Your privacy is very important to us. We promise to respect and protect your personal information and try to make sure that your details are accurate and kept up to date. This privacy notice sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this privacy notice carefully. When using our website, this privacy notice should be read alongside the website terms and conditions.
This privacy notice is published by Intelliflo Ltd (Company No. 05206315) based: Intelliflo Ltd, Wellington House, 60-68 Wimbledon Hill Road, SW19 7PA.
Intelliflo is a technology company that provides business management software to UK financial advice firms through its Intelligent Office (iO) software. Through iO, firms can access Intelliflo’s Personal Finance Portal and Automated Advice services, which enables them to offer online advice solutions to support the traditional, face-to-face advice model. iO is a cloud-based system which enables users to utilise it in a flexible, fluid way. Intelliflo’s open API technology enables developers to interact and build a business management system based upon iO in a liquid manner.
In this privacy notice references to 'we' or 'us' are relating to Intelliflo.
In order to provide our services, we will collect and use data about individuals. This means that we are a 'data controller' and we are responsible for complying with data protection laws.
We have appointed a data protection officer to oversee our handling of personal information. If you have any questions about how we collect, store or use your personal information, you may contact our data protection officer by emailing us at dataprotection@Intelliflo.com.
You are being sent this privacy notice as you are, or were, an Intelliflo product user. We need to process this data in order to keep you informed about Intelliflo's products and service and the UK financial advice sector. We also collect your data so that we may better understand the UK financial advice sector to allow us to develop products and services that best serve the market. Your data is collected and processed under the 'Legitimate interest' lawful basis for processing; specifically to enable Intelliflo to understand the UK financial advice sector such that we can provided tailored content, products and services to the UK financial advice sector.
Intelliflo will also process data that allows us to understand how you do, or did, use Intelliflo services. This will be ascertained from log information or database entries that are, or were, triggered by your engagement with Intelliflo services.
If you are currently a user of an Intelliflo product then much of the processing detailed in this notice will be done under the contractual obligations we have to your firm, or your employer, to deliver Intelliflo services such as the Intelligent Office platform. Your employer will be responsible for declaring Intelliflo, and it's sub-processors, as a processor of your data in the privacy notice they will provided to you under the GDPR.
This section will detail what personal information we collect about you and use to enable Intelliflo to understand the UK financial advice sector such that we can provided tailored content, products and services to the UK financial advice sector.
Intelliflo may process the following types of data relating to you, such as your name, information about the company you work for, your job title and role, contact details (email, mobile number) and other identifiers such as social media details (e.g. your twitter handle) and your FCA register number.
We will not collect any special categories of information on you
We will have received this information from yourself, a colleague of yours, the company you work for, the FCA register, third parties who run industry events where we have been present and you have have registered to attend, or that you have registered for an Intelliflo events. We will then enrich this using DueDil for shareholder data, Companies House for director status, and will sometimes add additional information to our records, or validate the quality of the data we hold, by leveraging GDPR compliant services such as email verification tools or tools that allow us to understand what social media systems you may use.
Additionally Intelliflo use other third parties to provide a number of services not already documented above, these purposes and types of suppliers include:
*Where legitimate interests is stated below this is specifically to enable Intelliflo to understand the UK financial advice sector such that we can provided tailored content, products and services to the UK financial advice sector.
|Purpose for processing||Legal grounds for using your personal information|
|Providing information to you around changes in the financial advice industry||Legitimate interests*|
|Informing you on our yearly conferences||Legitimate interests*|
|Providing information to you about Intelliflo services||Legitimate interests*|
|Providing updates on what you can do to get the best out of Intelliflo services||Legitimate interests*|
|Newsletters to advise you of what is going on with Intelliflo services and the wider industry||Legitimate interests*|
|Responding to any questions or queries you may have for Intelliflo||Legitimate interests*|
From time to time, we may share your personal information with the following third parties for the purposes set out above:
If you would like further information regarding the disclosures of your personal information, please see the "Contact us" section below for our contact details.
The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States in support of transatlantic commerce.
We will transfer some of your data outside of the EEA in the following instances:
|Third party transfers||Safeguards in place to protect your personal data||Purpose||Further information available here|
|FullContact - USA||EU-US Privacy Shield||Contact management solutions||privacyshield.gov|
|Cloudingo - USA||Model Clauses||Allows Intelliflo to manage duplicates of contacts||You can view model clauses by emailing dataprotection@Intelliflo.com|
|Litmos – USA||EU-US Privacy Shield||Learning management system||privacyshield.gov|
|Schedule Once - USA||EU-US Privacy Shield||Meeting booking||privacyshield.gov|
|HubSpot- USA||EU-US Privacy Shield||This is used for marketing and marketing automation||privacyshield.gov|
|Congamerge - USA||EU-US Privacy Shield||Generates initial contract and future contracts||privacyshield.gov|
|Cirrus Insight - USA||EU-US Privacy Shield||Outlook/Salesforce integration||privacyshield.gov|
|Gainsight - USA||EU-US Privacy Shield||Customer success management system||privacyshield.gov|
|Jitterbit - USA||Model Clauses||API transformation platform||You can view model clauses by emailing dataprotection@Intelliflo.com|
|SendGrid - USA||EU-US Privacy Shield||This is used for marketing and marketing automation||Sendgrid - USA|
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in the 'Contact us' section.
We may carry out marketing activities like the below:
You may be contacted about the above marketing activities, in any of these ways:
You can opt out of direct marketing at anytime by clicking 'email preferences' at the bottom of a marketing email we send you.
Intelliflo Ltd will process your personal data for 2 years after your firm ceases to do business with Intelliflo, or your employer deletes your account, if your data is not on the FCA register. If your data is on the FCA register we will process your data for 2 years after your data ceases to be on the FCA register. After this point we will either anonymise or delete the data dependent on what is most appropriate.
Where we are storing information in email, our email retention policy is 7 years - so any information you send us via email would be deleted 7 years after you send it.
Information stored in Salesforce or Netsuite will be stored for 7 years from the point you stop doing business with us.
For further information regarding how long your personal information will be kept, please our contact details in see the 'Contact us' section.
It is important that you understand that at any point while we are in possession of, or processing, your personal data, you, the data subject, have the following rights that Intelliflo is fully committed to upholding.
Your rights include:
You have the right to request a copy of the information that we hold about you.
You have a right to correct data that we hold about you that is inaccurate or incomplete.
In certain circumstances you can ask for the data we hold about you to be erased from our records.
You may object to your data being processed under legitimate interests by emailing dataprotection@Intelliflo.com - please note, this does not mean that Intelliflo has to cease processing as we may have an overriding legitimate interest to do so, despite such an objection.
You have the right to have data you supplied to us transferred to another organisation, in machine readable format.
You have the right to object to certain types of processing such as direct marketing.
You have the right to not have decisions made automatically about you, to be informed if they are made and to have an automated decision reconsidered.
You have the right to withdraw consent if that is the legal basis we are processing your data on.
You have a right to complain to the Information Commissioner's Office if you believe that any use of your personal information by us is in breach of applicable data protection laws and/ or regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk
This will not affect any other legal rights or remedies that you have.
Intelliflo Ltd accepts the following forms of ID when information on your personal data is requested:
Two forms of ID, such as:
Intelliflo may also ask you to prove current or former employment at the firm you are or were working for as we are unlikely to have your home address.
Intelliflo is an ISO27001 certified firm, which means that we have Information Security Management Systems in place, a key control within that framework is our management and risk assessment of suppliers we use. All suppliers that may process your data are subject to rigorous review as part of our ISO27001 supplier management processes.
You may contact our data protection officer if you have any questions about how we collect, store or use your personal information:
Data Protection Officer
60-68 Wimbledon Hill Road
0330 102 8402
We may need to make changes to this privacy notice periodically, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally.
Page updated: 5 June 2020