This privacy policy carefully explains how we use any personal information we collect about you. It relates to Bower Group Limited and all our subsidiaries.
Changes to our privacy policy
We regularly review our privacy policy and will place any updates on this web page.
What information do we collect about you?
We collect information about you, such as your name and contact details, when you engage us for Equity Release, Mortgage or Financial Planning advice, or where you utilise our pension income, insurance or estate planning services including wills and lasting power of attorney (LPA).
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 survey forms or use calculators on our website, when you provide feedback to us, or we may obtain information from referrals made by authorised third parties or from publicly available information.
Information relating to usage of our website is collected using ’cookies’, once you have approved the use of cookies (see cookie policy). These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
As a Data Controller, Bower processes its own data using its own Data-Processing systems. However, in the case of digital marketing, Bower may on occasion use Facebook Audiences and Google Customer Match as its Data-Processor to create Audiences for marketing purposes.
Bower data is either anonymised before being sent to these data processors, or immediately deleted after use, to ensure privacy. The data is then used to create audiences matching this data. For more information, please see terms for Facebook and Google.
How we use this information
Bower will process your data in order to fulfil our contract with you when you enquire about or purchase a service from us.
If you enquire about our services through our calculators or forms on our website, we will use the information you provide to contact you and provide further information about our various products and services.
We may combine data captured from across our group as well as overlay additional demographic and lifestyle data from publically available and other authorised sources, to help us understand your circumstances and needs for marketing and insight purposes. This will help us personalise the content we share with you with the aim of making it more relevant to you.
Information may be shared to help us improve our website and marketing by collecting and reporting information on how it is used. The information which may be shared (and which is collected in a way that does not directly identify anyone) may include the number of visits to the website, where visitors have come to the website from and the pages they visited.
By entering your name, address, telephone and email details, you understand and accept that we will not pass this information on to any third parties without your express consent.
Let’s explain the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In certain specific situations, we will collect and process your data with your consent. For example, before you submit your email contact details when using our online calculators.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Where special category data is required, for example details about your health, we’ll always obtain your explicit consent in order to collect and process this information.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
The information that we collect about you is essential for us 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 fulfil our legal and regulatory obligations.
For example, in order to provide you with suitable equity release advice, we need to gather information about your current financial circumstances.
Legal/Regulatory compliance
If the law requires us to, we may need to collect and process your data.
For example, where we identify fraud or other criminal activity we will pass on personal data, including your IP address, to relevant law enforcement agencies and/or other companies in the same industry as Bower.
Legitimate interest.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
When we process your personal information for our legitimate interests, we make sure to consider the balance and any potential impact on you (both positive and negative) and your rights under the data protection regulation.
Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Our legitimate business interests may include some or all of the following:
- To send you marketing communications, informing you about our products and services and keeping you updated about any relevant development (you can opt out of marketing communications at any time)
- For evidential purposes, to effectively manage and maintain records of our relationships and communications with you
- To enhance, modify, personalise or otherwise improve our services and communications for your benefit
- To better understand how you interact with our website and content in order to enhance your customer experience
- To determine the effectiveness of promotional campaigns to inform marketing strategy
Who might we share your information with?
We won’t share your information for marketing purposes with organisations 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 printing services, professional accountancy or legal services, as well as product providers we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a data processing agreement (DPA) 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.
To fulfil 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.
We reserve the right to disclose your information should we enter into a sale or merger with another business.
How we store your information
All of the information we collect or record is restricted to our premises and only members of staff who need the information to perform their specific job are granted access to your personal information.
We follow strict security procedures to make sure that your personal information is not damaged, destroyed, or disclosed to a third party without your permission and to prevent unauthorised access to it. Our storage computers are kept in a secure facility and we use secure firewalls and other measures to restrict electronic access.
As with all websites, we automatically record ‘log files’ which contain information about our website traffic, for example IP address, pages viewed and amount of time spent on the website. These log files build pictures of how our site is used so we can monitor and improve our service. We are unable to identify you from your log files.
We will retain your information for a reasonable period of time or for as long as is required by law.
How long we hold on to your information
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
At the end of any retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Your rights
You are entitled to or make choices about how we collect your data and exercise your rights over the information you give us or make choices about how we collect your data.
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.
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
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.
We have an obligation to ensure that your personal information is kept accurate and up to date. Please ask us to correct or remove any information that you think is incorrect via our GDPR request form. Your information will not be transferred outside of the European Economic Area.
Sending funds electronically to our bank account
We are committed to helping minimise your risk of being exposed to fraudulent activity.
We will NEVER notify you of changes to our bank details or send bank account details by email or electronic communication requesting money.
If you receive any communication indicating any change to our bank details or a request for money then you should immediately call our Accounts Department on 0203 817 6050 to confirm authenticity before you send any money or communicate further.
Cookies
We use cookies (which are text files placed on your computer) to track visitor use of the website and to compile statistical reports on website activity. We do this using Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). We also use Microsoft Clarity, a web analytics service provided by Microsoft Corporation, to help us improve our website by analysing how users interact with it. This data is collected anonymously and is not used to identify you personally.
The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Further details can be found in our cookie policy.
For further information about cookies visit https://ico.org.uk/for-the-public/online/cookies/
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.
Getting in touch
Bower treats the personal information of our customers with the utmost respect and confidentiality. You can contact us at any time if:
- You change your mind about receiving our postal/email offers or sharing your information with third parties
- You would like to correct and/or update your registration information
- You have any queries or comments about our use of your personal information
You contact us by email at [email protected].
Or write to us at Bower, Ongar Business Centre, The Gables, Ongar, Essex CM5 0GA.
You may be required to co-operate with our security checks before we disclose information to you.
You also have a right to lodge a complaint with the supervisory authority for data protection if you are unhappy with how your personal data is processed. In the UK, this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Company information
Bower is a trading style of Bower Retirement Limited. Bower Retirement Limited is a company registered in England and Wales, No: 5788110.
Registered Office: Bower, Ongar Business Centre, The Gables, Fyfield Road, Ongar, CM5 0GA.
Bower Retirement Limited is authorised and regulated by the Financial Conduct Authority. Financial Services Register Number: 451607. The Financial Conduct Authority does not regulate estate planning services.
Bower Retirement Limited is owned by Bower Group Limited which is registered in England and Wales number 14018276.
Bower Retirement Limited Information Commissioner’s Office (ICO) registration number is Z9443391.
