The data we collect about you and how we use it will depend on your relationship with us.

Who are we?

England & Company is the trading name of Kynance Ltd, incorporated and registered in England and Wales, company number 4521252.

What data do we collect about you?

We generally collect data from you directly, but we may also collect data from third parties such as:

• Our clients, including if our client is your employer
• Our professional advisers, your professional advisers and other service providers
• Associates of yours, including family members, colleagues and your connections
• Publicly available sources, such as social media
• Third party data providers and marketing companies
• Your agents and representatives, such as your power of attorney

The data we collect and for what purpose will depend on who you are and the nature of the relationship that you have with us. This data may include:

• Basic contact information – this may include your name, email address, telephone number and postal address.  
• Marketing preferences
• Records of your use of our website – if you visit our website, then we will install certain cookies on to the device that you are using.
• Information relevant to your role as trustee or beneficiary – this may include details of your financial circumstances, the benefit that you may be entitled to and other information such as trust deeds and trust minutes.
• Records of communications that you have with us – if you contact us or we contact you e.g. by letter or email, then we will retain records of such correspondence.
• Other information that you provide to us voluntarily

For what purpose do we use data about you, and on what legal basis?

Throughout the duration of our provision of our services to you, we may use data about you for the following purposes:

• To communicate with you, such as in the course of a commercial relationship between us and your employer
• To send you marketing communications, such as via email or post
• To create and manage records of your involvement with us
• To comply with our legal and regulatory obligations
• To share your data with relevant third parties
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

The legal basis for our use of data about you is one of the following, the processing of your data is necessary for:

• The performance of a contract to which you are the party;
• Compliance with a legal obligation to which we are subject; or
• A legitimate business interest that is not overridden by your interests, rights and freedoms which require protection

Where none of the above conditions apply, we will ask for your consent to process the data.

Who do we share your data with and for what purposes?

We may share data about you with:

• Third parties who provide us with products or services
• Other third parties where required or permitted by law

Where might data about you be sent?

It may be necessary for us to transfer data outside the country or territory where it was collected, including to a country, territory or international organisation that may not have the same data protection standards.

How do we protect data about you?

We implement appropriate technical and organisational measures to protect personal data that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the data you provide. We also require our service providers to comply with strict data privacy requirements.

How long will data about you be kept?

We store data in accordance with legal, regulatory, financial and best-practice business requirements. Once our relationship with you ends, we will securely delete/destroy your data in line with our data retention policies.

What rights and options do you have?

You may have the following rights in respect of data about you that we hold:

• Request us to give you access to it
• Request us to rectify it, update it, or erase it
• Request us to restrict our using it, in certain circumstances
• Object to our using it, in certain circumstances
• Withdraw your consent to our using it
• Data portability in certain circumstances
• Opt out from our using it for direct marketing
• Lodge a complaint with the supervisory authority in your country

You are able to exercise these rights by contacting us using the details set out below.

Who should you contact with questions?

If you have any questions, or wish to exercise any of the rights detailed above, please contact Daniel Whitcher at daniel@englandcompany.co.uk or on 01202 880384.