Privacy Policy

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At Greatway Financial Ltd, we value your trust and are dedicated to protecting your privacy. We handle your personal information responsibly and ensure it is collected, used, and stored in a manner that is fair, lawful, and transparent.

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This privacy notice explains:

• Who we are;
• Your rights;
• What personal information we collect;
• How we use your personal information;
• Who we share your information with and why;
• How we keep your information secure; and
• How to contact us.

In this document, “We”, “Us” and “Greatway” refers to Greatway Financial Ltd ("GWF").

Greatway Financial Ltd (“Greatway”, “we”, “us”, or “our”) is a financial services firm directly authorised by the Financial Conduct Authority (FCA) in the United Kingdom. Our team of qualified and experienced advisers provides professional financial advice designed to help secure your financial wellbeing and long-term stability.

In the course of delivering our services, Greatway Financial Ltd determines the purposes and means by which personal data relating to our clients is processed. As such, we act as a Data Controller for all activities connected to the provision of financial advice and are therefore responsible for ensuring that client data is managed and processed in accordance with applicable data protection legislation.

In certain circumstances, Greatway Financial Ltd may act solely in its own capacity for specific functions, such as direct marketing or other related business operations.

As a Data Controller, we are committed to processing all personal information fairly, lawfully, and transparently. We comply with all relevant data protection laws, which require that personal data we hold about you is:

• Processed lawfully, fairly, and in a transparent manner;
• Collected for explicit, legitimate purposes that we have clearly communicated to you;
• Relevant and limited to what is necessary for those purposes;
• Accurate and kept up to date;
• Retained only for as long as is necessary to fulfil the stated purposes; and
• Stored and handled securely to protect against unauthorised access, loss, or misuse.

At Greatway Financial Ltd, we are committed to being transparent about how we handle your personal information. We believe in giving you clear visibility and control over your data, and we fully support your rights under data protection laws.

You have the right to request the following:

• Right to be informed – To be told how and why we collect and use your personal information. This information is provided through this Privacy Notice and other relevant communications.
• Right of access – To obtain a copy of the personal information we hold about you.
• Right to rectification – To request that any inaccurate or incomplete personal information is corrected or updated.
• Right to erasure – To ask for your personal information to be deleted, where there is no lawful reason for us to continue processing it.
• Right to restrict processing – To ask us to limit the way we use your personal information in certain circumstances.

In addition, depending on the circumstances, you may also have the right to: 

• Right to object – To object to the processing of your personal data, including where it is used for direct marketing purposes.
• Rights related to automated decision-making and profiling – To object to decisions made solely through automated processes, including profiling, that significantly affect you.
• Right to data portability – To request that we provide your personal information to you, or to a third party you have chosen, in a structured, commonly used, and machine-readable format.

Exercising your rights

For information about your individual rights, including how to correct, restrict, delete, make changes to your personal information or if you wish to request a copy of the personal information we hold about you, please contact us by emailing us at atiangson@greatwayplanning.co.uk.

More information about your data protection rights can be found on the Information Commissioner’s Office (ICO) website as well as on other regulators’ websites.

If you would like to write to us, our postal address for data protection matters is:

Angelika Tiangson
Greatway Financial Ltd

5 Whins Avenue

Bolton

BL4 0NP

However, we have adopted a flexible model for working so please note that written communications will take longer to respond to than emails.

Further information

This privacy notice was drafted with brevity and clarity in mind, however further information can be obtained by contacting us using the details in the "contact us" section. More information about your data protection rights can be found via:

• UK Information Commissioner’s Office (ICO)

Personal data means information by which you may be personally identified directly or indirectly.

We collect certain personal information about you, this includes your name, address, or phone number and other information. We collect this information about you when you:

• Use our website and secure online services;
• Contact us about products and/or services;
• Apply for and receive our services;
• Complete our application form;
• Apply for employment;
• Visit a financial adviser; and

The type of personal information we collect will depend on the purpose for which it is collected and may include:

• Information about you to help identify you and manage your relationship with Greatway and, in some circumstances, as required by our regulators (e.g. Account number, Customer ID or Number, Name, Address, Age / Date Of Birth, Dependents' Details, Tax ID, National Insurance Number, Identity Check Information (e.g. Mother's Maiden Name, Name of First Pet), Email Address(es), Marital Status, Postcode, Telephone Number(s), Title, Gender);
• Information about your account with us (e.g. Past engagements with Greatway, Personal Preferences, Marketing Preferences and Policy, etc);
• Copies of documentation (e.g. statements, letters, copies of official documents (e.g. passports, driving licences, etc));
• Economic and financial information (e.g. credit card numbers, bank details, Past investment performance, etc and information pertaining to County Court Judgements (CCJs) and any debt history);
• Employment and educational information (e.g. employer details, relevant professional qualifications, etc);
• Marketing / Communications Data (e.g. Information relating to Marketing and External Communications (e.g. Marketing Campaigns, Opt-In Information, etc));
• Lifestyle, Health and Medical information for you, your family and other parties with a material interest in the product(s) (e.g. specific illness, smoker, disability, gender reassignment);
• Relationship Information (e.g. information relating to other parties directly associated with your policy (e.g. dependents, beneficiaries, trustees, etc); and
• Complaint Information (e.g. Complaint Description, Complaint Type, Reason/Details of the complaint).

We collect personal information directly from you. For example, we ask for personal information at the start of our relationship (e.g. when you apply for a policy or service) and in subsequent communications in order to manage our relationship (such as periodic “Fit and Proper” or competency checks). This is a regulatory requirement imposed by our Regulators and is important to help safeguard you and us against potential crime.

Where we provide our services to trusts, we collect the personal information listed for the settler, beneficiaries and trustees of that trust. Where we provide our services to companies we may collect personal information for Directors, Shareholders and Beneficial Owners of the company. Where we provide our services to charities, we may collect personal information about the trustees or directors of that charity.

We may also collect information about you from other sources such as:

• another agent (if you have one);
• the company who you act on behalf of;
• regulatory bodies, such as the UK FCA;
• credit and fraud prevention agencies, including sanctions lists; and
• external third parties (e.g. credit reference agencies to verify your identity and to check financial soundness).

Data retention

We keep your personal information only as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal information will be securely disposed of when it is no longer required in accordance with our Personal Data Retention Standard.

If your personal data is used for more than one purpose, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that period expires. Our retention periods are also based on our business needs and good practice, legal requirements and the principle of Storage Limitation.

Special category data and criminal conviction data

Greatway may also gather more sensitive personal data, called special category data, for example, as part of recruitment. This type of data can include racial or ethnic origin, genetic or health information or sexual orientation. The processing of some of this data is necessary for us to fulfil the obligations on us. In such cases, we will always explain this during the process and explain what information we require and why it is needed. We process any special category data we collect either using the lawful basis of substantial public interest or with your explicit consent. Special category data will always be processed and stored securely.

Where it is necessary, we may also collect information relating to an individual's criminal convictions. If this is the case we will explain what information we require and why it is needed and we will process this data using the lawful basis of substantial public interest.

Cookies and similar technologies

Our website may collect information from your computer using “cookies” and similar technologies which provide us with limited personal information. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners.

You can choose not to accept any non-essential cookies for your interactions, however, in a few cases, some of our website features may not function as a result. You can also delete any cookies that you may have accidentally accepted from your devices’ browser settings page.

We process your information for the following purposes:

• To perform our contract with you and to support and maintain that relationship. This includes the following:
  • assessing and processing an application for our services;
  • providing our products and/or services to you, including the management of our relationship with you, your adviser, or any other agent (if you have one);
  • carrying out transactions you have requested or on your behalf;
  • recording specific needs or adjustments you have or may require from time to time such as text to speech, large print, family representatives or medical reasons which allow us to better assist with your understanding of our products and services;
  • managing complaints and interactions with you;
  • monitoring or recording communications (such as telephone and video calls) with you to resolve any queries or issues and also for training and quality purposes and, in some cases to comply with regulatory requirements;
  • assessing your application for products (using automated decision-making tools when necessary);
  • record keeping in order to ensure our products and/or services operate within the law and relevant regulatory requirements;
  • as part of our recruitment activities; and
  • providing other services (e.g. enhanced due diligence, underwriting, reinsurance, data hosting, online services, and payments or reporting of any tax or levy).
• To comply with legal and regulatory requirements. These requirements include the following:
  • confirming your identity for regulatory purposes;
  • detecting and preventing fraud, money laundering, terrorist financing, bribery or other malpractice;
  • to meet tax reporting obligations such as Common Reporting Standards (CRS) and the US Foreign Account Tax Compliance Act (FATCA); and
  • to fulfil our data protection obligations.
• For specific business purposes to enable us to provide you with appropriate products and services and a secure experience. Our business purposes include the following:
  • verifying your identity for security purposes;
  • providing service messages which are relevant to our relationship with you and communications which are required to meet our regulatory obligations;
  • enhancing, modifying and personalising our services for your benefit;
  • to undertake Profiling activities;
  • audit and record keeping purposes;
  • general training and quality purposes;
  • enhancing the security of our network and information systems;
  • maintaining effective management systems including internal reporting and other members of our corporate group;
  • ensuring the integrity of our systems (for example, during final stages of testing where it is necessary to use real data to ensure that any system improvements do not interrupt business or corrupt the data);
  • providing reports and other communications to you where we are required to do so;
  • monitoring the number of visitors and usage of our website, and to maintain its effective operation;
  • analysing user behaviours on our website to improve its functions, usability and improve the customer journey;
  • to obtain and manage our own insurance; and
  • customer satisfaction research, statistical analysis and wider market research to capture the views and opinions of our customers.

We may also process your personal data as part of an acquisition or sale. Should this happen, you’ll be notified about any change to processing or data controller arising as a result of this activity.

You have the right to object to us processing your personal information for some of the business purposes listed above but, if you do so, this may impact on our ability to provide some or all of our services to you.

Profiling

Profiling involves the use of basic identifiers about you such as your name and address and matching this with information from third party services to create a demographic model and infer customer ‘types’. This helps us define groups based on factors like interests, age, location and more so we can better understand our customers to adapt and improve our products and services, and to ensure that we are developing and providing services that meet the needs of our customers, as is required by the Financial Conduct Authority (FCA).

Artificial Intelligence (AI)

At Greatway, we may utilise AI technologies, including machine learning, to perform some activities. Where this is the case, the output can be reviewed using human oversight. We will always endeavour to use AI technologies ethically in line with legislation, regulatory guidance and governmental policy and we will anonymise or aggregate personal data where appropriate.

Lawful basis

Greatway operate under a number of legal bases as required under the regulations. These include:

• Consent;
• Legitimate Interests;
• Substantial Public Interest;
• Performance of a Contract; and
• Compliance with a Legal Obligation.

We share your information with trusted third parties and service providers who perform tasks for us and help us to provide our products and/or services to you, and with other agencies where required by law, court order or regulation. These may include:

• Organisations and parties appointed by you or authorised by you
  • with third parties where you have given your consent to receive marketing information;
  • with your accountants to produce tax statements and in support of statutory reporting;
  • with an appointed discretionary asset manager or custodian to meet their legal or regulatory requirements; and
  • with product providers who ask for that information in order to allow us to provide our services to you.
• Statutory authorities
  • with organisations, including the police authorities and fraud prevention agencies, to prevent and detect fraud;
  • with regulatory or governmental agencies such as the UK Financial Conduct Authority, UK Information Commissioner’s Office and HM Revenue and Customs;
  • with professional bodies; and
  • with other agencies where required by law, court order or regulation.

If you would like further information regarding the specific named recipients that we share data with, please contact us using the information in the “contact us” section.

We’re committed to ensuring the confidentiality of the personal information that we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure and prevented from unauthorised or accidental access, processing, copying, modification, erasure, loss or use.

If we work with third parties in countries outside the United Kingdom, we ensure these are countries that the UK Government and the European Commission have confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards and agrees to treat your information with the same level of protection as we would.

We also utilise UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the United Kingdom or European Economic Area.

In limited circumstances, data may be accessed by employees outside of our usual operating locations. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.