Privacy Notice

INTRODUCTION

LIA Wealth Advisers Limited ("LIA Wealth Advisers", "we", "us"), registered at Floor 27, 52 Lime Street, London, United Kingdom, EC3M 7AF,  is authorised and regulated by the Financial Conduct Authority ("FCA") to carry out insurance distribution activities. LIA Wealth Advisers is registered with the Companies House number 11732755 and is listed on the Financial Services Register under the number 829788.

LIA Wealth Advisers is acting as data controller in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.
This Privacy Notice provides information about how we collect and use personal data and explains your statutory rights.

WHAT PERSONAL DATA DO WE COLLECT?

In order to provide you with our products and services, we collect information about you and related parties (“Personal Data”). This may include:

  • identification data such as full name, social security number, ID or passport and tax identification number
  • contact data such as correspondence address, email and phone numbers
  • financial data such as assets & liabilities, source and details of wealth, transactions data, existing life assurance plans and insurance premiums
  • personal characteristics such as age, gender, marital status, language
  • personal data relevant to the assessment of risk such as financial objectives, attitude to and understanding of investment risk and return, investment profile and past criminal convictions
  • Professional data related to activity and occupation

The level and type of personal data we collect and use varies depending on the products and services requested and may include information on other individuals who need to be considered as part of the product/service.

In some instances, it is necessary for us to collect and use information about health or past criminal convictions ("Special Categories of Personal Data").  We are required to establish a legal exemption to use your Special Categories of Personal Data - see 'WHY DO WE COLLECT PERSONAL DATA?’ section below for further details.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

 
Purpose for processing Type of information collected The basis on which we use the information
Set up a record on our systems
  • Contact details
  • Personal risk information
  • Product/Service information
  • Performance of a contract
  • Legitimate interests (to ensure we have an accurate record of all clients we provide products and services to)
Carry out background, sanction, fraud and credit checks/monitor or detect fraud
  • Contact details
  • Personal risk information
  • Criminal data
  • Financial information
  • Conditional consent
  • Legitimate interests (to ensure that clients are within our acceptable risk profile and to assist with the prevention of crime and fraud)
  • Legal obligation
Provide product or service
  • Contact details
  • Personal risk information
  • Health data
  • Criminal data
  • Financial information
  • Take steps to enter into a contract
  • Legitimate interests (to determine the likely risk profile and appropriate level, cost and type of product/service)
  • Explicit consent
  • Local law exemptions
Provide client care, assistance and support
  • Contact details
  • Product or service information
  • Performance of a contract
  • Conditional consent
Comply with legal and regulatory obligations
  • Contact details
  • Product/service information
  • Personal risk information
  • Financial information
  • Legal obligation
Manage relationships
  • Contact Details
  • Legitimate interests (to maintain an accurate client and partner relationship management)
  • Consent
Administer contracts
  • Contact Details
  • Performance of a contract
Sale or reorganisation of the company
  • All
  • Legitimate interests (to structure our business appropriately)
 


We may ask for your written consent before processing personal data for a purpose other than those listed above or to offer you real choice and control over your personal data. If you have given your consent for the processing of your personal data for a specific purpose, you have the right to withdraw this consent at any time, without affecting the lawfulness of the processing based on consent before withdrawal.

WHO HAS ACCESS TO YOUR PERSONAL DATA?
Your personal data is available on a need to know basis within LIA Wealth Advisers Limited, and can only be accessed by the employees of the relevant internal departments to the extent necessary to fulfil their respective tasks and responsibilities. Our employees process your personal data in accordance with our policies and procedures to ensure an adequate level of security.
We may make your personal data available by any means to third parties that may require access to them, including, service providers, legal advisers, auditors, delegates, any other subsidiary or affiliated company that is part of the group of companies of each of LIA Wealth Advisers and the other recipients of the personal data, public administrations and local or foreign public and judicial authorities, including any competent regulator. 
LIA Wealth Advisers uses service providers, notably located in Luxembourg, , to comply with anti-money laundering and KYC obligations and may provide certain information and personal data of the Policyholder, the Life Assured and/or the Beneficiary to them.
Depending on the product, LIA Wealth Advisers will communicate data to insurers, notably located in Luxembourg, Guernsey and Bermuda, as appropriate, to issue insurance policies.
If we were to sell part of our businesses we would need to transfer your personal data to the purchaser of such businesses.

TRANSFER OF PERSONAL DATA OUTSIDE THE EEA

Processing of personal data may include transfers outside the UK or the EEA, to countries that may not have data protection requirements deemed equivalent to those prevailing in the UK or the EEA. In such cases, we will strictly comply with chapter V of the UK GDPR and Section 17 of the Data Protection Act 2018 and provide appropriate safeguards through contractual clauses between the Insurer and the recipient located outside the UK or the EEA or ask for your consent. 

HOW CAN YOU EXERCISE YOUR DATA PROTECTION RIGHTS?

You have a number of rights in relation to your personal data.

  • Your right of access: You have the right to ask us for copies of your personal data.
  • Your right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. We may seek to verify the accuracy of the data before rectifying it.  
  • Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances. 
  • Your right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
  • Your right to object to processing: You have the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.


You also have a right to request information in relation to any automated decision making and profiling or the basis for international transfers.

You can submit your written request to Us via the following email address: LWAdataprivacy@lombardinternational.com and/ or by post mail at LIA Wealth Advisers Limited, Floor 27, 52 Lime Street, London, United Kingdom, EC3M 7AF.

We will respond without delay and within one month of receipt of your request.
We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, repetitive or excessive, in which case we may charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
Finally, you have a right to lodge a complaint with the United Kingdom supervisory authority, the Information Commissioner’s Office (the “ICO”), whose contact details are available at the following address: https://ico.org.uk/global/privacy-notice/how-you-can-contact-us/ or with the respective supervisory authority in your country of habitual residence, place of work or with the competent supervisory authority of the country in which an alleged data protection infringement occurred.

HOW WE PROTECT AND STORE YOUR INFORMATIO

Protecting your privacy is very important to us.
LIA Wealth Advisers has taken adequate safeguards to ensure the confidentiality and security of your personal data by implementing appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing or further processing. 
LIA Wealth Advisers Limited is ISO 27001 and ISO 27701 certified.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will process your personal data until the termination or cancellation of your Retail Client Agreement with Us to achieve the purposes described above and after its termination to comply with legal obligations applicable to insurance intermediaries.

MARKETING COMMUNICATION

We may use personal information to let you know about our products and services (e.g. via our newsletter) that we believe will be of interest to you. We may contact you by email, post, or telephone, depending on your chosen communication preference or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.  You can ask us to stop direct marketing at any time - you can ask us to stop sending electronic marketing, by following the 'unsubscribe' link you will find on all marketing messages we send you. Alternatively you can contact us using the details set out in the Contact Us section. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email).

PROFILING AND ANALYTICS

We may use Profiling or other forms of automated processing to make decisions about the products and services we offer you.
Please refer to our cookie policy to find out more about the information we collect using cookies and tracking technologies

COMPLAINTS

If you have a complaint or concern about how we use your personal data, please contact us  via the  following email address: LWAdataprivacy@lombardinternational.com and/ or by post mail at LIA Wealth Advisers Limited, Floor 27, 52 Lime Street, London, United Kingdom, EC3M 7AF in the first instance and we will attempt to resolve the issue as soon as possible. 


 Activity Type of information collected The basis on which we use the information
Set up a record on our systems
  • Contact details
  • Personal risk information
  • Product/Service information
  • Performance of a contract
  • Legitimate interests (to ensure we have an accurate record of all clients we provide products and services to)
Carry out background, sanction, fraud and credit checks/monitor or detect fraud
  • Contact details
  • Personal risk information
  • Criminal data
  • Financial information
  • Conditional consent
  • Legitimate interests (to ensure that clients are within our acceptable risk profile and to assist with the prevention of crime and fraud)
  • Legal obligation
Provide product or service
  • Contact details
  • Personal risk information
  • Health data
  • Criminal data
  • Financial information
  • Take steps to enter into a contract
  • Legitimate interests (to determine the likely risk profile and appropriate level, cost and type of product/service)
  • Explicit consent
  • Local law exemptions
Provide client care, assistance and support
  • Contact details
  • Product or service information
  • Performance of a contract
  • Conditional consent
Receive payments
  • Contact Details
  • Financial information
  • Performance of a contract
Comply with legal and regulatory obligations
  • Contact details
  • Product/service information
  • Personal risk information
  • Financial information
  • Legal obligation
Manage relationships
  • Contact Details
  • Legitimate interests (to maintain an accurate client and partner relationship management)
  • Consent
Administer contracts
  • Contact Details
  • Performance of a contract
Sale or reorganisation of the company
  • All
  • Legitimate interests (to structure our business appropriately)
Marketing
  • Contact Details
  • Legitimate interests ( to ensure  that our customers are kept up to date with information about our products and services)
  • Consent (where we are required by law to obtain your consent before sending you such information, we will rely upon such consent as our basis for processing).