Privacy notice

Embark Platform is a trading name of Embark Investment Services Limited, a company incorporated in England and Wales (company number 09955930). The Embark website (embarkplatform.co.uk) is therefore brought to you by Embark Investment Services Limited (“We”).

The Embark Platform Privacy Notice applies to customers and prospective customers of Embark Platform (a trading name of Embark Investment Services Limited, a wholly owned subsidiary of Embark Group Limited). This details how we will collect and process the personal data that we hold about you and your rights under the Data Protection Act in respect of the data held.

Embark Investment Services Limited  will be the Data Controller as defined under UK Data Protection legislation and regulations.

The lawful basis and purpose for the processing of your data

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 us
• Where processing is necessary for the performance of a contract between you and us or to take steps to enter into a contract;
• Where processing is necessary for compliance with a legal or regulatory obligation
• Where we have 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.

The information that we collect

We will collect personal data from you at the outset of your relationship with us, from your application as well as from other third parties such as your financial adviser and any providers that are transferring money or assets to us on your instruction. We will also collect personal data from you and other third parties you instruct on your behalf throughout the course of your relationship with us. This personal data will include;

• Contact information such as name and address, telephone numbers and email addresses
• Information from your contact with us, voice recordings from telephone calls, letters and emails.
• Socio-demographic information; age, employment status, profession, earnings, gender, other sources of wealth
• Family circumstances information; marital status, beneficiary information
• Transactional information; account transactions, access to our online client portals
• Legal; national identifiers, copy documents relating to your identity, nationality and citizenship such as birth certificate, passport, proof of address documents, marriage certificates.
• Special category data if necessary, such as information relating to your health, such as medical conditions and disabilities.

Sharing your personal data

We may disclose your personal data to other companies within the Embark Group of companies as well as companies in Lloyds Banking Group, we may also share your personal data with third parties which provide services in connection with the administration of your account.

We may also share your personal information for legitimate business reasons or as may be required by applicable law and regulations with your Financial Adviser, third parties appointed by your Financial Adviser, third party investment managers, and product providers with whom you or your Financial Adviser instructs us to invest.

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 use it for any other purpose or pass your details to any third parties without your consent.

Retention of your personal data

We will retain your personal data for no longer than is necessary to provide the services under the Terms and Conditions applicable to the account and to meet any legal or regulatory obligations that may apply.

Your Data Protection Rights

You have a number of rights under the 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.

Important Information

If you have any questions regarding howwe use the data that we collect please contact:

The Group Data Protection officer
The Embark Group
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 at https://ico.org.uk/for-the-public/

By signing our product application form, you consent to the use of your Personal Information for the purposes and on the terms set out above. You have the right to withdraw consent at any time.

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 also allows us to improve our site.

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.

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to marketing@embarkgroup.co.uk.