Privacy Notice
We are a group of separate companies that co-operate together under agreement and licence, but are not legally connected.
Aisa International SAS is registered at Lieu dit la Jaubertie 24380 Saint-Maime-de-Péreyrol, FRANCE
Aisa International (pty) Ltd is registered at 3rd Floor, Heritage House, 20 Dreyer Street, Claremont, Western Cape 7708, SOUTH AFRICA
Aisa International s.r.o. is registered at Pitterova 7, 130 00, Žižkov, Praha 3, CZECH REPUBLIC
Aisa International and Aisa Professional are trading styles of Aisa Financial Planning Ltd, whose address is at the bottom.
Money Trove Limited, 41 A Glover Street, Over, CB24 5PQ, UK Registered in England & Wales 4459189
Aisa Financial Planning Ltd controls a cloud based information and data system called Money-Trove under licence from Money Trove Limited.
This privacy notice explains how each company may use any personal information we collect about you. Each company will provide its own separate Privacy notice for services they are specifically advising you.
This notice focus on the websites and data held as a result of forms completed. It also outlines the crossover between data held by different companies.
Client data is stored securely for all companies, but each company only has access to their OWN client information on their website database, and their own privacy process according to the country they are based in. To be clear information held by one Aisa Group or International company cannot be accessed by another Aisa company on the website as they have separate third party secure logons; on Money-Trove.eu log-in is 2 factor authenticated. If a client wishes for their website data to be shared with another company then they will have to approve this first.
Aisa, in both the UK and in the Czech Republic, have a responsibility under financial legislation to record both incoming and outgoing calls to the company. This notice makes any person aware that their telephone calls to these companies and some individuals within the companies will be recorded and held in accordance with GDPR rules for up to 5 years, after which they will be deleted.
What information do we collect about you?
If you engage the services of an Aisa Group company, we will inform you which company you are dealing with and you will only be dealing with that company unless otherwise clearly informed. However, as the controlling entity Aisa Financial Planning has access to the databases although it will not process data other than if you engage it for services.
We (the relevant company) collect information about you when you engage us for financial planning or financial advice, mortgage or investment management services. Not all services are available in every country, and we will detail separately to you what services are available to you depending on where you live, and which company you are dealing with. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client fact finding, risk questionnaires, surveys or provide feedback to us, and this can be done through an online system called Money-Trove. Money-Trove is now separately owned by Money Trove Limited.
Information about connected individuals
We hold only contact details and initial inquiries on our website databases. However, in order for the companies to provide a service to you then we may need to gather additional personal information about you, your close family members and dependents in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them if we are also providing services to them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data outside of these websites is for the performance of the relevant company contract we have with you. The information that we (the company that you contract with through a terms of business or client agreement) collect about you is essential for the relevant company to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfill our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
The relevant company that you contract with collects information about you and your associated parties in order to provide you with the services for which you engage with the appropriate company.
Who might we share your information with?
If you engage the services of an Aisa Group company, they will provide their own Privacy notice to you for the the country they are based in, and where you give permission they may email you about other products or services that they think may be of interest to you. We’ll pass on your personal information to our group of companies only where you permit this, and where you have then they may offer you their products and services linked to your circumstances. However, Aisa Financial Planning controls the database servers and has access to data but will never use that data itself unless specifically approved. An example would be a client in France managed by the french company would only have their data controlled by the the French company according to the French Privacy Notice provided to you. The data itself is held on servers owned by Aisa Financial Planning, but Aisa Financial Planning will not review or use this data for the french based individual unless specifically contracted to by the individual.
We won’t share your information for marketing purposes with another Aisa Group company without your permission, and nor for companies outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. Any data sent to third parties are password protection and encrypted. Within Trove, all data is secured with encryption, and access to the system is two factor authenticated. Third party use will be granted only to those firms that we engage for professional compliance and IT services.
To fulfill our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re are also subject to regulatory requirements in the EEA, UK and USA to retain your data for specified minimum periods. These are in the EEA and UK, generally:
• Five years for investment business
• Three years for mortgage business
• Indefinitely for pension transfers and opt-outs
• Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records. For some business, such as pension business connected with the UK (whether you as the client are in the UK or not is irrelevant) then we have an obligation of holding your data for lifetime.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 6 years after our relationship with you has ended, with the exception of some business where the relevant regulator rules in a country insist we retain that data for a particular company – that company will inform you within their terms of business and privacy notice. We delete all emails after 1 year other than those that contain personal advice.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the personal information that each company hold about you. If you’d like a copy of some or all of your personal information, in the first instance, please email or write to the specific company you engaged as listed above at their relevant address following their client agreement and Privacy notice. You also have the right to contact the database controller which is Aisa Financial Planning using the contact details noted below. We will provide that information in digital format where appropriate, and we summarise the personal data and information we hold about you rather than provide copies of generic files.
If you write to a company in the group that you have not been working with, it is unlikely they will be able to respond other than to refer you back to the company that you hold a contract with.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
Whilst we have an obligation to ensure that your personal information is accurate and up to date at the time of providing services, you must ask us to correct or remove any information that you think is incorrect. We cannot be held responsible if part of our services are offered and you have failed to notify us of change of circumstances.
Automated decision making and profiling
If you use Money-Trove your personal information will be gathered through the information that you and we input onto the system. Your data is collected in order for us to carry out the service for which you engage us. If you’re unsure about the outcome of the automated process you can contact us to discuss or to challenge the outcome. There are no automated services conducted with your data in the rest of the Aisa Group at the time of this notice other than we have back-office systems where each company stores data that may be queried through searches.
We take measures to ensure the security of your data by following best practice including encryption and separate database held on private servers with full security and regular anti-hack checks. We don’t use any special category data (such as data about your health) in any automated process but we may have to use search queries where it’s strictly necessary to deliver our service and the relevant company will have obtained your explicit consent to do so.
We regularly check our systems for accuracy and bias and feed any changes back into the design process. For Money-Trove we refer you to their own statements on the handling of your data.
Marketing
We may ask you if we can send you information about our products and services and those of other companies in our group which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date. An example would be a British pension where you may be seeking advice from one of the International group companies, but only Aisa Financial Planning has the authority to deal with the query. You will be referred tot he company, and if you are to be advised then you will be sent a separate terms of business, but only if the UK company is providing advice.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post (details below).
How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you 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.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
We use these cookies:
Google Analytics cookie – _utma _utmb _utmc _utmx _utmxx _utmz
Analytic cookies to identify which pages are being used, helping us to analyse data about website usage and improve our website to better serve our customers.
More information here: Google Analytics
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
Links to other websites
Our website contains links to other websites. This privacy policy only applies to this website group, whose names are clearly displayed at the top of this notice, so when you link to other websites you should read their own privacy policies.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113 (local rate)
Changes to our privacy policy
We keep our privacy policy under regular review and we’ll place any updates on our web page. This privacy policy was last updated on 10 May 2020.
How to contact us
Please contact us if you have any questions about the privacy policy or information we hold about you by email.
Or write to us at Aisa Financial Planning, 10 Prince Maurice Court, Hambleton Avenue, Devizes, Wiltshire SN10 2RT, United Kingdom or, if your query relates to Money Trove Limited, then write to
Money Trove Limited, 41 A Glover Street, Over, CB24 5PQ, United Kingdom
Your right to be forgotten on this website database:
Please delete me from the website database.