Privacy notice

Vested Employee Benefits Limited (VEBL) will collect personal information about you such as your name and address (“Personal Data”). The VEBL client will be the Data Controller and VEBL will be the Data Processor as defined under UK Data Protection legislation.

The Personal Data the subject of this Privacy Notice is not only Personal Data relating to the VEBL client itself but also the Personal Data relating to employees of the VEBL client.

Despite not having a direct contractual relationship with employees of VEBL clients, VEBL shall process Personal Data belonging to such employees on the basis on the contractual representation given by the VEBL client that such Personal Data has been transferred to VEBL on a lawful basis in accordance with UK Data Protection legislation.

VEBL will apply the same levels of protection to Personal Data of such employees as it does to Personal Data of VEBL clients and for the purposes of this Privacy Notice, references to Personal Data shall include both Personal Data of the VEBL client and Personal Data of the employees of the VEBL client.

We will only process your personal data where we have a legal basis for doing so. This includes:

• Where you have provided positive consent to the company
• Processing is necessary for the performance of a contract between you and VEBL or to take steps to enter into a contract;
• Processing is necessary for compliance with a legal or regulatory obligation
• The company has a legitimate interest upon which the data may be processed. Any decision to process data on the basis of legitimate interest will be made on a case by case basis and in line with the guidance set out in UK Data Protection legislation.

This means we may disclose your Personal Data to other companies within the Embark Group of companies and third parties for example your Financial Adviser, third party investment managers, and product providers provided one of the legal basis described above can be relied upon.  The most common reason for disclosing your Personal Data to any of the above parties will be because the sharing and processing is necessary for the performance of our contractual obligations to you in our administration of your account.

We may disclose your Personal Information to a credit reference agency in order to verify your details both during the application process and the ongoing administration of your account. This information will be used to prevent fraud and money laundering and to check your identity. Any checks performed may be recorded on your credit history.

We will disclose your Personal Information to any governmental, legal or regulatory body if required to do so by applicable law and regulation.

We may need to disclose sensitive Personal Data about you to third parties, such as information relating to your health where required to do so to give effect to an instruction from you or your Financial Adviser in respect of your account.

We may need to transfer your Personal Data to another country, in which case we will ensure that your Personal Data is afforded the same level of protection as is required under UK Data Protection legislation and regulations prior to sending your Personal Data.

We will otherwise keep your personal information confidential and never pass your details to any third parties without your consent.

We will retain your Personal Data for no longer than is necessary to meet any legal or regulatory obligations that may apply.

For further details of your rights under the UK’s data protection legislation and regulation please contact the Information Commissioner’s Office online here.

You have a number of rights under UK Data Protection laws, including:

1. the right to request a copy of the personal information we hold on you.  When you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee;
2. the right to have personal information we hold about you transferred securely to another service provider in electronic form;
3. the right to have any inaccurate personal information corrected;
4. the right to have any out of date personal information deleted once there’s no business need or legal requirement for us to hold it;
5. the right to object or restrict some processing, in limited circumstances and only when we don’t have legitimate grounds for processing your personal information;
6. the right to object to your personal information being used to send you marketing material.  We will only send you marketing material where you’ve given us your consent to do so.  You can remove your consent at any time.

If you have any questions regarding how the firm uses the data it collects please contact:

The Group Data Protection Officer
The Embark Group
7th Floor, 100 Cannon Street
London
EC4N 6EU

If you are not satisfied with any aspect of how we have managed your data you have the right to complain to the Information Commissioners Office. For further details of your rights under the UK’s data protection legislation and regulation please contact the Information Commissioner’s Office online here.

By signing the VEBL terms and conditions you consent to the use by VEBL of Personal Information for the purposes and on the terms set out above. You have the right to withdraw consent at any time.

Changes to this Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.