PRIVACY POLICY

OVERVIEW

Please read this Privacy Policy carefully. It applies to you when you visit killik.com, MyKillik.com and client.killik.com (our sites), use our mobile applications (apps), telephone our branches or open and operate a Killik & Co account. It sets out how we use and protect any information that you give us.

 

We take your privacy very seriously and are committed to ensuring that your privacy is protected. Whenever we ask you to provide us with information about you, be assured that it will only be used in accordance with this Privacy Policy. We do not share data with other organisations unless the law permits us to do so. We do not sell individuals’ information.

For the purpose of this Privacy Policy and the General Data Protection Regulation (GDPR), Killik & Co (we and us) of 46 Grosvenor Street,  London  W1K  3HN  is  a  ‘data  controller’. We are registered with the Information Commissioner under registration  number  Z5711970.  Our  Data  Protection  Officer can be contacted at: [email protected].

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.

WHAT WE COLLECT |
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 Site or App. 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 document.

When you telephone us, calls are recorded and your phone number will be searchable within our call recording system.

Correspondence with you will be stored in our prospect/customer database.

USES MADE OF THE INFORMATION

We must have a good reason, known as a “lawful basis” to use your information. The table on page 3 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 transfers
  • Monitoring our services for regulatory compliance,
  • customer satisfaction and complaints and future business strategy. See also Appendix 1 – Cookie Policy.

    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

    Carefully selected third parties necessary in providing the services, e.g. ID verification services, payment services, bank account aggregation services etc.

    Analytics Services

    Services that assist with optimisation of our Site or App and help us to understand how visitors use/navigate our Site or App.

    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 asset).

    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 and payment transactions will be encrypted using SSL technology. Where you use Intelligent Siloing and provide us with your bank login details, these are stored encrypted. Where you have chosen a PIN which enables you to access our Site or App, you are responsible for keeping the 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

    We will retain your personal data for the duration of our contract with you and for a reasonable period of time afterwards. We are bound by financial regulation to keep our records for set periods of time and will also wish to retain enough information where we have a legitimate interest in doing so.

    LINKS TO OTHER
    WEBSITES

    Our Site may contain links to other sites of interest. However, once you have used these links to leave our sites, you should note that we do not have any control over those other sites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting other sites and such other sites are not covered by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the sites in question.

    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.

    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 any information 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.

    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 123 113

    See also Appendix 1 for details on how you can manage the way that Cookies use and store information about you.

    UPDATES TO THIS
    PRIVACY POLICY

    We may change this policy from time to time by updating this page. You should check this page periodically for any changes.

    CONFLICTS OF
    INTEREST POLICY

    If you wish to read our conflicts of interest policy, you can find it here

    APPENDIX 1 - HOW WE
    USE COOKIES

    Killik & Co (“us”, “we”, or “our”) uses cookies and similar tracking technology on killik.com and all our websites and online services.

    Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on our site, your choices regarding cookies and further information about cookies. The information set out in this policy is provided in addition to our privacy policy and should be read alongside our privacy policy.

    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 third-parties to recognize you and make your next visit easier and the experience more useful to you. Cookies can be “persistent” or “session” cookies.

    how we use cookies

    On our sites, we use cookies that are essential to make them work or to identify which pages are being used. This helps us analyse data about web page traffic and improve our sites in order to tailor them to customer needs generally. We may also be able to identify individual users of the sites, if for example your details are stored within our database. Where this is the case, we may use the data about which areas of our sites you have visited, to analyse trends and tailor our communications to you.

    We use cookies with selected third party publishers 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 websites.

    When we send you an email that contains a link to our site or app, we may use cookies to tell us if you click on the link. This is intended to help us to direct other information to you that you may find of interest or may prompt us to contact you.

    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.

    Non-Necessary:
    ANALY TICAL | 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

    You can manage the use of cookies, including advertising cookies, and disable the sharing of data with partners for advertising purposes, by using the steps set out here. 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.

    Killik.com cookies

    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.