Privacy Policy

NAVIGATE PRIVACY NOTICE

INTRODUCTION

This privacy notice explains how we use any personal information we collect about you. Navigate acts as the data controller for your personal information and is committed to protecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and FCA requirements.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect information about you when you engage us for financial planning, financial advice, mortgage advice, or investment management services. This includes personal and financial circumstances, and may include special categories of personal data (e.g., health data) if necessary for our services.

We may also collect information when you voluntarily complete client surveys or provide feedback.

Website usage information is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We use this information to personalise your repeat visits to the site.

INFORMATION ABOUT CONNECTED INDIVIDUALS

We may need to gather personal information about your close family members and dependants to provide our service effectively. If you provide data about another person, you confirm you have their consent. Where appropriate, we may send a copy of this privacy notice directly to those individuals.

HOW DO WE GATHER YOUR PERSONAL INFORMATION?

–          Directly from you (face-to-face, telephone, email, online forms)

–          From other organisations (e.g., investment, pension, insurance providers) with your authority

–          From your professional advisers with your authority

–          From recordings or notes of calls/meetings

WHY DO WE NEED TO COLLECT AND USE YOUR PERSONAL DATA?

The primary legal basis for processing your data is the performance of our contract with you. Some data may be processed under recognised legitimate interests (e.g., fraud prevention, safeguarding, network security, internal analytics). Where special category data is required, we will obtain your explicit consent.

HOW WILL WE USE THE INFORMATION ABOUT YOU?

We use your information to provide the services you engage us for, analyse your financial needs, and ensure our advice is suitable for your circumstances.

USE OF ARTIFICIAL INTELLIGENCE (AL)

We may incorporate Artificial Intelligence (Al) technologies into our advice process. This includes, but is not limited to, the recording and analysis of client meetings to enhance service quality, ensure regulatory compliance, and support accurate documentation. Clients will be informed whenever Al tools are used in their interactions with us, and will have the opportunity to ask questions or opt out of specific Al-enabled features where appropriate.

AUTOMATED DECISION-MAKING

If your personal data is processed by automated means (e.g., credit scoring, eligibility checks). you have the right to:

–          Request human intervention

–          Challenge decisions made solely by automated processing

–          Receive meaningful information about the logic involved

We will inform you when automated decision-making is used and explain its impact.

CHILDREN’S DATA

Our services are not intended for individuals under the age of 18. If we become aware that we have collected personal data from a child without appropriate consent, we will delete it promptly. If you provide information about a child, you must ensure you have the appropriate legal authority or consent.

WHO MIGHT WE SHARE YOUR INFORMATION WITH?

We will only share your information with third parties when necessary, including:

–          Insurance, pension, annuity, and investment providers/platforms

–          Providers of pension transfer comparison reports

–          Legal and compliance advisers

–          Back office systems and third-party software providers

–          Professional compliance, accountancy, or legal services (e.g., Finametrica, CashCalc)

–          Product and platform providers (e.g., Transact)

Where third parties are involved in processing your data, we have contracts in place to ensure confidentiality and purpose limitation. Where necessary, we use appropriate security measures to protect your personal data in transit.

We will not share your information for marketing purposes with other companies.

INTERNATIONAL DATA TRANSFERS

If we need to transfer your personal information outside the UK or EEA. we will take reasonable steps to protect your privacy, including using standard contractual clauses or ensuring the recipient country has adequate data protection laws.

SECURITY AND INTERNET DISCLAIMER

We take steps to safeguard your data against unauthorised or unlawful processing and accidental loss, destruction, or damage. However, internet communications are not guaranteed to be secure, and we cannot accept liability for any damages or loss arising from breaches of confidentiality, GDPR regulations, or non-delivery of messages.

HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?

We retain personal data necessary to provide services to you and to meet regulatory requirements:

–          Five years for investment business

–          Three years for mortgage business

–          Indefinitely for pension transfers and opt-outs

–          Three years for insurance business

We may retain data longer if required by our legitimate interests or PI insurers. Retention is linked to both contract duration and regulatory requirements.

YOUR PRIVACY RIGHTS

You have the right to:

–          Access a copy of your personal information (free of charge)

–          Correct or complete inaccurate or incomplete information

–          Delete your personal information (subject to regulatory obligations)

–          Restrict or object to processing

–          Data portability (move your data to another organisation)

–          Withdraw consent at any time (where processing is based on consent)

MARKETING

We may send you information about our products and services if you have agreed to receive marketing. You may opt out at any time by contacting us at unsubscribe@navigateifa.com or by post.

COOKIES

We use cookies to track visitor use of the website and compile statistical reports. Essential cookies are used without consent under the Data (Use and Access) Act 2025. Non-essential cookies require your consent. You can manage cookie preferences via your browser settings or our cookie banner.

For further information, visit www.allaboutcookies.org.

OTHER WEBSITES

Our website contains links to other websites. This privacy policy only applies to this website. When you link to other websites, you should read their own privacy policies.

COMPLAINTS AND CONCERNS

If you are unhappy with how your personal data is processed, please contact us first at

office@navigateifa.com or [insert phone number]. We aim to resolve complaints within 30 days.

You also have the right to lodge a complaint with the UK’s supervisory authority:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

0303 123 1113 (local rate)

https://www.ico.org.uk

DATA GOVERNANCE AND RESILIENCE

We have internal data governance procedures to ensure the accuracy, security, and resilience of your personal data.

–          Our Data Protection Officer oversees compliance and risk management.

–          We conduct regular data quality checks and backup/recovery testing.

–          All staff receive training on data protection and privacy obligations.

Your Privacy Rights

You have the right to:

–          Access a copy of your personal information (free of charge)

–          Correct or complete inaccurate or incomplete information

–          Delete your personal information (subject to regulatory obligations)

–          Restrict or object to processing

–          Data portability (move your data to another organisation)

–          Withdraw consent at any time (where processing is based on consent)

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and will place any updates on our website.

HOW TO CONTACT US

Please contact us if you have any questions about our privacy policy or the information we hold about you:

–          Email: office@navigateifa.com

–          Website: www.navigateifa.com

–          Phone: 028 90 769 769

–          Address: studio 3, Strand Studios, 150 Holywood Road, Belfast, BT 4 lNY

CONSENT TO PROCESS SPECIAL CATEGORY DATA

Our website contains links to other websites. This privacy policy only applies to our website. When you link to other websites, you should read their own privacy policies.

PURPOSE OF CONSENT

Navigate IFA Ltd may need to process special category personal data to provide financial planning services. This includes data relating to:

• Health (e.g., for insurance underwriting or suitability assessments)
• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership

This data is considered sensitive under the Data Protection Act 2018 and the UK GDPR.

YOUR CONSENT

By continuing to engage with our services and providing the necessary information, you acknowledge that:

• You have read and understood the Navigate IFA Privacy Notice (www.navigateifa.com/privacy)
• You consent to Navigate IFA Ltd processing your special category personal data for the purposes outlined above
• You understand that you may withdraw this consent at any time by emailing: unsubscribe@navigateifa.com

If you have any questions about how your data is used, please contact us at office@navigateifa.com or 02890 769 769.