Company Policies
Privacy Policy
Your rights, your information and how we use it
AV Trinity is committed to protecting your personal information. Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us. We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know. This version of our Privacy Policy was last updated in May 2020.
How to contact us
If you have any questions about our Privacy Policy or the information we collect or use about you, please contact:
FAO Data Protection Officer, AV Trinity Limited, Oakhurst House, 77 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS
Email: info@avtrinity.com
Information we collect and use
Information about you that we collect and use includes:
Information about who you are e.g. your name, date of birth and contact details;
Information connected to your product or service with us e.g. your bank account details;
Information about your contact with us e.g. meetings, phone calls, emails / letters;
Information that is automatically collected e.g. via cookies when you visit our website;
Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV);
Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations;
Information you may provide us about other people e.g. joint applicants or beneficiaries for products we advise you on;
Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender).
What are cookies?
A cookie is a small file – it’s saved onto your computer or other device when you visit our website. Cookies store small pieces of information. For example - they will remember you've visited our website or performed a certain action.
We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don't have to keep entering it.
Cookies also let us know which pages of our website you’ve visited; they help us develop our services.
Persistent cookies: These stay valid, and will work until their expiry date (unless you delete them before they expire);
Session cookies: These expire when you close your web browser.
Where we collect your information
We may collect your personal information directly from you or from a variety of sources, including:
An application form for a product or service;
Phone conversations with us;
Emails or letters you send to us;
Meetings with one of our financial advisers;
Registering for one of our events or seminars;
Our online services such as our website and social media ;
One of our professional connections, such as an accountant or solicitor, but only where they have your permission for them to pass us your details.
If you are a member of your employer’s pension scheme which was set up or is serviced in any way by AV Trinity, the information we collect and use will most likely have been provided by your employer on your behalf.
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
You have given us your permission [consent] to send you information about products and services offered by AV Trinity and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you;
It’s necessary to provide the product or service you have requested e.g. if you wish to accept our advice in respect of an investment, we will require some personal information including your name, address, date of birth, bank account details;
It’s necessary for us to meet our legal or regulatory obligations e.g. to tell you about changes to Terms and Conditions or for the detection and prevention of fraud;
It’s in the legitimate interests of AV Trinity e.g. to deliver appropriate information and advice so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products we advise you on and to develop new services; where we use artificial intelligence or computer algorithms to improve the services offered to you;
It’s in the legitimate interests of a third party e.g. sharing information with your Power of Attorney.
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our advice and services.
Who we may share your information with
We may share your information with third parties for the reasons outlined in 'What we collect and use your information for’.
These third parties include:
Your professional representative (such as an accountant or solicitor) or employer;
Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers;
Our regulators and supervisory authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO);
Law enforcement, credit and identity check agencies for the prevention and detection of crime;
HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance.
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA). However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States, New Zealand and India. Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information
We will keep your personal information only where it is necessary to provide you with our services while you are a client.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
Your individual rights
You have several rights in relation to how AV Trinity uses your information. They are:
Right to be informed - You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy.
Right of access - You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request.
Right to request that your personal information be rectified - If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure - You can ask for your information to be deleted or removed if there is not a compelling reason for AV Trinity to continue to have it.
Right to restrict processing - You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability - You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
Right to object - You can object to AV Trinity processing your personal information where: it’s based on our legitimate interests; for direct marketing; and if we were using it for scientific/historical research and statistics.
How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, contact us and we will do our utmost to make things right. If you are still unhappy, you can complain to the Information Commissioner’s Office (ICO).
Ethics & Complaints Policy
We are committed to acting in our client’s best interests. We promise to be open, honest and transparent in the way we deal with you, not place our interests above yours, communicate clearly, promptly and without jargon, seek your views and perception of our dealings with you to ensure that they meet with your expectations or to identify any improvements required.
Sometimes things can go wrong and when they do we promise to investigate and put things right as quickly as possible. We have a transparent and fair complaints policy in place for these situations.
Making a complaint
If you have a complaint or any questions about our Complaints Policy, you can contact us by post, email or by calling us:
FAO Complaints Officer
AV Trinity Limited, Oakhurst House, 77 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS
Email: info@avtrinity.com
Telephone: 01892 612500
What happens when we receive your complaint and expected timescales
We will record your complaint and do everything we can to resolve it quickly.
If we can resolve your complaint within three working days following the day we received it, we will send you confirmation of this and we will let you know about the Financial Ombudsman Service (FOS) at this time.
If we are unable to resolve your complaint within three working days, a written acknowledgement will be issued promptly and no later than five working days of receiving your complaint.
Our acknowledgement letter will outline the next steps and when you can expect to hear from us. We will make every effort to resolve your complaint within eight weeks of receiving it.
If the investigation is still not completed after eight weeks, a further letter will be sent explaining that we are still not in a position to provide a final response. We will let you know why this is the case and provide you with details of the FOS.
Our Final Response
Once we have completed a thorough investigation, we will send you a Final Response in writing. This will outline the details of our investigation, how we reached our decision and what we are going to do to put things right if we believe we have been at fault.
It will also provide information about the FOS.
Financial Ombudsman Service (FOS)
If you do not agree with our resolution of your complaint and you would like to take it further, you can ask the FOS to look into it. This is a free, independent and impartial service that helps resolve disputes.
If you choose to refer your complaint to the FOS, it should be within six months of the date on our Final Response. If you refer your complaint before you have received our Final Response, the FOS will ask for our permission to investigate complaints where:
You have not complained to us first, to give us the chance to put things right.
You have complained to us, but we have not given you our Final Response yet and we are still within our stated timescales.
FOS contact details:
Web: www.financial-ombudsman.org.uk
Email: complaint.info@financial-ombudsman.org.uk
Phone: 0800 023 4567
Post: Financial Ombudsman Service, Exchange Tower, London E14 9SR
Complaints that relate to advice or services provided by another firm
In the event we receive a complaint where we have reasonable grounds to believe that it relates to another firm, within five days of receiving the initial complaint, we will carry out the following:
Positively identify the other firm we believe to be responsible and establish a current address and point of contact.
Write to the firm, enclosing a copy of the original complaint, explaining why we believe they are responsible for dealing with the complaint.
Write to you, explaining the action taken, and enclosing a copy of the letter sent to the other firm.
Equality & Diversity Policy
AV Trinity recognises the positive benefits of the implementation of an Equality and Diversity Policy. The aim of the policy is to ensure that all employees, potential employees, volunteers and visitors are treated in a fair and equitable manner regardless of their age, disability, marital status, family responsibility, race, colour, ethnic background, nationality, religion or belief, gender, gender identity or sexual orientation. We value the differences, needs and contributions a diverse workforce and client base represents.
AV Trinity places an obligation upon all our staff and volunteers to respect and act in accordance with this policy. AV Trinity extends this positive attitude in respect of equality and diversity to our contractors, service users and the community.
AV Trinity believes that equalising employment opportunity not only meets legal and social responsibilities, but also promotes organisational effectiveness and improves the quality of working life. All employees and volunteers whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.
We are committed to inclusion and diversity, and supporting the progression of women at all levels of the business and into senior roles. Two of our three Executive Director roles, including that of our Managing Director, are held by women. We are proud of the fact that we do not contribute negatively to the gender pay gap and that all our employees’ salaries are equitable when comparing those in the same roles, regardless of gender.
Intellectual Property Rights
We are the owner or the licensee of all intellectual property rights in our website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You may print off one copy, and may download extracts, of any page(s) from our website for your personal use and you may draw the attention of others within your organisation to content posted on our website.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Our status (and that of any identified contributors) as the authors of content on our website must always be acknowledged.
You must not use any part of the content on our website for commercial purposes without obtaining a licence to do so from us or our licensors. If you print off, copy or download any part of our website in breach of these terms of use, your right to use our website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.