decision about which of our investment strategies is suitable for you. The automated decision is based on a numerical score that attaches to certain information you have provided and the answers given to a series of questions about risk. The automated decision making process has been carefully designed to choose a suitable investment strategy. We also carry out regular reviews of the results of the automated decision-making to ensure it is working correctly. If you have queries or concerns about the investment strategy that has been selected for you, please contact [email protected]
Disclosure of your Information
You Agree that we have the Right to Share your Personal information WITH:
GROUP COMPANIES | Killik & Co LLP, Killik & Co Trustees Limited, Killik Intelligent Savings Limited.
DATA PROCESSORS & BUSINESS PARTNERS | Carefully selected third parties necessary in providing the services, e.g. custodian, print services, ID verification services etc.
ANALYTICS SERVICES | Services that assist with optimisation of our sites and helping us to understand how visitors use/ navigate our sites.
THIRD PARTY PLATFORMS | Carefully selected third party publisher websites, social media platforms and advertising platforms where we advertise our services or free content to attract new customers, using third party cookies or data to understand and improve where and how people are engaging with our adverts/content both off and on our website.
BUSINESS ACQUIRER | Prospective or actual acquirer of some or all of our business in the event that any part of our business were to be sold (information about clients and prospects will be a business event).
AUTHORITIES | To comply with legal obligations; to enforce our legal agreements; to protect our rights, property or safety and that of our clients and others. This could include exchanging information with other companies for fraud prevention purposes.
Security and Where we Store your Personal Data
We are committed to ensuring that your information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place strict procedures and security features around the app, our sites and our internal systems and databases. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password or PIN which enables you to access certain parts of our sites, you are responsible for keeping the password or PIN confidential. We ask you not to share your login details with anyone.
You should remember that transmission of information via the internet is not completely secure. We may use encryption as way of protecting attachments to emails that may contain your personal information. However, we cannot guarantee the security of information that you transmit to us via our sites or by email. Any transmission is at your own risk.
Data provided to third party partners such as online platforms, will be aggregated (groups of people rather than individuals) and either anonymised (removing personally identifiable information for privacy protection) or pseudonymised (a data management process where personal information is de-identified by replacing it with artificial identifiers or pseudonyms again for privacy purposes). We may also use third party cookies, which are managed by partners and governed by your interactions and consents with those individual third parties as well as our own website.
Before we share your information with any Data Processors or Business Partners we make sure that they have appropriate technical and organisational security measures in place to keep your information safe and that they have undertaken to comply with data protection law and regulations. Typically, the data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. If for any reason we need to transfer and store your data outside the EEA, we will do so only where we have assessed that equivalent data protection measures are in place. By providing us with your personal information, you agree to this transfer, storing or processing.
How long we keep your Personal Data
Links to Other Websites
Controlling your Personal Information
You may Choose to Restrict the Collection or use of your Personal Information in the Following ways:
CONSENT | If you have previously agreed to us using your personal information for our own marketing purposes, you may change your mind and withdraw this consent at any time. You may also view and adjust your cookie settings on our website.
ACCESS | You may request details of the personal information which we hold about you. We must provide this to you free of charge within 30 calendar days of your request.
CORRECTION | If you believe that any information we are holding about you is incorrect or incomplete, please tell us as soon as possible. We will promptly correct anything found to be incorrect.
OBJECTION, RESTRICTION OR DELETION | You may have the right to object to the way in which we process your data, you may ask us to restrict the processing of your data, or you may ask us to delete it. You may also view and adjust your cookie settings on our website.
Please direct all enquiries concerning your control over your personal information to [email protected].
The supervisory authority for data protection in the UK is the Information Commissioners Office. You have the right to complain to them about the way in which we process your data and their helpline number is 0303 123 1113.
See also Appendix 1 for details on how you can manage the way that cookies use and store information about you
We may change this policy from time to time by updating this page. You should check this page periodically for any changes.
Uses made of the Information -table
What are cookies
Cookies are small pieces of text sent from your web browser, by websites that you visit. A cookie file is stored in your web browser on your computer or mobile device. They are widely used to gather information in order to make websites work, or work more efficiently, as well as to provide web services and functionality for users. They allow us or thirdparties to recognize you and make your next visit easier and the experience more useful to you. Cookies can be “persistent” or “session” cookies.
Overall, cookies help us provide better website experience, by enabling us to monitor which pages visitors find useful and. which they do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us or with third party websites or about your journey through the websites.
Types of cookies we use
We use several types of cookies, which we describe in this section.
NECESSARY | cookies that are essential to provide you with the digital services you are trying to access or have requested. This might include basic functionalities and security features. If you set your browser to block these cookies, then certain functions may not work for you.
ANALYTICAL | cookies which measure how often you visit our sites and how you use them. We use this information to get a better sense of how our users engage with our website, content and services to improve them and so that users have
a better experience. For example, we collect data on which pages are most frequently visited, and by which types of users. We also use third party cookies to help with performance. For example the Google Analytics cookie gives us information
such as your journey between pages and whether you have download anything (details of how to opt out are below).
FUNCTIONAL | cookies that are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience. A mix of first and third party cookies may be used.
SOCIAL MEDIA & ADVERTISING | cookies that are used to collect information about your visit to our site, the content you viewed, the links you have followed and the information about your browser, device and your IP address. This helps us to understand what and where our advertising is most relevant and can be used to help us tailor these advertisements or to find other potential customers.
How to manage cookies
By clicking the cookie settings link in the footer of our website you can adjust the settings for the cookies that we control on our website. There are some third-party cookies that we cannot control, for example if you chose to share an article via a social media buttons. You can usually still adjust these cookies but not through us.
You can see a list of all cookies used here, as well as the type, duration and purpose. Please note, this list changes from time to time and any updates will be made to this document available online.
We are unable to disable cookies within our Client Login services (MyKillik and Client Portal) and by using these services you accept that cookies will be placed on your computer.
Client log in cookies
Information can usually be found in your web browser’s help section or on this page.