information, and what we do to ensure it is kept private and secure.
This Policy sets out the following:
- The Companies in the Wills Tax & Trusts Group
- The Information we collect
- Clients and Potential Clients
- Business contacts and professional advisers
- Our website and cookies
- Storing your information
- Your rights
- Updates to this Policy
1 THE COMPANIES IN THE WILLS TAX & TRUSTS GROUP
The group comprises of :-
Rabix Ltd t/a UnaVida Life Planning
Wills Tax & Trusts Ltd
Independent Probate Services Ltd
For the purposes of data protection law, we will be a controller of your
personal information. (This means we make decisions about how and why
your information is used and have a duty to ensure your rights are
writing to the Data Protection Manager, Wills Tax & Trusts Group,
4 Beech Court, Hurst, Berkshire. RG10 0RQ;
or telephoning 01189 347 920.
2.THE INFORMATION WE COLLECT
In order to operate our business and provide our services, we need to
use personal information about actual and prospective clients and
We collect information from individuals to provide services and to keep
them informed about us.
How we use your information
We will only use your information with your consent, or because we need
to in order to:
- enter into, or perform, a contract with you
- comply with a legal or regulatory duty
- for our own (or a third party’s) lawful interests, provided your
rights don’t override these
- perform a duty of care or protect your vital interests
In any event, your information will only be used for the purpose(s) we
collected it for (or else for a closely related purpose, such as
We would under normal circumstances never sell or trade your personal
information. We do share information with our suppliers, and this may
include personal information in some cases, but they will only be
allowed to use the information for a specific purpose and there will
be a written agreement which makes sure your information is
We will also share personal information with professional advisers,
intermediaries or when we are required to do so by law or by a
regulator or governmental authority (for example HM Revenue and
Customs or the Financial Conduct Authority).
In certain limited circumstances, we may collect or process sensitive
personal information (such as information about someone’s health).
In the event that we do, we’ll ensure that this information is kept
private and secure. We will collect some sensitive data about company
directors and officers as part of our due diligence process.
3.CLIENTS AND POTENTIAL CLIENTS
For contacts on our mailing lists, the personal information we hold is
likely to be limited to your name and contact details
Clients and prospective clients expect us to provide accurate and relevant
advice. To do this professionally, we often obtain very detailed
information of their financial and personal circumstances. This may
or may not include details of their extended family – depending on
the services or nature of advice we are requested to provide.
For business contacts ie directors of companies only when you instruct us
to provide services then we shall also process financial information
in order to provide you with investment services.
We collect information about individual investors in order to provide
our services, administer accounts and make investments. This
information will include:
- basic personal information and contact details
- personal information about beneficiaries and next of kin
- security information (to enable us to identify individual account holders and
- information about their account with us, their investments and transactions
- financial data (such as bank account details and national insurance numbers)
which we require to process payments and invest money on our
5. BUSINESS CONTACTS, PROFESSIONAL ADVISERS AND INTERMEDIARIES
We often work with other businesses. These might be intermediaries,
professional advisers or other businesses with whom we choose to
partner in relation to events or initiatives. We collect information
about individuals working with or for these businesses, including
names and contact details, and information about someone’s role in
a business (such as their job title).
6. OUR WEBSITE AND COOKIES
We don’t collect or process personal information about visitors to our
website unless they choose to provide information (such as when
signing up to a mailing list).
We may collect non-personal information about visitors to our website as
this helps us optimise and improve the website. This information
might include your internet protocol address, the browser being used
to connect to our site, the device (e.g. its operating system) and
the connection type (e.g. the Internet service provider used).
However, none of this information will directly identify you.
Our website may use “cookies” to enhance your experience and enable
certain functionality (such as making any log in processes easier).
Web browsers place cookies on hard drives for record-keeping purposes
and sometimes to track information (such as repeat visits). You can
when cookies are being sent. However, if you refuse to allow cookies,
this may interfere with your ability to use the site.
Our website also uses Google’s AdWords remarketing service. This means
that if you visit our website, you may see adverts for Oxford Capital
when you visit other websites. This happens because Google places a
cookie on your machine based on which pages you visit on our site,
and then uses that cookie to show you relevant advertisements when
you visit other sites. This remarketing process does not involve
collecting or storing any of your personal data.
Ads Settings. Alternatively, you can-opt out of Google and
third-party cookies by visiting the Network
Advertising Initiative opt-out page.
Hyperlinks to other sites
Our website may contain hyperlinks to third-party websites. We are not
responsible for the content or functionality of any of those external
websites. If an external website requests personal information
from you (e.g. in connection with an order for goods or services),
the information you provide will not be covered by this Policy. We
any personal information.
We may contact you by email, telephone or post with information about
investment products or services that might interest you (see
‘Marketing’ below), updates or information about your account or
investments, or to notify you of changes to our terms of business or
If you are an existing client, we’ll send you marketing communications
about similar products or services that may be of interest, unless
you ask us not to or decide to unsubscribe.
Email and SMS marketing
We will only contact an individual personally with email marketing
communications if that individual is an existing customer or if he or
she has asked to receive marketing or enquired about a particular
service. If you would like to opt-in to marketing you can do so on
We sometimes send emails to business customers, contacts, intermediaries
and professional advisers without their prior consent, which we do in
order to promote our services and build relationships. If we have
contacted you, it will be because we think these communications may
be of interest or relevance to you on the basis of our previous
dealings with you or a recommendation from a third party.
Our marketing emails will always tell recipients why they are receiving
that email and give them the option to unsubscribe.
Our marketing communications are either sent directly by us or using the
MailChimp email marketing platform based in the USA (and for further
information about how we ensure your data is protected when it is
transferred to the USA please see ‘International transfers’
Telephone and Post
We may record telephone conversations, video calls or any other
electronic communication and retain copies of them, as well as any
transcripts and any written or electronic communication we have with
you. These will be used for the purpose of administering your
account, training, evidencing compliance with regulatory
requirements, evidence in the event of a dispute, or as evidence in
Changing your preferences or unsubscribing
You can change how you hear from us or unsubscribe from marketing at any
time. You can do this by clicking the “unsubscribe” link on any
of our emails, or by writing to the Data Protection Manager, Wills
Tax & Trusts Group, 4 Beech Court, Hurst, Berkshire. RG10 0RQ;
or telephoning 01189 347 920 with details of your request.
You can also
contact us using these details if you wish to complain about a
marketing communication you have received in error.
8. STORING YOUR INFORMATION
We employ a variety of physical and technical measures to keep your
personal data safe and to prevent unauthorised access to, or use or
disclosure of it. Electronic data and databases are stored on secure
computer systems and we control who has access to them (using both
physical and electronic means). Our staff receive data protection
training and we have a set of detailed data protection procedures
which personnel are required to follow when handling personal data.
We cannot absolutely guarantee the security of the internet or external
networks or your own device. Accordingly, any online communications
(e.g. information provided by email or through our website) are at
your own risk.
We only store personal information for as long as it is required for the
purpose(s) we collected it for (or for a related compatible purpose,
such as keeping a record of a transaction). We regularly review what
data we have and delete that which is no longer necessary. In certain
situations, you have the right to request that your data be deleted
(the right to be forgotten), please see paragraph 9 for further
If you believe that any information we are holding on you is incorrect
or incomplete, please contact us using the details set out in
9. YOUR RIGHTS
We want you to remain in control of your personal information. Part of
this is making sure you understand your legal rights, which are as
- where data is processed on the basis of consent, the right to withdraw
- the right to confirmation as to whether or not we have your personal
data and, if we do, to obtain a copy of the personal data
- the right to have inaccurate data rectified
- the right to object to your data being used for marketing or profiling,
or on the basis of our or a third party’s legitimate interest
- the right to restrict how your personal information is used
- the right to be forgotten, which allows you to have your data erased in
certain circumstances (though this is not an absolute right and may
not apply if we need to continue using the information for a lawful
If you would like further information on your rights or wish to exercise
them, please write to the Data Protection Manager, Wills Tax &
Trusts Group, 4 Beech Court Hurst Berkshire RG10 0RQ; emailing
telephoning 01189 347 920.
Please keep in mind that there are exceptions to the rights above and,
though we will always try to respond to your satisfaction, there may
be situations where we are unable to do so (for example, because the
information no longer exists or there is an exception which applies
to your request).
If you are not happy with our response, or you believe that your data
protection or privacy rights have been infringed, you should contact
the UK Information Commissioner’s Office, which oversees data
protection compliance in the UK. Details of how to do this can be
found at www.ico.org.uk.
10. UPDATES TO THIS POLICY
We may update this Policy at any time. When we do, we will post a
notification on the main page of our website and revise the updated
date at the bottom of this page. We encourage users to frequently
check this page for any changes to stay informed about how we are
helping to protect the personal information we collect.
This policy was last updated on 18th May 2018