Privacy Policy

NAVIGATE PRIVACY NOTICE

INTRODUCTION

Some of the third-party service providers we use, including cloud-based technology and approved AI-assisted services, may process personal information outside the UK or European Economic Area (EEA).

Where this occurs, we will ensure that appropriate safeguards are in place to protect your personal information. These safeguards may include transferring data to countries that have been recognised as providing an adequate level of data protection or using UK-approved International Data Transfer Agreements (IDTAs), the UK Addendum to the EU Standard Contractual Clauses, or other lawful transfer mechanisms permitted under UK data protection legislation.

Who we are:

We are responsible for your personal information and are registered with the Information Commissioner’s Office (ICO). Our ICO registration number is ZA584261

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect information about you when you engage us for financial planning, financial advice, investment management, insurance or protection services. This includes personal and financial circumstances and may include special categories of personal data, such as health data, if necessary for our services.

We also collect data to meet our legal and regulatory duties, carry out identity checks, respond to lawful requests from regulators or courts, help prevent financial crime, and manage our business, including quality checks and complaints.

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?

We gather your personal information in several ways, including;

– Directly from you during face-to-face meetings, telephone calls, emails and 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 and meetings

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

We process your personal information to provide the financial planning, financial advice, investment services you have requested, and to meet our legal and regulatory obligations.

Depending on the circumstances, we rely on one or more of the following lawful bases under the UK GDPR:

Performance of a contract – where processing is necessary to provide the services you have asked us to deliver.

Legal obligation – where we are required to process your information to comply with legal or regulatory requirements, including those relating to anti-money laundering, fraud prevention, taxation and Financial Conduct Authority (FCA) rules.

Legitimate interests – where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms. This may include fraud prevention, safeguarding, network and information security, service improvement, internal administration and business analytics.

Consent – where we process special category personal data or where consent is otherwise required by law. You may withdraw your consent at any time, although this may affect our ability to provide certain services.

Our obligations:

To inform you, where appropriate, of the contact details for any Data Protection Officer appointed by us.

To inform you of the recipients or categories of recipients of data.

To inform you of the period for which we propose to hold the data, or where this is not possible, the criteria which we will apply to data retention.

Where you exercise your right to request access to data of which you are the data subject, we will undertake to respond to you within one month of receipt of your request. There will be no charge for this service unless the request is manifestly unfounded or excessive in which case we reserve the right to charge a fee or refuse to respond.

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 use secure, approved AI-assisted technologies to support the delivery and administration of our services. This may include meeting note summaries, document preparation, data analysis, quality assurance, regulatory compliance checks and other administrative or operational processes.

AI is used solely to support our staff and does not replace professional judgement. Our advisers remain responsible for all advice, recommendations and decisions provided to you, and all client-facing outputs are reviewed by an appropriately authorised member of our team.

Where AI tools process personal information on our behalf, we only use providers that meet our security and data protection requirements and have appropriate contractual safeguards in place.

We do not use AI to make decisions about you without meaningful human involvement. Where solely automated decision-making applies under data protection legislation, you will be informed of your rights.

AUTOMATED DECISION-MAKING

Navigate does not make decisions about you based solely on automated processing. All advice, recommendations and decisions involve meaningful human review by an appropriately qualified member of our team.

We may use technology, including AI-assisted tools, to support administrative tasks, data analysis, document preparation and other operational processes. However, these tools do not make decisions on your behalf or replace the professional judgement of our advisers.

Under the UK GDPR, you have rights in relation to solely automated decision-making. If we were ever to introduce processing that resulted in decisions being made solely by automated means and which had a legal or similarly significant effect on you, we would inform you in advance and explain your rights. These include the right to:

request human intervention;

express your point of view;

challenge the decision; and

receive meaningful information about the logic involved in the automated processing.

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 specialist financial planning or pension transfer analysis software;

– Legal and compliance advisers;

– secure cloud-based business systems and client relationship management (CRM) providers;

– secure document management, document signing and communication platform providers;

– approved technology providers, including AI-assisted services, where these are used to support the delivery or administration of our services;

– professional advisers, including compliance consultants, accountants, auditors and legal advisers;

– regulators, government bodies or law enforcement agencies where required by law;

– other organisations where you have instructed us to do so or provided your consent.

Where third parties process personal information on our behalf, we have appropriate contractual arrangements in place to protect your information and ensure it is processed only in accordance with our instructions and applicable data protection legislation.

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 the security of your personal information seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised or unlawful processing, accidental loss, destruction or damage.

These measures include secure IT systems, access controls, encryption where appropriate, multi-factor authentication, staff training, regular security reviews and the use of trusted third-party service providers who are required to maintain appropriate security standards.

Where we engage third-party providers to process personal information on our behalf, we ensure appropriate contractual safeguards are in place to protect your data and require those providers to comply with applicable data protection legislation.

Whilst we take reasonable steps to protect your personal information, no method of transmitting information over the internet or storing data electronically can be guaranteed to be completely secure. We therefore encourage you to take appropriate precautions when sending sensitive information electronically.

HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?

We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including providing our services, complying with legal and regulatory obligations, resolving complaints, establishing or defending legal claims, and meeting the requirements of our professional indemnity insurers.

The length of time we retain your information will depend on the type of service we have provided. Our typical retention periods are:

Investment business: at least 5 years after the end of our relationship, or longer where required by regulation or business need.

Mortgage business: at least 3 years after the end of our relationship.

Insurance business: at least 3 years after the end of our relationship.

Pension transfer and pension opt-out advice: records are retained indefinitely due to the long-term nature of the advice and potential future regulatory or legal requirements.

Where there is a legal, regulatory or legitimate business reason to do so, we may retain your personal information for longer than the periods stated above. Once information is no longer required, it will be securely deleted or anonymised in accordance with our data retention procedures.

POTENTIAL BUSINESS TRANSFERS

In the event that our firm is involved in a merger, acquisition, sale of assets, or other business transaction, your personal data may be part of the assets transferred. Any such transfer will comply with applicable data protection laws, and the receiving party will continue to handle your personal data in accordance with this Privacy Notice, or an updated notice provided at the time of transfer. We will notify you in advance of any such transfer, providing details of the acquiring entity and any changes to how your data will be processed, if applicable.

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

– Request erasure of 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)

– Claim compensation if you suffer harm because data protection law has been broken

MARKETING

We may send you information about our products and services that may be of interest to you, including our monthly newsletter, financial planning insights, market updates and news from the team. If you do not wish to receive this information, you may opt out at any time by emailing unsubscribe@navigateifa.com or by contacting us 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 028 90 769769. 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 are committed to maintaining appropriate governance arrangements to protect the personal information we hold. We have policies, procedures and technical controls in place to ensure personal data is processed securely, accurately and in accordance with applicable data protection legislation.

Our governance framework includes:

oversight of data protection and information security by senior management;

regular staff training on data protection, information security and the responsible use of AI-assisted technologies;

appropriate access controls and user permissions;

regular reviews of our systems, suppliers and security arrangements;

business continuity and data backup procedures; and

incident reporting and breach management procedures to help identify, investigate and respond to security incidents promptly.

We regularly review our policies and procedures to ensure they remain appropriate, effective and aligned with legal, regulatory and industry best practice.

CHANGES TO OUR PRIVACY POLICY

If any provision, or part thereof, of this Privacy Notice is found by any court or administrative body of competent jurisdiction to be invalid, unenforceable or illegal, the remainder of this Privacy Notice will remain in force.

We keep our Privacy Notice 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