How we deal with your data. Our Privacy Policy.



	<div><h1>How we deal with your data. Our Privacy Policy.</h1><p>This policy sets out the basis on which the personal or other data collected from you, or that you provide to us (moneyinfo limited), will be protected by us and how that information will be used. It describes the kinds of information we may collect from or about you, how we use that information and your rights to access and control our use of your information. </p><h2>1. The privacy &amp; security of your data is maintained at all times.</h2><p>The security and privacy of your information is extremely important to us and we have implemented appropriate technical and organisational security measures to ensure that your information is protected.</p><p>We use data and password encryption and the latest in electronic and physical security measures to give you the best possible protection. All information is securely transmitted using SSL standard encryption which creates an encrypted connection between your browser and our servers. Your information remains encrypted at all times.</p><p>Our servers are located in a secure facility that is protected by the very best in physical security, electronic security and internal security policies to ensure that your data remains secure. Security personnel monitor the system 7 days a week, 24 hours a day and access requires multiple levels of authentication.<br></p><h2>2. Purpose, legal basis and any concerns you may have.</h2><p>All data is held securely under the provisions of the relevant Data Protection Law which includes the Data Protection Act 1998 and the General Data Protection Regulation and data is provided for you for the purposes of viewing and managing your financial information.</p><p>The R C Brown Secure Portal is supplied to you by us through R.C. Brown Investment Management Plc who acts as our agent for that purpose. We are processing your personal data under the strict understanding that you have given explicit permission for us to do so to R.C. Brown Investment Management Plc. You may withdraw this consent at any time by notifying either us or R.C. Brown Investment Management Plc.</p><p>If you have any concerns in connection with your data and its processing via the R C Brown Secure Portal or if you think any data held within the R C Brown Secure Portal may be inaccurate or incomplete then please contact, in the first instance, R.C. Brown Investment Management Plc, the Data Controller.</p><p>You may also contact us as the Data Processer at Moneyinfo Limited, email enduserservices@moneyinfo.com, by telephone 03303 600300 or by writing to us at Moneyinfo Ltd, Forward House, 17 High Street, Henley-in-Arden, Warwickshire B95 5AA.</p><p>If you have a concern or would like to lodge a complaint against us you may raise your concern with the Information Commissioner’s Office (ICO). You may be eligible for compensation for damages caused if we breach of our responsibilities. For information on how to raise your concern with the ICO please see https://ico.org.uk/concerns/.</p><p>To make a complaint against R.C. Brown Investment Management Plc you should contact their Compliance Director either orally or in writing at their registered office.</p><p>If you have a concern or would like to lodge a complaint against either us or {CompanyName} you may raise your concern with the Information Commissioner’s Office (ICO). You may be eligible for compensation for damages caused if we breach of our responsibilities. For information on how to raise your concern with the ICO please see https://ico.org.uk/concerns/.</p><h3>2.1. What information is held about you?</h3><p>We hold personal information and other data in R C Brown Secure Portal as is necessary to provide you with the service. Most of the personal information we process is provided to us directly by you, either you have added it directly to R C Brown Secure Portal if you have permissions to do so, or R.C. Brown Investment Management Plc have captured the information previously and imported it from other systems they may use.</p><p>All data held about you within the R C Brown Secure Portal database is encrypted and securely stored and retained whilst you continue to be subscribed to the service.&nbsp; The data held is visible to you via the R C Brown Secure Portal service and you have control over who can access any data you add yourself.</p><p>The type of personal information we collect and hold includes:</p><ul><li>Personal identifiers, contacts and characteristics (for example, your name, national insurance number and contact details).</li><li>Demographic information such as your date of birth, gender or marital status</li><li>Details about your work, nationality, or your tax status.</li><li>Your financial information such as your income, expenditure, assets or liabilities.</li><li>Bank account information including your account type and details, account or credit card balances, account transactions or other details, if you choose to add your accounts through Open Banking</li><li>Details about you that are stored in documents that you may have uploaded to the service.</li><li>Information that allows us to understand how you use our services e.g. from your log in history or page visits;</li></ul><ul><li>We may also collect certain information about you and your use of our service by using cookies and other tracking technologies. This will record information such as IP address, domain names, the web browser and operating system used to access our website, your location and browsing history, including the pages visited, the time spent on each page, the time and date of each visit. This information is used to measure the use of our service and improve its content, and &nbsp;would not identify you without being combined with other information.</li></ul><p>For more information about how and why we use cookies and how you can change your cookie settings please see our Cookie Policy below.</p><h3>2.2. Your data belongs to you and you can delete your data at any time.</h3><p>Your data is yours. You can request it is removed from the R C Brown Secure Portal at any time. When you request us to delete your account from the R C Brown Secure Portal, your data will be permanently deleted from our primary production servers and further access to your account will not be possible. This deletion will disconnect any connection we had established to your account information. However, portions of your data, consisting of Aggregated Data derived from your account information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media for a limited period whilst backup cycles complete. the R C Brown Secure Portal keeps backup data to ensure that we can continue to provide the service to you in the unlikely event of malfunction of our primary production servers. We also reserve the right to retain and use any Aggregated Data derived from or incorporating your information.</p><p>If you have any queries about how we use your personal data, please contact R.C. Brown Investment Management Plc in the first instance or you can email us on support@moneyinfo.com..</p><h2>3. Why you should not solely rely on the information contained in the R C Brown Secure Portal.</h2><p>The content on the R C Brown Secure Portal is provided for general information only. Whilst every effort is made to ensure that the information contained on the R C Brown Secure Portal is accurate and up to date, we cannot accept any responsibility for the accuracy of the underlying data.</p><p>You should not rely on the information on the R C Brown Secure Portal to decide upon or undertake transactions or financial decisions. You must obtain professional or specialist advice from your financial adviser or an alternative qualified adviser who is regulated by the Financial Conduct Authority before taking, or refraining from, any action or financial decision. Use of the R C Brown Secure Portal does not constitute advice and we are neither qualified nor permitted by law to advise you in relation to financial matters.</p><p>We make no representations, warranties or guarantees, whether express or implied, that the content on the R C Brown Secure Portal is accurate, free from errors or omissions, complete or up-to-date.</p><h2>4. Data accuracy within the R C Brown Secure Portal.</h2><p>The information displayed in the R C Brown Secure Portal is only as up to date as the information supplied to us by third party sites, providers and R.C. Brown Investment Management Plc. We do not check the data we receive from third parties for accuracy and the information displayed may be more up-to-date when obtained directly from the relevant parties.</p><p>We do not assume responsibility for the timeliness, accuracy, deletion, non-delivery or failure to store any user data, communications or personalisation settings.</p><h2>5. Who will your data be shared with?</h2><p>Data is visible by you and any related parties linked to you. You can set privacy on any data you add yourself and choose which related parties you wish to share your data with. Your data may be shared with our staff and the staff of R.C. Brown Investment Management Plc as necessary to provide R C Brown Secure Portal to you and in their capacity as your financial adviser or wealth manager. R.C. Brown Investment Management Plc's access does NOT include the ability to view or access your bank, credit card or loan statements if you have chosen to add these using the Open Banking features. This data can only be viewed by you.</p><h3>5.1. Controlling your Privacy Settings</h3><p>You can directly control who can view any of the data which you have added to the R C Brown Secure Portal by use of the privacy control settings. See my privacy settings by clicking on the Me icon within the R C Brown Secure Portal.</p><h3>5.2. moneyinfo Ltd employees can access your data only in strictly safeguarded circumstances</h3><p>moneyinfo Limited employees do not have direct access to the R C Brown Secure Portal database except where necessary for system management, maintenance, monitoring and backups. In this scenario, only specific nominated individuals have access. Such access is only given and used in accordance with strict internal procedures, in order to operate, develop or enhance the Service. These individuals have passed stringent employment vetting checks and are bound by confidentiality obligations and are subject to disciplinary procedures, including termination of employment and potentially criminal prosecution if they fail to meet these obligations.</p><h3>5.3. Your log-in credentials are kept secure and encrypted in the R C Brown Secure Portal Service.</h3><p>You are responsible for ensuring that your login credentials are kept secure and not disclosed to any other party. In the event that you feel your log in credentials have been obtained by another party you should change your password immediately.</p><h3>5.4. Disclosure of your information to protect our rights or if required by law.</h3><p>Notwithstanding anything to the contrary, the R C Brown Secure Portal reserves the right (and you authorise us) to share or disclose your information at our sole discretion, should we deem that the disclosure of such information is necessary or appropriate:</p><p style="padding-left: 30px;" data-mce-style="padding-left: 30px;">a. to enforce our rights against you or in connection with a breach by you of our Privacy or Security Policies or the R C Brown Secure Portal Terms of Use;<br>b. to prevent prohibited or illegal activities; or<br>c. when required by any applicable law, regulation, other legal process.</p><h2>6. Other information regarding your data.</h2><h3><br>6.1. Marketing and other notices.</h3><p>You can change your marketing preferences within the settings section of the R C Brown Secure Portal to manage your email preferences and opt-out of education, marketing and service notifications. To access these settings click on the Me icon and select settings from the pop-up menu.</p><h3>6.2. Cookies and how we use online session information.</h3><p>We may store information about you in a cookie (a small file that is sent by our web server to your computer), which we can access when you make return visits to R C Brown Secure Portal. Storing cookies is usual practice for any web site that needs to remember what its users' preferences are and we use cookies to keep track of your choices in the Website. Our cookies are encoded so that they can only be accessed by us. If you would like to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that cookies are stored in. If you would like to stop cookies being stored on your computer in the future, please refer to your browser manufacturer's instructions by clicking "Help" in your browser menu. Further information about deleting or controlling cookies is available at www.aboutcookies.org.</p><p>We may collect information when you visit R C Brown Secure Portal such as the pages you have visited, your browser type or the average time you have spent on the site. Please note that when you visit our site, we may also log your IP address, a unique identifier for your computer or other access device. This information is only analysed and used to improve the design or functionality of the service or to alert you to any compatibility issues.</p><p>We use cookies to enhance the security of the service and to compile anonymous statistics about the use of the service. Here is a list of the main cookies that we use and what they are used for:</p><table class="mce-item-table"><tbody><tr><td width="117"><p>Category</p></td><td width="206"><p>Name</p></td><td width="279"><p>Purpose</p></td></tr><tr><td width="117"><p>Session</p></td><td width="206"><p>.NativityAuth</p></td><td width="279"><p>This cookie is strictly necessary for the website to function correctly. It remembers the user who logged in to the system. It is removed when the browser is closed.&nbsp;</p></td></tr><tr><td width="117"><p>Session</p></td><td width="206"><p>__RequestVerificationToken&nbsp;</p></td><td width="279"><p>This cookie is strictly necessary for the site to function correctly. It is used to protect the user against cross site request forgery. It is removed when the browser is closed.</p></td></tr><tr><td width="117"><p>Persistent</p></td><td width="206"><p>ai_user</p></td><td width="279"><p>This cookie is to determine if the user has previously visited the site (within the past year).&nbsp;</p><p>This cookie is created on first visit to the R C Brown Secure Portal website and expires one year after created.&nbsp;</p></td></tr><tr><td width="117"><p>Session</p></td><td width="206"><p>ai.session</p></td><td width="279"><p>This cookie is to link together the users navigations within the website to help support developers to understand what actions the user took and in what order.&nbsp;</p><p>This cookie is created on first visit to the R C Brown Secure Portal website and expires 30 minutes after it is created.&nbsp;</p></td></tr><tr><td width="117"><p>Persistent (Analytics)</p><p><br></p><p><strong>Note: Optional addition to the privacy policy if GA is switched on</strong></p></td><td width="206"><p>_ga</p></td><td width="279"><p>R.C. Brown Investment Management Plc may set up Google Analytics on R C Brown Secure Portal. These cookies collect information about how you use the site. This information is collected anonymously and is used to understand how users are engaging with the service. This cookie expires after 2 years.</p></td></tr></tbody></table><p><br></p><ol start="7"><li><strong> Your data protection rights</strong></li></ol><p>You have rights under data protection laws in relation to your personal information. This includes the following rights:&nbsp;</p><ul><li><strong>Right of access</strong>(commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.&nbsp;</li><li><strong>Right to rectification</strong>. This enables you to have any incomplete or inaccurate information we hold about you corrected.&nbsp;</li><li><strong>Right to erasure</strong>. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).&nbsp;</li><li><strong>Right to object to processing</strong>.&nbsp; As we have your consent to process your information you do not have the right to object to processing but you do have the <strong>right to withdraw consent</strong> which in effect acts as a right to stop the processing of your data.</li><li><strong>Right to restriction of processing</strong>. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to prove its accuracy or the reason for processing it.&nbsp;</li></ul><p>If you wish to exercise any of the rights set out above, please contact&nbsp;<a href="mailto:support@%7bServiceName%7d.com" data-mce-href="mailto:support@%7bServiceName%7d.com">support@moneyinfo.com</a>. R.C. Brown Investment Management Plc may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. R.C. Brown Investment Management Plc may also contact you to ask you for further information in relation to your request.</p><ul><li><strong>Right to data portability.</strong> This enables you to request the transfer of your information to another party. You can exercise this right within R C Brown Secure Portal via the My Downloads area under the ‘Me’ menu. Here you can request a download of your R C Brown Secure Portal data in a machine-readable format.</li></ul><p>You are not required to pay any charge for exercising your rights. We have one month to respond to you.</p></div>
Category	Name	Purpose
Session	.NativityAuth	This cookie is strictly necessary for the website to function correctly. It remembers the user who logged in to the system. It is removed when the browser is closed.
Session	__RequestVerificationToken	This cookie is strictly necessary for the site to function correctly. It is used to protect the user against cross site request forgery. It is removed when the browser is closed.
Persistent	ai_user	This cookie is to determine if the user has previously visited the site (within the past year). This cookie is created on first visit to the R C Brown Secure Portal website and expires one year after created.
Session	ai.session	This cookie is to link together the users navigations within the website to help support developers to understand what actions the user took and in what order. This cookie is created on first visit to the R C Brown Secure Portal website and expires 30 minutes after it is created.
Persistent (Analytics) Note: Optional addition to the privacy policy if GA is switched on	_ga	R.C. Brown Investment Management Plc may set up Google Analytics on R C Brown Secure Portal. These cookies collect information about how you use the site. This information is collected anonymously and is used to understand how users are engaging with the service. This cookie expires after 2 years.