Privacy Notice

Last updated 19 April 2021

1. Who are we?

This privacy notice is issued by Intelliflo Limited (“intelliflo”, “we”, “our” or “us”). Our registered office is at Wellington House, 60-68 Wimbledon Hill Road, SW19 7PA.

intelliflo is a technology company that provides business management solutions to financial advisors and institutions through our cloud-based platform and services. You can find more information about our solutions and services on our website.

We collect and use data about individuals, and we do so as a controller of that data. This means we determine why and how we collect and use that data e.g. to provide our services or for other reasons, as described in this privacy notice.

We have appointed a data protection officer to oversee our handling of the data we collected. If you have any questions about how we collect or use that data, you may contact our data protection officer by emailing us at dataprotection@intelliflo.com.

2. What is the purpose of this privacy notice?

When we provide our services or otherwise interact with individuals, we collect information about them which constitutes personal data under applicable laws. Personal data means any information about an identified or identifiable natural person. This privacy notice explains how we collect, use, share and protect your personal data. Please read this privacy notice carefully to understand what we do with your personal data. We may change this privacy notice from time to time and then we will make the updated privacy notice available on our website. The date at the top of this page indicates when this privacy notice was last updated. In certain circumstances, we may provide supplemental privacy notices which should be read together with this privacy notice.

Information for applicants seeking a position at intelliflo

If you are applying for a position at intelliflo, whether through the intelliflo website or otherwise, then section 9 of this privacy notice (“How do we process your information during the recruitment process?”) applies to you, in addition to the other sections of this privacy notice as appropriate.

3. When does this privacy notice not apply?

Information for our customer’s clients

If you access our services as a client of our customer (e.g. your financial advisor), this privacy notice does not apply, and your financial advisor’s privacy notice explains how your personal information is used. We will process your personal data only as directed or permitted by our customer. Please contact your financial advisor to obtain a copy of their privacy notice.

Links to other websites

This website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy notice of such websites to understand how your personal information that is collected on that site is used and protected.

4. Whose personal information do we collect?

We collect and process personal data about individuals (data subjects) who may be:

  • A user of our services (e.g. an employee of our customers)
  • A representative of our former, current or prospective customers, partners, or vendors
  • Data subjects who work in or around the UK financial advice sector
  • A visitor to our website
  • A visitor to our premises or facilities
  • Data subjects who are staff of intelliflo’s suppliers or intelliflo’s app store developers
  • Data subjects who have registered for intelliflo's annual customer conferences Any other individual (outside our organisation) with whom we interact (“you”).
  • Data subjects who are applying for a position at intelliflo (please see section 9 for more information) and
  • Any other individual (outside our organisation) with whom we interact (“you”).

5. What personal information do we collect about you, and how?

We may collect and process your name, information about the company you work for, your job title and role, your business contact details (email, mobile number), information about your business relationship with us, your regulatory registration number (if any), information about your use of our services or websites, online identifiers such as social media details (e.g. your Twitter handle) and any other information that we ask you to provide or you choose to share with us.

We may collect and process personal information about you in the following ways:

Information that you give us:

  • By filling in forms on our website e.g. when you submit your personal details in our “Get in touch” forms to ask us to send you or allow you to access information about us, our products and services, or to respond to your requests and questions;
  • By providing your information when using our services; or
  • By interacting with us by phone, email or by other means.

Information that our services, systems and websites may collect about you:

  • Information that allows us to understand how you do, or did, use our services e.g. from log information or database entries that are, or were, triggered by your engagement with our services;
  • If you visit our websites, we may also collect certain information about you and your use of our website by using cookies and similar technologies e.g. IP addresses, domain names, the web browser and operating system used to access our website, your location and browsing history, including the pages visited, the time spent on each page, the time and date of each visit. This information is used to measure the use of our site, improve its content and personalize your online experience, but it would typically not identify you without combining this information with other information we may have about you. Please see oue Cookie Policy for more information about how and why we use cookies and similar technologies, and how you can change your cookie settings, and please note our site does not respond to “Do Not Track” requests;
  • If you contact us (e.g. via email or phone), we may log your correspondence with us; and
  • If you visit our facilities or premises, your visit may be recorded by our CCTV systems for security reasons.

Information about you that we may collect from other sources:

  • From a colleague of yours, or the organization you work for or represent;
  • from publicly available profiles, registers and public and private databases;
  • From our partners e.g. application providers who may integrate their services with our solution;
  • From other third parties who run industry events where we have been present, and you have registered to attend;
  • We may validate the quality of the data we hold, by leveraging third-party services such as email verification tools or tools that allow us to understand what social media systems you may use; and
  • In some circumstances, from authorities and governmental agencies.

6. What are the consequences if you fail to provide us with the requested personal data?

If we ask you to provide us with your personal data to comply with a legal requirement, or to allow us to enter into or perform a contract with you, we will advise you whether you are obliged to provide the personal data as well as of the possible consequences if you fail to do so.

7. How do we use your personal information?

This section of this privacy notice explains for what purposes we use your personal data and on which legal bases we rely, to ensure that we process your personal data lawfully.

The legal bases for our processing are as follows:

  • Our processing of your personal data is necessary to perform a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;
  • Our processing of your personal data is necessary to comply with a legal (or regulatory) obligation we are subject to;
  • Our processing of your personal data is necessary for the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data; and
  • In some circumstances and subject to applicable laws, your consent, however we will make this clear to you at the time of collection of your personal data, and you will have the right to withdraw your consent at any time.
  • We may rely on other legal bases during the recruitment process (please see section 9).

Purpose

Legal Basis

Perform and administer our agreement with you or your organization, and maintain the relationship or otherwise interact with you for day-to-day business purposes e.g. to provide you with support for the service;

  • Performance of a contract;
  • Compliance with a legal obligation;
  • Legitimate interests;

Provide you with updates and training to help you get the best out of our services;

  • Performance of a contract;
  • Legitimate interests;

Respond to any questions or queries you may have for us;

  • Performance of a contract;
  • Legitimate interests;

Better understand your use of our services and the financial advice sector to allow us to develop products and services that best serve our customers and the market;

  • Performance of a contract;
  • Legitimate interests;

Sending you newsletters or other information about us, our or our affiliates’ products and services and the financial advice sector;

  • Legitimate interests;

Log and monitor calls and electronic communications for record-keeping, security, quality, staff training and other business purposes;

  • Performance of a contract;
  • Legitimate interests;

Manage our and our affiliates’ business operations, and for other internal administrative and other business purposes, including to promote, market, distribute and provide our and our affiliates’ products and services to you or your organization;

  • Legitimate interests;

Inform you about our or our affiliates’ products and services, conferences, events, publications, or anything else that you have requested or we think may be of interest to you or your organization, and subject to applicable laws, this information may be provided to you by mail, phone, email, text message, social media or in the form of other digital advertisement and where you receive marketing via email or text message from us, we will tell you in that message how to unsubscribe;

  • Legitimate interests;
  • Consent (in some circumstances);

Conduct business analysis and market research relevant to our or our affiliates’ business;

  • Legitimate interests;

Test, develop and improve our and our affiliates’ products, services and IT-infrastructure, including our websites or systems;

  • Legitimate interests;

Ensure network and information security, and investigate, detect and prevent fraud and other crime;

  • Performance of a contract;
  • Compliance with a legal obligation;
  • Legitimate interests;

Protect our and our affiliates’ interests, including establishing, exercising and defending legal rights and claims;

  • Legitimate interests;

In connection with corporate transactions or restructurings;

  • Legitimate interests;

In some circumstances, to comply with our legal obligations and requests from authorities.

  • Compliance with a legal obligation;
  • Legitimate interests;

If you are a user of intelliflo’s developer platform we will be processing your personal data in order to manage your account(s) registered on our applications. We will also process your data in order to contact you, in relation to intelliflo's developer focused products, for important notifications, feature releases and promotions.

  • Performance of a contract;
  • Legitimate interests;

Any information collected about you from our website, your use of our services or otherwise, can be associated with other identifying information we have about you e.g. from other sources, and we may derive inferences based on that information.

We may aggregate and/or de-identify information about your use of our website and services for our business purposes e.g. testing, product development and improvement activities, or to create business intelligence reports or statistical information about the use of our services.

8. Who do we share your personal information with?

We may disclose your personal information, for the purposes set out in this privacy notice, to

  • A colleague of yours, or other staff within the organization you work for or represent;
  • Our affiliates, our and their vendors, information technology service providers, data analysis and web hosting companies or other third parties who support us or them e.g. in providing our services to you, conducting marketing and CRM activities, and in managing business operations;
  • Our partners (e.g. application providers or developers) who integrate their services with our platform;
  • Our agents, distributors, auditors and consultants; and
  • In some circumstances, the police, courts, governmental agencies and authorities, where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with laws or legal processes, support an investigation or to protect our rights and interests.

We may also disclose your personal data in connection with any proposed purchase, merger or acquisition of any part of our or our related bodies corporate’s business e.g. to a potential buyer and their professional advisers.

From time to time, we may share your personal information with the following third parties for the purposes set out above:

  • FullContact - This allows us to enrich the social media details of data subjects who may have an interest in our products
  • Cloudingo - This allows us to identify duplicates in our data
  • Absorb - This is our learning management system
  • Schedule Once - This allows us to book meetings, it will allow access to diaries and contact details
  • HubSpot - We use this as a CRM to build relationships with clients and conduct marketing activities such as sending emails
  • Marketo - We use this as a CRM to build relationships with clients and conduct marketing activities such as sending emails
  • Sendgrid - We use this to send emails from our system when necessary
  • Salesforce - We use this as a CRM (Customer Relationship Management) system which allows us to manage relationships with clients and conduct marketing activities
  • DocuSign - We use this to generate contracts and allow electronic signing of said contracts
  • Congamerge - We use this to generate contracts
  • Cirrus Insight - We use this to integrate Outlook with Salesforce
  • Jitterbit - We use this to connect our systems together
  • Go Cardless - We use this to process payments
  • Natterbox - We use this as one of our telephone systems
  • LogMeInInc - We use this so that we can use GoToWebinar and GoToMeeting
  • Microsoft Office 365 - We use this for sending and receiving emails
  • Vonage - If you make telephone calls to intelliflo, or someone calls you from intelliflo, details about your phone call will be processed by Vonage.
  • Zoom - If you join a call or demo with someone at intelliflo, your details will be processed by Zoom.

If you would like further information regarding the disclosures of your personal information, please see the "Contact us" section below for our contact details.

9. How do we process your information during the recruitment process?

If you apply for a role at intelliflo, we collect and process information about you to enable the recruitment process to run smoothly. Depending on the relevant circumstances and subject to applicable laws, we may collect information about you as shown in the table below. Please note that the personal data in italics is only collected in limited circumstances where collection of this information is applicable/appropriate:

Category of personal data

Examples

Your personal details, including eligibility to work in the UK

Name; age/date of birth; sex/gender; your signature, including in electronic form; immigration status (whether you need a work permit), visa details; nationality/citizenship/place of birth; health and disability-related information

Your private contact details

Address, email address and telephone number

Your education and employment history

Exam results, employment history and locations of previous employment; details about your current or former role(s) including remuneration, pension and benefits arrangements

Your identification data

A copy of your driving license and/or passport/identity card (or, if not available, birth certificate or a utility bill); social security number (or equivalent in your country) and any other tax-related information; biometric information; information we obtain from background verification checks, including information relating to criminal convictions and offences, and credit checks

Financial-related data

Information we obtain from credit checks, including bankruptcy and court judgments for debt checks

Other

Extra information that you or third parties such as your referees choose to provide to us (including special categories of personal data, as defined below*)

*”Special categories of personal data” means personal data consisting of information such as your racial or ethnic origin, your political opinions or religious beliefs, whether you are a trade union member, your physical and mental health, your genetic and biometric data, data relating to your sex life and sexual orientation, and whether you have or are alleged to have committed a criminal offence. Due to the nature of the special categories of personal data, data protection legislation is much stricter about how such data should be held and processed.

We may collect and process information about you during the recruitment process in the following ways:

Information you give to us:

There are numerous ways that you can share your information with us. These may include:

  • When you make a job application to intelliflo via our website or other recruitment portal;
  • When you register to receive more information from us at a job fair or other intelliflo careers event; or
  • Information you provide to our staff in communications during the recruitment process.

Information about you that we may collect from other sources:

We also receive personal data about you from other sources, such as:

  • LinkedIn and other job sites or from third parties such as recruitment agencies, consultants, and members of our staff who refer you to us;
  • Our internal recruitment team who receive your information;
  • Third party service providers who undertake background checks about you on our behalf;
  • Your referees, past employers, educational institutions, and
  • Twitter or similar sites on which you 'follow' us.

How will we use your personal data during the recruitment process and what is our legal basis for doing so?

This section provides a non-exhaustive list of purposes that we may use your personal data for and the legal bases on which we rely to ensure that we process your personal data lawfully during the recruitment process:

Purpose

Legal Basis

Ensuring the smooth running of the recruitment process and enabling us to make a decision about your suitability for the role:

  • Enabling recruiters to contact you about the role; collecting your data from you and other sources;
  • Storing and transferring your details (and updating them when necessary) on and between our internal recruitment databases and applicant tracking systems, and keeping a record of when you attend an interview or other assessment;
  • Assessing your qualifications for a particular role, including decisions about appointment; enabling our hiring managers to decide whether to make you a job offer;
  • Verifying information we have received, using third party resources where permitted by law (such as psychometric evaluations or skills tests) or through information requests (such as references, background verification checks, qualifications and criminal convictions checks, to the extent that this is appropriate);
  • Informing you of the result of your application, determining the terms on which you will work for us and making arrangements in order to offer you a job;
  • If you are successful in being appointed to a role, transferring your personal data onto our internal HR systems
  • Legitimate interests in hiring appropriate staff;
  • Performance of our intended contract with you (where relevant);
  • Processing relates to special categories of personal data which is manifestly made public by you (e.g. on your publicly accessible social media profile);
  • Compliance with a legal obligation (e.g. where permitted by law we may be required to keep a record of your application in order to comply with immigration laws);
  • Processing special categories of personal data is necessary for the purposes of carrying out our obligations in the field of employment law
  • Consent (in some circumstances);

Retaining your personal data for future roles: If you are unsuccessful in your application for a role with intelliflo, we may retain your application in the event that a suitable role at intelliflo becomes available that we think you may be interested in applying for

  • Legitimate interests in hiring appropriate staff;

Making appropriate adjustments for you: If you suffer from any health conditions or disabilities, we may record details of them so that we can make reasonable adjustments for interviews and other recruitment procedures if required

  • Compliance with a legal obligation;
  • Processing special categories of personal data is necessary for the purposes of carrying out our obligations in the field of employment law
  • Processing special categories of personal data is necessary to assess your working capacity

What are the consequences if you fail to provide us with the requested personal data?

If we ask you to provide us with your personal data to comply with our legal obligations, and you fail to do so, we may not be able to satisfy ourselves that you are suitable for the relevant role. This will mean that we may not be able to progress your application with intelliflo further.

Who do we share your personal data with during the recruitment process?

We may share your personal data during the recruitment process with the following recipients:

  • Our affiliates (including our overseas offices), for example, for internal administrative, regulatory compliance and other legitimate business purposes;
  • Your family and personal representatives, for example, if you are involved in an accident whilst at an interview with us;
  • Individuals and organisations who hold information related to your reference or application to work with us, such as current or past employers, educators and examining bodies, immigration agencies, employment and recruitment agencies and criminal convictions checks providers;
  • Third parties who hold information related to your financial record such as financial organisations, credit reference agencies and debt collection and tracing agencies;
  • Where appropriate, medical professionals such as your GP or an occupational health specialist;
  • Third party service providers who perform functions on our behalf or provide services to us (including pension scheme administrators, external consultants, business associates and professional advisers such as lawyers, auditors, accountants, technical support functions, IT consultants carrying out testing and development work on our business technology systems and psychometric testing providers).

10. How do we protect your personal information?

To seek to protect the security of your personal data, we implement appropriate technical and organisational security measures which include physical and technical security safeguards and a governance model that ensures that adequate policies, procedures and controls are in place within our organisation.

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.

If you are a user of our services, you are responsible for maintaining the secrecy of your user credentials. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us.

11. How do we protect your personal information when sending it abroad?

Your personal data may be transferred to countries outside the UK or the European Economic Area, for example, to the United States. Where the level of protection of personal data in those countries has not been deemed adequate by the European Commission (or e.g. by relevant bodies or applicable laws in the UK), we put in place standard data protection clauses (adopted by the European Commission) or third parties engaged by us may rely on other transfer mechanisms (e.g. binding corporate rules) to provide appropriate safeguards to protect your personal data in accordance with applicable data protection laws.

You can find a list of countries deemed by the European Commission as providing an adequate level of protection at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

You can obtain a copy of the standard data protection clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

If you would like further information regarding our data transfers and the steps we take to safeguard your personal data, please contact us using the details set out in the 'contact us' section.

12. How long do we retain your personal information for?

We may retain your personal data as long as it remains necessary in relation to the purposes we collected the information for. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this privacy notice.

For example, we 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.

We will process personal data for 2 years following any conference we host and will store the personal data for 2 years after. After 2 years your data will be deleted.

intelliflo developer store accounts are stored for 3 years after you last login to your account and 3 years after our last customer ceases to use your product. This is so we can deal with any billing issues which may arise.

For further information regarding how long your personal information will be kept, please our contact details in see the 'Get in touch' section.

13. What are your rights in relation to the personal data we hold about you?

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 (subject to the conditions set out in applicable laws):

Your rights include:

  • The right to access your personal data

    You have the right to request a copy of the information that we hold about you.

  • The right to rectification

    You have a right to correct data that we hold about you that is inaccurate or incomplete.

  • The right to erasure

    In certain circumstances you can ask for the personal data we hold about you to be erased from our records.

  • The right to restriction of processing

    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.

  • The right to data portability

    You have the right to have data you supplied to us transferred to another organisation, in machine readable format.

  • The right to object to processing of your personal data

    Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to the processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to the processing of your personal data for direct marketing purposes.

  • Rights relating to automated decision-making

    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.

  • The right to withdraw consent

    You have the right to withdraw consent if that is the legal basis we are processing your data on.

  • The right to lodge a complaint with the ICO

    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.

What forms of ID will I need to provide in order to access this?

intelliflo Ltd accepts the following forms of ID when information on your personal data is requested:

Two forms of ID, such as:

  • Government issue photo ID such as Passport, driving licence
  • Birth certificate
  • Utility bill (from last 3 months)

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.

How can you contact us?

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
intelliflo Ltd
Wellington House
60-68 Wimbledon Hill Road
SW19 7PA
0330 102 8402 Email: dataprotection@intelliflo.com