We take privacy very seriously and therefore urge you to read this notice very carefully as it contains important information about the data we collect about you, what we do with that data and who your data will be shared with. By consenting to us processing your personal data, you are giving us permission to perform the actions referred to in this notice. If you do not wish us to continue to process your data, you must inform us immediately.
Under the EU General Data Protection Regulation, personal data is defined as:
“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The EU General Data Protection Regulation, which applies from 25th May 2018, gives people more control over how their personal data is used. The Regulation sets out your rights as an individual regarding how your personal data is collected, used and stored, including your rights to have data corrected or removed. We take the privacy and security of your personal information very seriously and are committed to protecting and respecting your privacy.
This notice sets out the purpose for which personal data that LTV Group S.A. and any entity listed below collects from you, or that you provide to us, will be processed by us. This policy covers data you may provide to us via the website only, when you are not an existing client or have a relationship with us.
We provide additional details to our clients regarding how we handle their personal data in separate Data Protection Notices, which overrides the provisions of this policy. If you are an employee, further details will be provided in your employment documentation about your data protection rights. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.
Under the EU General Data Protection Regulation, you have the right to obtain:
- Confirmation that your data is being processed
- Access to your personal data
- Other supplementary information
This is so that you can verify if necessary, the lawfulness of the processing.
LTV Group S.A. (Data Controller) is a financial advisory company with pan-European ambitions. We currently own and run two award-winning IFAs – Harpsden Wealth Management and Create Financial Management. Our business model is to acquire profitable existing IFAs and then growing them further, leveraging our sector know-how and single-minded focus on client needs.
LTV is currently operating companies in the UK and is also evaluating additional acquisitions in both the UK, but also in many other European countries.
The company has been established by a team of seasoned veterans within the financial services space. The team can be viewed at: https://ltvaluegroup.com/the-team/
References to “we” or “us” are to LTV Group S.A.
What do we do?
LTV Group S.A. is a financial advisory company. LTV Group S.A currently owns two authorised and regulated UK advisory businesses:
Harpsden Wealth Management Limited is authorised and regulated by the Financial Conduct Authority. Financial Services Register No: 488658
Registered in England, No. 6654455 Registered Office: Newtown House, Newtown Road, Henley-on-Thames, Oxfordshire RG9 1HG VAT Registration No: 971 5221 26
Create Financial Management LLP is an appointed representative of TenetConnect Ltd, which is authorised and regulated by the Financial Conduct Authority. TenetConnect Ltd is entered on the Financial Services register (www.fca.org.uk/register) under reference 149826.
Create Financial Management LLP is a Limited Liability Partnership. Registered in England. LLP no. OC305811. Registered Address: York House, Stephensons Way, Wyvern Business Park, Derby, DE21 6LY
LTV Group S.A. act as data controller for your data.
This section details your rights in brief, but should you require further details or you have any concerns about our information rights practices, you can contact the LTV Group S.A’s Data Controller. If we are unable to resolve your concerns, you have the right to refer these to the Information Commissioner’s Office. Full details can be found at: https://ico.org.uk
Your rights under the EU General Data Protection Regulation include:
If you have any concerns about LTV Group S.A. or associated companies processing your personal data you must inform us prior to its collection or as soon as possible thereafter.
What type of personal information will be processed?
- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together.
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Uses made of the information
We use information held about you in the following ways:
Information you give to us
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to notify you about changes to our service; and
- to ensure that content from our Site is presented in the most effective manner for you and for your computer.
Information we collect about you
We will use this information:
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so; and
- as part of our efforts to keep our Site safe and secure.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give authorisation on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.
When we record communications
We, and persons acting on our behalf, may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, instant messaging, chat rooms, fax and other electronic communications) between our staff and you. We only record communications between us in order to comply with our legal and regulatory requirements where we are required to and we will notify you in advance prior to any recording.
Who might my personal information be shared with?
We may disclose your personal information to the following categories of recipients:
To our suppliers and partners to help us provide our services to you, this includes:
- our IT systems providers to assist us with providing you with an efficient, modern and professional service;
- our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
- our bankers, financial backers, accountants, solicitors, insurer(s) and insurance broker(s) and any other provider of professional services to us;
To Credit Reference Agencies and Fraud Prevention Agencies to help us make the best possible assessment of your financial situation before we decide whether we can provide you with services. We are also required to provide information to such agencies so that they can update the information which they hold about you and which they may share with other organisations;
- to other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
- to the following group companies of ours for the purpose of:
- LTV Group S.A. with whom information is shared for the purposes of assisting us with performing a contract that we have entered into with you or to take steps to enter into such a contract;
- to a prospective buyer (and its agents and advisers) in the event we intend to sell any part of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your personal information could form part of one of the assets we sell, provided that we inform the buyer it must use your personal information only for the purposes described in this Notice. We will never rent or sell your personal information other than as part of a sale of our business;
- to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary
- as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC),
- to exercise, establish or defend our legal rights, or
- to protect your vital interests of those of any other person; and
- to any other person with your consent to the disclosure or where we are permitted to do so by law.
Our legal basis for processing personal information
Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the ‘What type of personal information will be processed’ and ‘Uses made of the information’ sections above.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you or with your explicit consent, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with our own standards, this Notice and applicable law.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent, please see the “Your consent to us processing your special category personal data” heading below.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
In some circumstances you can ask us to delete your data: see above for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Using our website
We may use “cookies” to keep track of your visit to our website and give you a better browsing experience. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our website.
Social media widgets and applications
Our website may include functionality to enable sharing via third party social media applications, such as the Facebook Share button and Twitter widget. These social media applications may collect and use information regarding your use of our site. Any personal information that you provide via such social media applications may be collected and used by that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
Links to external websites
Our site may, from time to time, contain links to and from the websites of our partner firms or other business links. 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 or how such websites collect and use your data. Please check these policies before you submit any personal data to these websites.
Updates to this Notice
We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
How to contact us
If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please contact The Data Protection Manager at email@example.com.
LTV UK Holdings Ltd.
York House, Stephenson’s Way
Wyvern Business Park, Derby DE21 6LY
LTV Group S.A.
1, Avenue de la Gare, L-1611 Luxembourg
Phone: +352 2088 1783
LTV Group S.A. Vienna Branch Office
Kohlmarkt 8-10, c/o Regus
A-1010 Vienna, Austria
Phone: +43 1 22746 1000
November 2019 – version