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Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Types of information we collect and use

Depending on how you choose to interact with us, the information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your product or service with us e.g. your bank account and financial details
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected e.g. via cookies when you visit one of our websites (please see our section on cookies)
• Information classified as special category personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the products or services you have requested or to comply with our legal obligations
• Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
• Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
• Demographic information such as postcode, preferences and interests
• Other information relevant to customer surveys/and or offers

Where we collect your Information

We may collect your personal information directly from you, or from a variety of sources, including: • application forms for a product or service

• credit reference agencies
• phone conversations with us
• emails or letters you send to us
• meetings with your IFA
• registering for one of our events e.g. presentations, seminars or webinars
• participating in research surveys or feedback forms to help us understand you better and improve our products and services
• our online services such as websites, newsletters, social media and mobile device applications (‘Apps’)

If you use one of our Financial Advisers, the information we collect and use will most likely have been provided by them on your behalf. We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to verify your identity, to comply with our anti-money laundering and financial crime obligations, check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

What we collect your information for

We take your privacy seriously and we will only ever collect and use information that is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

• you have given us your permission [consent] to send you information about products and services offered by Juniper Wealth and other parts of The Boxwood Group and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you, or;
• it’s necessary to provide the products or services you have requested e.g. if you wish to take out any of the pensions, investments, mortgages, loans or insurances available through us. Typically to facilitate this we will require personal information including your name, address, date of birth, and bank account details, or;
• it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Review Letters or Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud, or;
• it’s in the legitimate interests of Juniper Wealth and The Boxwood Group e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment;
• we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services;
• we use artificial intelligence or computer algorithms to improve the products and services offered to you, or;
• it’s in the legitimate interests of a third party e.g. sharing information with the providers of products or services you have chosen through us.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services. We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you. • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• where we need to comply with a legal or regulatory obligation such as anti-money laundering.

In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

For more information about CRAs, please visit https://www.experian.co.uk/crain/index.html or https://www.equifax.co.uk/ein.html

Click here https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/  ) to find out more about the types of lawful basis that we will rely on to process your personal data.

We rely on consent as a legal basis for processing your personal data only in relation to sending third party or direct marketing communications to you.  You have the right to withdraw consent to marketing at any time by contacting us.

Automated decision-making systems

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:

• to tailor products and services e.g. placing you in groups with similar customers to make decisions about the products and services we may offer you to help meet your needs
• to design and enhance our online services to help meet your requirements for ongoing guidance and support.

For further information on your rights relating to automated decisions, please see the section on YOUR INDIVIDUAL RIGHTS.

Who we may share your information with

We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’ These third parties include:

• companies within The Boxwood Group
• your Financial Adviser
• companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you
• our Regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. Once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy notice applicable to the website in question.

Where your information is processed

The majority of your information is processed in the UK and European Economic Area (EEA).

However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States and India.

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

Our security controls are aligned to industry standards and good practice; providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection responsibilities.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees are trained to protect sensitive or confidential information when storing or transmitting data in any medium including electronically and must undertake annual refresher exercises on this.

How long we keep your information

We will keep your personal information where it is necessary to provide you with our products or services while you are a customer with us.

We may also keep your information after this period but only where it is required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your individual rights

You have several rights in relation to how Juniper Wealth and The Boxwood Group uses your information. They are:

The right to be informed You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with. This can be found in our Privacy Notices.

The right of access You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).

The right to request that your personal information be rectified If your personal information is inaccurate or incomplete, you can request that it is corrected.

The right to request erasure You can ask for your information to be deleted or removed if there is not a compelling reason for Juniper Wealth or The Boxwood Group to continue to have it.

The right to restrict processing You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted. The right to data portability You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.

The right to object You can object to Juniper Wealth and The Boxwood Group processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

Rights related to automatic decision-making including profiling You have the right to ask Juniper Wealth to:

• give you information about its processing of your personal information
• request human intervention or challenge a decision where processing is done solely by automated processes
• carry out regular checks to make sure that our automated decision-making and profiling processes are working as they should.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please write to us using the contact details above and we will do our utmost to make things right. If you are still unhappy, you can make a complaint to the Information Commissioner’s Office, who are the UK’s independent authority charged with upholding information rights in the public interest, promoting openness by public bodies and data privacy for individuals.  You can contact them at: https://ico.org.uk/