VIRTUS INSURANCE SOLUTIONS AND PROTECTING YOUR DATA: PRIVACY POLICY

Virtus Insurance Solutions Ltd is committed to protecting the privacy of its clients, and we therefore ask that you please read the Data Protection Agreement before providing us with any information about you or any other person. This agreement explains when and why we collect personal information about people who inquire about or make an investment with Virtus Insurance Solutions Ltd. The agreement also explains how we use that information, the conditions under which we may disclose information to others, and how we keep personal information secure.

The Regulation

Insurance Solutions Ltd is regulated by the ICO (Information Commissioner's Office), the UK’s independent body set up to uphold information rights. Insurance Solutions Ltd, as a Data Controller, is legally obligated to comply with the General Data Protection Regulation (GDPR), which applies to all UK and EU businesses processing personal data from May 25, 2018. This ensures that, as our client, you can be sure that Virtus Insurance Solutions Ltd will manage and process your personal data in line with the new regulations.

Definitions

Data Controller – Virtus Insurance Solutions Ltd is classified as a Data Controller, as we determine the purposes and means of processing your personal data in respect of the advice we give.

Personal Data – When using the term “personal data” in our agreement, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold, which may include your address, date of birth, income, assets, etc.

Special Category Data – As part of our service, we may be required to collect Special Category Data about you to help us understand your personal circumstances and achieve your goals. This may include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, or data concerning a natural person’s sex life or sexual orientation. If applicable, you will need to give us explicit consent to process this data by using the opt-in box below.

The Purpose and Lawful Basis for Processing Your Personal Data

You acknowledge and understand that we process your personal and financial data (electronic and/or paper-based) regarding your circumstances, as this is a contractual requirement to advise you on your financial planning needs. Without your agreement to process your data, we will not be able to fulfill your financial planning requirements, as it is essential to carry out this contract. You can withdraw consent to process your data at any time by contacting us, but this will result in an inability to provide you with financial advice.

Relatives' Personal Data

When Virtus Insurance Solutions Ltd gathers data regarding your personal and financial situation, we may need to obtain data regarding your spouse or children to give you more rounded advice. The ongoing processing of their data falls under the lawful basis for processing titled ‘legitimate interest’, as it is required for the continuation of the service offered by Virtus Insurance Solutions Ltd. Without this information, we may not be able to provide you with the personalized and high standard of service that we endeavor to give all of our clients. If required, please ensure that either they complete the consent box or provide sufficient details for us to provide this document to them.

Third Parties and Your Personal Data

We confirm that your personal data will not be used or transferred by us to any other firm, company, entity, or person without your consent to do so, or without your acceptance of the financial advice to apply to specific product providers, i.e., Ascentric or Aegon. These providers are joint data controllers and are responsible for processing your personal data under the GDPR in the same manner as Virtus Insurance Solutions Ltd. We do not transfer any of your personal data to non-EU jurisdictions or international organizations. We may also provide information to our regulators, the FCA, or ICO upon request for regulatory purposes.

Where Personal Data is not Obtained Directly from the Client

In order to verify your identification, we are required to use a third-party Anti-Money Laundering provider to carry out verification services on our behalf. We have chosen Smartsearch as they are extremely reputable and maintain the high standards that Virtus Insurance Solutions Ltd looks for when using contractors. They are, therefore, classified as Joint Data Controllers as we share some of your personal data with them to obtain certain verification documents. For further information, please see the client agreement.

Your Rights Available under the General Data Protection Regulations (GDPR)

Under the new regulation, your rights have been enhanced and updated to ensure you have more control over the data that Virtus Insurance Solutions Ltd holds. These include the rights to be informed, of access, to rectification, to erasure, to restrict processing, data portability, and to object to processing. If you require more information on these, please contact the Virtus Insurance Solutions Ltd Data Protection Officer at the address below or visit the ICO (Information Commissioner's Office) website at ico.org.uk.

Marketing

Virtus Insurance Solutions Ltd does not 'direct market' to any of our clients. We have a legitimate interest in contacting you about your plans and will only contact you regarding the performance of your existing contracts or portfolios, and for associated purposes such as our quarterly investment newsletter and individual tax-efficient opportunities. It is not recommended to stop these communications as they are vital to the performance of your contract; however, if you wish to have these removed, please do contact the office directly.

Retention Periods for Your Personal Data

If you become a Virtus Insurance Solutions Ltd client, we will retain your personal data throughout the contract period, following termination of this contract, and until your death. This is because under FCA regulation, there are no clear limitations as to when a client can make a complaint regarding the financial advice from firms, and therefore it is necessary to keep all data such that Virtus Insurance Solutions Ltd could defend a potential legal claim in the future. You do, however, have the right to restrict the processing of your data should you require it.

If you are a prospective client, we will retain your data for 2 years, after which point we will delete it, unless you revoke your consent to process your data sooner than this.