Privacy & Cookies Policy for www.Lowes-sic.com

Thank you for visiting our website. We respect your privacy and protecting your information is paramount. Please read this Privacy Policy carefully before using our website or registering to use our services to understand our views and practices regarding your personal data and how we will treat it. This Privacy Policy together with our Cookies Policy sets out the basis on which any personal data will be processed by us.

By visiting Lowes-SIC.com you are accepting and consenting to the practices described in this Privacy Policy. By submitting your data to us, it is implied that you have given us your permission to use your data under the terms of this policy.

Changes to our privacy policy

Our Privacy Policy is updated from time to time, so please check our website regularly to ensure you are fully up-to-date with how we deal with the information you have provided to us.

Who we are

Lowes Structured Investment Centre is a trading style of Lowes Financial Management Limited. In connection with the EU General Data Protection Regulation, the data controller responsible for handling your personal information is Lowes Financial Management Limited. Lowes Financial Management Limited is a limited company registered in England & Wales whose registered number is 01115681 and whose registered address is at Fernwood House, Clayton Road, Jesmond, Newcastle upon Tyne, NE2 1TL. Lowes Financial Management Limited is registered with the Information Commissioners Office under number Z5427259.

You can check our registration on the Data Protection Public Register by clicking here

References in this Privacy Policy and on our website to “we”, “our” or “us” are references to Lowes Structured Investment Centre. References to “you” and “your” means each natural or legal person who uses our website or the associated services.

Your Information

Information you give us

The information that we hold may be supplied by you directly to us when you register with our website www.Lowes-SIC.com (our website) or by communicating with us by telephone, e-mail or face to face meetings. This includes information you provide when you subscribe to our services, participate in discussion boards or other social media functions on our website, provide us with feedback, participate in surveys, and when you report a problem with our website. The information you give us may include the following; -

your name and title, address, email address and phone number
the content of any enquiry submitted over our website

We class this as being 'personally identifiable information', which means it can be used to identify you, personally.

Information we collect about you

We will use this information:

to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
to improve the service, we offer you and to try and ensure that you get the best from our website, ensuring that content is presented in the most effective manner for you and for the devices you use to access it;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our website safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our website about services that may interest you or them.

Information we may collect about you

We may collect and process information about you through various means, including:

via our website (e.g. on our ‘Contact Us’ page or when submitting your email address to request a brochure.)
otherwise through providing our services or operating our business.

We may also collect the following information from you automatically when you visit our website:

technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as clicks, and page-view duration), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers) and may receive information about you from them.

Cookies

A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We may monitor or record telephone conversations or other communications between you and us. We will use these recordings or transcripts of them to check your instructions to us, analyse, assess and improve our services to clients, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.

Why we need your details

We use information that you give to us or we collect from other third parties on your behalf as part of our services. We will use this information to:

provide you with the information and services that you request from us;
provide you with information about other services we offer that are like those that you have already acquired or enquired about;
provide you with information about or services we feel may interest you or be best for you;
notify you about changes to our services;
ensure that content from our website is presented in the most effective manner for you and your device; and
aggregate it on an anonymous basis with other data for data analytical and reporting purposes.

Lawful grounds for processing your information

We will rely on the following legal bases under European Data Protection Legislation for processing your personal data:

Compliance with a legal obligation to which we are subject.

We have a legitimate interest in doing so as a financial services provider (and where our legitimate interests are not overridden by your (or the relevant individual’s) own interests or fundamental rights or freedoms). These legitimate interests will include our interests in managing our relationship with our clients, administering visits to our offices and ascertaining achievement of proper standards/ compliance with policies, practices or procedures. We may also act on legitimate interests in processing your information to improve our products and services. We may periodically send promotional materials by email about new products or services, special offers or other information which we think you may find interesting.

Who your data can be disclosed to

Disclosure of your data to others may be necessary to ensure the smooth provision to you of services and information you request. Your data may be disclosed to the other entities as described below.

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties including:

Advertisers and advertising networks that require the data (in an aggregated format whereby individuals cannot be individually identified), to select and serve relevant adverts to you and others and to make sure their adverts reach their intended audience (for example, by telling them how many women or men have clicked on an advert); and
Analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may disclose your personal information to third parties if:

Lowes Financial Management Ltd or substantially all its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets; and
We are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Lowes Financial Management Ltd, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
If you register to use any of our services, which requires us to source information from a service provider we may, in accordance with our terms share your personal data with such service providers to provide these services to you.
Your personal data will not be sold, distributed or leased to third party organisations unless we are required to do by law or we have received your consent to do so.

We have processes and systems that protect our clients and ourselves against fraud and other crime. Information can be used to prevent crime and trace those responsible. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information.

Sending your information outside of the EEA

If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) (e.g. a professional advisor or third party engaged by us or you as part of our work under an engagement letter) for example where the transfer is necessary to perform a contract in place with you, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.Where we store your data

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep these details secure and free from unauthorised access, loss or damage by use of technology and internal systems and controls. We will update the technology and our internal systems as new technology becomes available and is appropriate to our systems.

How long we keep your information for

How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for those purposes and in accordance with our statement of service.

Third party websites

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Your information rights

You have a right to be informed about the collection and use of your personal data. We provide you with this information within this document entitled Privacy Policy.

European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.

You can access the personal information we hold on you by writing to us at: FAO: Data Protection Officer, Lowes Financial Management Limited, Fernwood House, Clayton Road, Jesmond, Newcastle upon Tyne, NE2 1TL. You can also contact us by email at enquiry@Lowes.co.uk.

You have the additional rights to request rectification and erasure of your personal data and to request restriction of, and to otherwise object to, our processing of your personal data and you can exercise these rights at any time by contacting enquiry@Lowes.co.uk. There may be instances when we cannot delete your data for legal, regulatory or technical reasons.

Where technically feasible, you will also be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise this right by contacting us at enquiry@Lowes.co.uk.

You have a right relating to automated decision making and profiling. We will only carry out this type of activity if it we have an acceptable lawful basis for doing so and if certain conditions apply. You have the right to object to profiling.

Right to be informed

You have a right to be informed about the collection and use of your personal data. Our Privacy notice provides information explaining our purposes for processing your personal data, our retention periods for that personal data, and who it will be shared with. We call this ‘privacy information’.

We will regularly review, and where necessary, update our Privacy Notice. Please check our website regularly to ensure you are fully up-to-date with how we deal with the information you have provided to us.

Right of access

You have the right to access your personal data and supplementary information. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.

We will ask you to provide proof of identity before we show you your personal information – this is so we can prevent unauthorised access.

Information will be provided within one month of receipt of a request and an initial request for your personal data will be responded to free of charge.

Please note: For any access request made that is deemed excessive or especially repetitive, we may charge a ‘reasonable fee’ for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. (That fee will be based upon the administrative costs of providing the information).

Right to rectification

You have the right to have inaccurate personal data rectified or completed if it is incomplete. If you have any concerns about the accuracy or completeness of your personal data, you can raise these with us either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: For any access request made that is deemed unfounded or excessive, we may charge a ‘reasonable fee’ for the administration costs of complying with the request.

Right to erasure

You do not have an automatic right to have personal data deleted, however, this right may apply in the following circumstances; -

your personal data is no longer necessary for the purpose which we originally collected or processed it for;
you have withdrawn your consent and we have no other lawful ground for processing your data;
you object to the processing of your data, and we have no overriding legitimate interest to continue this processing;

you object to the processing of your data for direct marketing purposes;
we have processed the personal data unlawfully
we need to erase your data to comply with a legal obligation; or
we have processed the personal data to offer information society services to a child.

There may be occasions when we are unable to delete records due to our regulatory obligations or legal responsibilities.

If you believe we should erase your data, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: For any access request made that is deemed unfounded or excessive, we may charge a ‘reasonable fee’ for the administration costs of complying with the request.

Right to restrict processing

You do not have an automatic right to have personal data restricted or suppressed, however, this right may apply in the following circumstances; -

you contest the accuracy of the personal data we hold for you and you have requested that we verify the accuracy of the data;
if the processing of your data is unlawful and you have opposed erasure and requested restriction instead
we no longer need the personal data, but you may need us to keep it to establish, exercise or defend a legal claim; or
you have objected to the processing of your data and we are considering whether we have overriding legitimate grounds.

If you would like us to consider restricting or suppressing your data, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: We may refuse to comply with a request for restriction if we believe the request is unsupported or excessive, taking into account whether the request is repetitive in nature. Alternatively, we may request a reasonable fee to deal with the request. We will base the reasonable fee on the administrative costs of complying with the request. If we decide to charge a fee we will contact you promptly to inform you.

Right to object

You have the right to object to:

processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
direct marketing (including profiling); and
processing for purposes of scientific/historical research and statistics.

We will stop processing personal data based on legitimate interests unless:

we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or
the processing is for the establishment, exercise or defence of legal claims.

We will stop processing personal data for direct marketing purposes as soon as we receive an objection and this request will be processed free of charge.

You can exercise your rights to object at any time by contacting enquiry@Lowes.co.uk.

Right to data portability

You have the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services. This right may apply in the following circumstances; -

you have provided the personal data to us
where the processing has been carried out based on your consent or for the performance of a contract and
where the processing is carried out by automated means.

If you would like to request a transfer of data to another organisation, you can ask us to do so either verbally or in writing.

We will respond to a request without undue delay and within one calendar month of receipt.

Please note: We may be unable to transmit the data directly to another organisation if this is not technically feasible.

Rights relating to automated decision making including profiling

You have a right relating to automated decision making and profiling. We will only carry out this type of activity if it is; -

necessary for the entry into or performance of a contract
authorised by law
based on your explicit consent.

In addition, if we do carry out profiling, the following conditions will apply; -

we will use appropriate statistical procedures for the profiling
implement appropriate technical and organisational measures to enable inaccuracies to be corrected and reduce errors; and
secure personal data in a way that is proportionate to the risk

You have the right to object to profiling as explained above.

You can exercise this right to object at any time by contacting enquiry@Lowes.co.uk.

Marketing

Who is collecting my data?

Lowes-SIC.com collects data to operate effectively and provide you with the best experiences about our services, which collects data to communicate with you to improve your experience. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

What potential ways is data used for marketing purposes?

to provide products and/or services requested by you;
to administer surveys.
to conduct analysis and market research, for example, to identify trends in the use of our services so that we can:
improve the service we provide to you;
improve our business;
keep you up to date with relevant products and services
to comply with applicable laws, regulations and/or codes of practice;
to support research and analytics that assist us in marketing our products and services
to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

Withdrawal of consent for direct marketing

We offer you the opportunity to receive information from us. If you have chosen to receive direct marketing information from us, we will normally send this by email if we have your email address but may choose to contact you via other methods such as post or telephone.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be told how to unsubscribe.

If you consented to receive marketing communications when you registered for our website or services, you can tell us that you do not wish to receive any more by writing, with your full name, address and other contact details (to enable us to find your records), to:

Lowes Structured Investment Centre,

Fernwood House,

Clayton Road,

Newcastle upon Tyne,

NE2 1TL

Complaints

If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.

You also have the right to make a complaint to the Information Commissioner’s Office. For more details please visit the ICO website at ico.org.uk.

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to enquiry@Lowes.co.uk.

If you require any further guidance on updating the details we hold about you, please contact us at: enquiry@Lowes.co.uk.

This Privacy Policy is effective from 25 May 2018.

Cookies Policy

Lowes-SIC.com uses cookies for a variety of purposes, including ensuring that our website functions as expected, remembering your preferences and gathering data on the users of our website and our services.

By using our website (through any device) you agree that this Cookies Policy, together with our Privacy Policy and Statement of Service, applies to that use.

We are committed to protecting you and any information (anonymous or otherwise) that we collect about you online. This section tells you about how and why we use cookies, and how this allows us to improve our service.

If you wish to use our website, but would like us not to set cookies in your browser, you can disable or remove the cookies. Details on how to do this are set out below. Please note that disabling or removing the cookies we or our third party service providers set may impact the functionality and security of our website and our ability to provide our services to you. Please note that you will not be able to use our website if you do not accept our use of cookies.

We reserve the right to make changes to our Cookies Policy. Any changes we may make to our Cookies Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Cookies Policy. Your continued use of our website is taken as your agreement to any such changes.

About cookies

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Your web browser (such as Internet Explorer, Mozilla Firefox, Google Chrome or Safari) then sends these cookies back to our website [or application] on each subsequent visit. Cookies do not contain any information that personally identifies you.

We and our reputable third party service providers use the information we obtain about you through the use of cookies for the following purposes:

(a) To recognise your device(s) when you visit our website;

(b) To remember if you’ve set any preferences on our website;

(d) To test new content and evaluate its effectiveness;

(e) To remember if you’ve been informed of our Cookies Policy, Privacy Policy and other Terms;

(f) To track you as you navigate our website (including tracking page usage and paths used by visitors through our website; and tracking use of our Internet banner advertisements and other links from our marketing partners’ websites to our website);

(g) To improve our website’s usability;

(h) To allow you to share pages with social networks such as LinkedIn, Facebook and Twitter / to support social media components, like Facebook or Twitter (where our website uses a plugin from these third party platforms);

(i) To ensure you don’t miss information that is relevant to you (including targeting our website content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites);

(j) To analyse use of our website (including for statistical analysis, sales and marketing research). To stop us setting these cookies you will need to set up your browser to reject all cookies (see further below).

We may also combine this web usage data with other information we have collected about you. We store this information so that we have a better and more specific understanding of the way users are using our website, and their preferences and interests, for the purposes set out above.

Cookies may be either “persistent” cookies or “session” cookies, depending on how long they are used.

Persistent cookies remain on your device after you have closed your browser, and allow a website to remember your actions and preferences. They are activated each time you visit the website where the cookie was generated. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device. They are stored by the browser and remain valid until their set expiry date (unless deleted by the user before the expiry date).

Session cookies only last for the duration of your visit and are deleted when you close your browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.

Many of the cookies we use are session cookies. For example, they help us to ensure the security of your session, and can also keep you signed in to your Lowes Financial Management accounts while you move between pages.

More about the cookies we use

Whether a cookie is a first or third party cookie depends on which website the cookie comes from. First party cookies are those set by or on behalf of the website visited. All other cookies are third party cookies. We use both first party and third party cookies. You can read more about them below. Third party cookies: In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above.

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website such as your Lowes Valuation Report Login.

Performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Analytics cookies: In order to keep our products and services easy to use and up-to-date, we use web analytics services to help us understand how people use our website. For example we can see which parts of our services are most popular, identify when errors occur and test different versions of a page or feature to see which one works best. These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as “web beacons” or “tracking pixels” that may be included in the digital products and services on our website. These are used for example to count the number of times something has been seen. These web beacons are anonymous and do not contain or collect any information that identifies you.

Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We use retargeting and online behavioural advertising to market Lowes Financial Management which employs targeting cookies to deliver you more targeted advertising.

By using our website, you agree that we can place the above types of cookies on your device.

Cookies we use

Below is a full list of the cookies we use together with a description of what they are used for.

Lowes-SIC.com

ASP.NET SessionId

This is a cookie placed to register your preferences in regard to our cookie policy, this will expire after 30 days. If you chose to login to any of our services, a second cookie will be placed so that your browser can remember that you are logged in. For security purposes, the second cookie will expire when you close your browser.

UMB_UCONTEXT, UMB_UPDCHK

Our website is built using a content management system called Umbraco. This uses cookies to store non-identifiable configuration information to improve your experience and display content.

XSRF-TOKEN

This is a cookie used to identify if anyone is using your browser for malicious attacks against our servers and is a preventative measure to safeguarding your information.

__RequestVerificationToken & XSRF-V

This cookie assigns a unique random value to your browser session so it cannot be replicated by unauthorized individuals trying to access your account.

CookiesDirective

This is a script that helps us comply with the Cookies Directive regulations.

Google Analytics and Google Tag Manager

_ga & _gid

These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

Createsend.com

hblid & olfsk

These Cookies are used alongside our email communications to analyse what content is being engaged with. This is to improve the quality and design of our email content to provide the best experience for recipients and to allow us to tailor more relevant content.

Turning cookies off

In all modern browsers you may elect to reject cookies and/or enable do not track features, and we provide instructions on how to do this below. Please note however that by doing so parts of our website may no longer function as expected. For example, if you delete cookies any preferences they record will be lost. This includes for example where you have opted out from cookies, as this requires an opt-out cookie to be set.

If your concerns are based around third party cookies, then we recommend you just reject those cookies, rather than all cookies so that we can still provide you with the functionality you expect.

If you do wish to stop your browser from accepting cookies, see the following pages:

Mozilla Firefox:

http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Internet Explorer:

http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Safari:

http://support.apple.com/kb/PH5042

Contact us

If you have any questions about our cookies or this Cookies Policy, please contact us on enquiry@Lowes.co.uk

Further reading

For more information about cookies see the links below.

Useful information about cookies can be found at: http://www.allaboutcookies.org

The BBC Web Wise guide to cookies:

http://www.bbc.co.uk/webwise/guides/about-cookies

Information on the ICO cookie guide can be found on the ICO website: https://ico.org.uk/media/for-organisations/documents/1545/cookies_guidance.pdf