As a financial services company we have an important responsibility to protect the data you share with us and ensure your privacy is maintained. This document is intended to help you understand what information we collect, how we use it and how you can control that information.
Where we refer to “Octopus Money”, “we”, “us” or “our”, we mean TW11 Wealth Management Limited, a Company registered in England (No. 10339119). TW11 Wealth Management Limited is authorised and regulated by the Financial Conduct Authority (FCA). The firm reference number is 763630.
What we collect
|Information Collected||When We Collect It|
|Your name and contact details (email, phone number)||When you contact us through the Octopus Money website|
When you enquire about Octopus Money through marketing partners or services (e.g. VouchedFor)
|Your name and work email address||When your employer introduces Octopus Money as an employee benefit, and asks us to email you on their behalf.|
|Information about your finances including:|
– Income and Expenditure
|To create your financial plan|
When you use the Octopus Money financial planning tool
When you use the Octopus Money financial services
|Payment information / Bank Account information||When you choose to pay for Octopus Money through Direct Debit|
When you claim the Octopus Money Referral Reward
|Employment information, including your current employer and occupation||When signing up to Octopus Money and/or when creating your financial plan|
|Communications we have with you(emails, online chat, letters, telephone call recordings, audio recordings from in person meetings)||When you get in touch with us|
When you have a coaching session or other communication with a Financial Coach
When you respond to requests for feedback
|Information about your location and how you use our website||When you use the Octopus Money website or Octopus Money financial planning tool|
When you update your account
When you open our emails
|Information publicly available on your social profiles||When you like or otherwise interact with us on Facebook, Twitter or LinkedIn|
|Sensitive data including gender, sexual orientation and health information||When creating your financial plan|
When providing our Insurance & Protection Service
|Copies of your passport, driving licence or other official documentation so that we can verify your identity||If we cannot identify you using electronic verification methods, we may need copies of these documents to do so|
|Information on how you use our online services, including our website:|
For example, the IP address of the devices you use to access our services and other technical usage data.
|When you use our website and other online tools|
|Information we receive from other companies within the Octopus Group, provided you agreed with them that they can share it:||When Group companies share your data with us (provided you agreed to let them do so)|
How we use the information that we collect
|What we use your information for||Legal basis||Our legitimate interest|
|To build and update financial plans||To fulfil our contract with you|
|To provide financial services to you||To fulfil our contract with you|
|Communicating with you as part of the Octopus Money service||To fulfil our contract with you||– Ensure our clients are aware of all of the services available to them through Octopus Money|
– To notify clients of changes to legislation, tax rules or other things that will affect their finances and/or where some action would improve their finances.
– To encourage clients to recommend Octopus Money to their friends and/or colleagues
|Referring you to a non-Octopus Money financial adviser||Legitimate interest||– To ensure clients get financial advice in the event that Octopus Money turns out not to be suitable for their needs.|
|To inform you about our news and offers you might be interested in||Legitimate interest||– To develop our products and services.|
– To keep you informed about services offered by Octopus Money.
|To carry out research and development|
To test new products and services
|Legitimate interest||– Identify ways to improve our services|
– Be efficient about how we fulfil our contracts, provide our services and fulfil our legal duties
|To process, respond to and resolve feedback and/or complaints||Legitimate interest||– Identify ways to improve our services|
– Be efficient about how we fulfil our contracts, provide our services and fulfil our legal duties
|To ensure compliance with our legal obligations as a regulated financial advice firm||We have a legal duty|
|To detect and prevent fraud and/or financial crime||We have a legal duty|
How we share information we collect
Sharing anonymised or aggregated data
We will from time to time share data with partners, other third parties and/or publicly which shows how the Octopus Money service is used, the financial wellbeing of our customers, and any feedback we have received about Octopus Money. We do this so that we can validate the impact we are having, and identify areas to improve either our impact, or other things we or our partners could do to improve financial wellbeing. All personal information used for this purpose will either be anonymised and/or used in aggregate such that no individual person will be identifiable.
Sharing information with third party providers of Financial Services as part of the Octopus Money Service
Some of the financial services included as part of the Octopus Money Service are delivered by a third party service or financial adviser. We select our partners carefully to ensure they offer a high quality service and are the most suitable option for our clients. Examples include:
- Investment firms (such as fund managers), insurers, insurance or credit brokers and similar organisations who offer financial products
- Providers of third party data sources to verify your identity and prevent fraud
- Providers of financial planning, content management or productivity software and tools.
We may share you data with any organisation which you disclose to us that might hold information about your investments, pensions and other financial products or anything else we might need to know about. This includes:
- Your existing providers
- Your current and past employers
- Government departments
- Other persons or organisations we believe may help us.
To ensure that clients receive the best possible customer experience, we will share the information those third parties will require in order to contact you and deliver the services required.
For example, a client who needs a mortgage would be referred to our specialist whole of market mortgage broker. We would share information about the client’s name, contact details and relevant financial information that the mortgage broker will need to get a mortgage quote.
We may also request permission to share sensitive information about you to those third parties where the information is essential to carrying out the requested service. For example when referring you to our Protection Specialist we will request permission from you to let them know about any health conditions you have told us about. This information will only be shared with your explicit consent.
How long we keep information
The length of time that we store information we have collected about you depends on the type of information and what it was collected for.
As a regulated financial advice firm we are required to demonstrate that we are compliant with the laws and regulations related to providing financial advice. Therefore, we will retain a record of our clients, their financial plans and the financial services we provide for an indefinite period.
All other information will be retained for as long as required for the uses outlined above. When your information is no longer needed, we will either delete or anonymise your information.
Where your data is stored
The vast majority of personal data stored by Octopus Money is held within the UK and Ireland. However, we do use a number of third party services which store and process data in the USA. We have implemented a number of processes and policies to ensure that the security and privacy processes and policies of our third party services are at least as protective as our own.
We also have written contracts with every third party to ensure compliance with GDPR and ensure your rights are protected. We review our third party services at least annually to ensure ongoing compliance.
If you have any questions or concerns about the storage of your data, please contact us at firstname.lastname@example.org
Under the terms of the General Data Protection Regulation (GDPR) you have the following rights:
You can ask us for a copy of the personal information we hold about you; we will provide this free of charge.
You can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you.
In certain situations, you can ask us to erase the personal information we hold about you, or object to particular ways in which we are using your personal information. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time.
Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information by contacting email@example.com
For security reasons we may ask for proof of your identity before we disclose information about you, or to you, via email or over the telephone.
Privacy and your rights
Cookies are used to uniquely identify a person and therefore at Octopus we treat them as personal identifiable information. Cookies are used for analytics and advertising to improve the experience and relevance of our websites. At Octopus we want our customers to understand what cookies are by being jargon free, whilst also being transparent regarding how we use them, please see the What are cookies? What cookies do we use? and How do I turn cookies off? so you are fully aware.
What are cookies?
Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the domain you are visiting are called “first party cookies.” Therefore, cookies served by the Octopus Money website whilst you visit octopusumoney.com are first party cookies.
Cookies served by companies that are not operating the domain you’re visiting are called “third party cookies.” For example, we may allow Google to set a cookie on your browser while you visit octopusumoney.com, and that would be a third-party cookie. Cookies may also endure for different periods of time. “Session cookies” only last as long as your browser is open.
These are deleted automatically once you close your browser. Other cookies are “persistent cookies” meaning that they survive after your browser is closed. For example, they may recognise your device when you re-open your browser and browse the internet again.
What cookies do we use?
We use the following cookies:
Analytical and performance cookies. We may use analytics service providers in relation to the Octopus Group websites’ traffic analysis and reporting. Analytics service providers generate statistical and other information about the use of the Octopus Group websites by using cookies. They allow us to recognise and count the number of visitors and to see how often visitors return to the Octopus Group websites, how long they stay and how visitors move around the Octopus Group websites when they are using them. This helps us to improve the way the Octopus Group websites work, for example, by ensuring that users are finding what they are looking for easily. The information generated relating to the Octopus Group websites may be used to create reports about the use of the Octopus Group websites and the analytics service provider will also store this information.
Advertising and targeting cookies. These cookies record your visit to the Octopus Group websites, the pages you have visited and the links you have followed to other websites. We will use this information to try and make the Octopus Group websites and other websites that you visit more relevant to your interests. We may also share this information with others, within the Octopus Group and carefully selected third parties for this purpose.
Functionality cookies. We may use functional cookies that allow us to remember choices you have made in relation to the Octopus Group websites so as to provide a more personalised experience and enhanced user experience by delivering content specific to your interests.
How do I turn cookies off?
You can use your browser settings to accept or reject new cookies and to delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or other device.