Privacy Policy
About this Privacy Policy
We know how important it is for you to understand how we use your data. This Privacy Policy sets out how and why we collect, store, process and share your personal data. We will always be transparent with you about what we do with your personal data.
LS Wealth Management Limited has the statutory obligations that require us to implement policies and practices to safeguard and protect personal data under our control. When dealing with your application and further request, we may collect, hold and use your personal data. We will use it for all purposes connected with the company and the services that we provide. We may keep information and documents connected with the work we do for you in our internal storage system and may refer to the content in relation to future business. You are entitled to request access to and rectification of your personal data or the restriction of its use.
For these purposes we may transfer your data or make it available to other people or organisations who process information on our behalf and other organisations such as court of law or regulatory authorities if we have the legal duty to do so. Other than in these cases, we will not release your personal data or information to anyone without your permission
This Policy also tells you what your rights are in relation to the personal data you give to us. If you have any questions about this Privacy Policy or your rights under it please contact us at:
Correspondence Address:
C/O Sovereign Trust (Mauritius) Limited
Unit 21
Circle Square Business Park
Forbach
Mauritius
E-mail: info@leadsolutionss.com
LS Wealth Management is the “data controller” of any personal data it may collect, process and hold about you, unless we inform you otherwise.
WHO WE ARE
We, refers to LS Wealth Management ("The Company") - Company Number 155535, FSC Licence Number C117022693
This privacy statement is made by The Company.
Our registered office address is as follows:
C/O Sovereign Trust (Mauritius) Limited
Circle Square Business Park
Forbach
Mauritius
References to "we", "us", "our" and "ours" in this privacy statement means LS Wealth Management
WHAT PERSONAL DATA DO WE COLLECT & WHEN?
The personal data we collect from you directly as a client of the company can include your name, email address, mobile/landline telephone number, date of birth, address, your passport & visa details, bank details, confirmation of assets, investments and holdings and all other relevant information pertaining to the implementation of a full and thorough financial review and fact find as well as information required for the completion of any financial application or investment as requested by you as part of our services to you.
This will also include any information you give us when you contact our administrative team or when you engage with our social media platform.
We may, where we have a lawful basis for doing so, also collect personal data about you from third parties who provide us with additional publicly available information about you - this will typically be as part of standard Anti Money Laundering and Anti Terrorist Funding initial client screening.
Information may be collected at the following times:
· When you authorise to invest into products and services recommended by us, by phone, email, in writing or in person
· When you access our website. Our website also uses cookies; to find out more about the use of cookies and how you can manage them, please read our Cookie Policy
· When you contact us or we contact you regarding feedback, queries or complaints
· When you contact our administration team in person, online, via email, over the phone or via any other medium
INFORMATION ABOUT VISITORS TO OUR WEBSITES
We collect information pertaining to the use of our websites especially in areas visited most frequently by users and also the services accessed by them. We do not collect information about or identify individual visitors to our websites. We use aggregated data to analyse the usage patterns of our website. The main intent of this is to derive information regarding user needs and ensure that we offer them the best online user experience while at our Websites. We may share generic information of this nature within LS Wealth Management and also with our business partners for better understanding of how the Websites are used.
If you are using a mobile device and browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.
COLLECTION OF YOUR PERSONAL INFORMATION
Guest users of our Websites
In case, you are not registered with us then very limited information about you is collected. Do refer to the earlier paragraph mentioning the extent of visitor information collected by our website.
» Registered users
Upon registering with us, you are permitting us to use your personal data for opportunities related to our services in conjunction with our clients. The data offered by you will be shared within The Company and with our affiliate institutions. Depending upon the requirement, you will be asked to furnish select information over and above your personal details. Along with these details, you may volunteer to offer any other relevant information as a part of the registration process that will support your relationship with us and the services we provide to you.
» Inquiries through contact forms/email
The provided information is stored wherever applicable in a secure cloud server, electronically in our database or in a physical database. The information will be processed as mentioned in our privacy statement. Do reach out to use if you think the information provided by you is incorrect and needs correction.
The Company reserves the right to securely delete any personal information of sensitive nature provided by you to us.
HOW WE USE YOUR PERSONAL INFORMATION
If you choose to register with us, then we may use your personal information to contact you vie email, direct mail, telephone or any other communication channels to provide you with the information or services that you have approached us for.
Your personal information will be used by us to cater to your requests for information, quotes or services. We will process the required information only and may send you relevant information as a follow up through e-mail or via post. These communications may be, but are not limited, to the following purposes:
» To update you on the new services
» To provide you with the requested information on our services
» For research or marketing purposes
» For administration of our websites and improving our services
If you no longer wish to receive emails or newsletters from us and wish to be removed from our mailing list, please send an e-mail to info@leadsolutionss.com with "Unsubscribe" in the subject heading.
Alternatively, you could get in touch with us at our correspondence address
You should provide us with adequate details to ensure that you are unsubscribed from our mailing lists and we do not contact you further.
WHY WE USE YOUR PERSONAL INFORMATION
To make our products and services available to you
We use your personal data to provide you with the information, products and services that you request from us (i.e. to complete certain tasks, processes or investments), and to communicate with you regarding those products and services that you request from us and respond to your questions and comments.
We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with your requests for services)
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make a request for products and services.
Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For administrative and internal business purposes
We may use your personal data for our internal business purposes, such as enhancing our site, improving our services and products and identifying usage trends. We may also use your data to monitor the use of our website and ensure that our website is presented in the most effective and relevant manner for you and your device and setting default options for you (such as language and store location).
It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For security and legal reasons
We use your personal data to for security and legal purposes, including but not limited to:
There may be other scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime/fraud or fulfil a legal requirement.
We will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
In relation to being an LS Wealth Management Client and Receipt of Client Newsletters
We use your personal data to personalise your experience with us and to:
· provide you with relevant tailored company and personal updates and investment material via email if you have given us your consent to this
· process your registration details, account activity and investment history to analyse how you invest and how best to service you or your policies. This may include information on assets and investments you have shown an interest in and any historical transactions.
· measure the effectiveness of our newsletter campaigns
We rely on your consent to send direct postal and email newsletters and updates to you as a LS Wealth Management client based on the consent we acquired from you when you became a client, as amended by you from time to time.
In other cases (for example, measuring the effectiveness of our newsletters), we will rely on our legitimate interests as a business to communicate with our clients in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
INFORMATION DISCLOSURE & THIRD PARTIES
We will never sell any of your personal data to a third party. However, in order for us to provide our services to you, we share your personal data with our trusted third party financial service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.
We will not disclose the personal information provided by you or details of your individual visits to our Website to unrelated third parties unless they are provided as required by the law as per our belief.
In order to provide you with information you have requested, your personal information may be transferred or shared with third parties who act for use for further processing in accordance with the purposes to which you have consented.
As per the appropriate conditions, we may contractually require the third party to take adequate precautions to protect the data shared and comply with the applicable law.
We work with a number of trusted financial and administrative service providers who carry out services on our behalf. When you request products and services from us, the services provided by these organisations include but is not limited to: screening, administration, delivery, payment processing.
It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.
We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.
We work with carefully selected third parties, such as life companies, investment platforms, fund houses, asset managers, fund managers, banks, insurers, insurance agents/brokers, financial advisers, management companies, etc. to manage client policies and investments and carry out requests relating to services.
SECURITY & TRANSFER OF DATA
The Company is committed to protect and secure your personal information in the best possible manner through measures which could include firewalls SSL encryption and more. This is to ensure that your personal information is protected from – unauthorised access, improper use or disclosure, unauthorised modification or alteration and unlawful destruction or accidental loss.
Bearing the mind, that Internet is an open system, The Company cannot guarantee that the personal information submitted by you will not be intercepted by others. All employees and agents of LS Wealth Management who have access to your personal information or are involved in its processing respect the confidentiality of the personal information at all times.
Also, our Websites may include links to external websites which are maintained and used by other organisations which may collect personal information from visitors to their site. At no point does The Company guarantee the content or the privacy practices of any external websites and does not accept responsibility of any of them.
We may need to transfer your personal data outside of the European Economic Area (EEA), in the following circumstances: we may transfer your data between our servicing offices…..
· Where you have requested a service which is fulfilled by one of our affiliates, associates or employees based outside of the EEA
· Where we work with a supplier which processes some of its personal data outside of the EEA.
These countries may not have the same data protection laws as the UK and the EEA and so your personal data may not be subject to the same protections. However, in such cases, we will make sure that any transfer of your personal data to countries outside the EEA is subject to appropriate safeguards as if it were being processed inside the EEA and under the guiding principles set out in this privacy policy.
Keeping in mind the global nature of The Company, transfer of your personal information to other staff, properties, affiliates and associates located across the world as per business requirements may take place from time to time.
If you would like further information please contact us.
RETENTION
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place.
We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.
LS Wealth Management holds personal information for a period of at least 12 months or for the length of the period as deemed necessary for the provision of services by us - as can be dictated by third parties such as compliance companies, management companies or financial institutions. We will not keep your personal information for longer periods unless necessary.
CHANGES TO THIS PRIVACY STATEMENT
Changes in our privacy policy made will be posted on our websites so that you are well informed on what information is gathered and along with it, the extent of disclosure.
CONSENT & YOUR RIGHTS
You have a number of rights relating to your personal information and what happens to it.
You are entitled to:
· have your data processed in a fair, lawful and transparent way;
· be informed about how your personal data is being used, an example being this privacy policy;
· access personal data we hold about you;
· require us to correct any mistakes in your personal data;
· require us to delete personal data concerning you in certain situations where there is no good reason for us to continue to process it;
· request that we transfer your personal data to you or another service provider in a simple, structured format;
· object at any time to processing of your personal data for direct marketing purposes;
· object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
· object in certain other situations to our continued processing of your personal data; and
· otherwise restrict or temporarily stop our processing of your personal data in certain circumstances.
By accessing the website and/or submitting your personal information to us as a registered client, you agree to the use of your information a set out in this privacy policy.
If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting us as outlined above.
QUESTIONS
Questions relating to the use of your personal information or requests to correct or remove your submitted personal information should be emailed to info@leadsolutionss.com.
You may also write to us at the correspondence address given above.
This Privacy Policy was last updated on 5th August 2019
We know how important it is for you to understand how we use your data. This Privacy Policy sets out how and why we collect, store, process and share your personal data. We will always be transparent with you about what we do with your personal data.
LS Wealth Management Limited has the statutory obligations that require us to implement policies and practices to safeguard and protect personal data under our control. When dealing with your application and further request, we may collect, hold and use your personal data. We will use it for all purposes connected with the company and the services that we provide. We may keep information and documents connected with the work we do for you in our internal storage system and may refer to the content in relation to future business. You are entitled to request access to and rectification of your personal data or the restriction of its use.
For these purposes we may transfer your data or make it available to other people or organisations who process information on our behalf and other organisations such as court of law or regulatory authorities if we have the legal duty to do so. Other than in these cases, we will not release your personal data or information to anyone without your permission
This Policy also tells you what your rights are in relation to the personal data you give to us. If you have any questions about this Privacy Policy or your rights under it please contact us at:
Correspondence Address:
C/O Sovereign Trust (Mauritius) Limited
Unit 21
Circle Square Business Park
Forbach
Mauritius
E-mail: info@leadsolutionss.com
LS Wealth Management is the “data controller” of any personal data it may collect, process and hold about you, unless we inform you otherwise.
WHO WE ARE
We, refers to LS Wealth Management ("The Company") - Company Number 155535, FSC Licence Number C117022693
This privacy statement is made by The Company.
Our registered office address is as follows:
C/O Sovereign Trust (Mauritius) Limited
Circle Square Business Park
Forbach
Mauritius
References to "we", "us", "our" and "ours" in this privacy statement means LS Wealth Management
WHAT PERSONAL DATA DO WE COLLECT & WHEN?
The personal data we collect from you directly as a client of the company can include your name, email address, mobile/landline telephone number, date of birth, address, your passport & visa details, bank details, confirmation of assets, investments and holdings and all other relevant information pertaining to the implementation of a full and thorough financial review and fact find as well as information required for the completion of any financial application or investment as requested by you as part of our services to you.
This will also include any information you give us when you contact our administrative team or when you engage with our social media platform.
We may, where we have a lawful basis for doing so, also collect personal data about you from third parties who provide us with additional publicly available information about you - this will typically be as part of standard Anti Money Laundering and Anti Terrorist Funding initial client screening.
Information may be collected at the following times:
· When you authorise to invest into products and services recommended by us, by phone, email, in writing or in person
· When you access our website. Our website also uses cookies; to find out more about the use of cookies and how you can manage them, please read our Cookie Policy
· When you contact us or we contact you regarding feedback, queries or complaints
· When you contact our administration team in person, online, via email, over the phone or via any other medium
INFORMATION ABOUT VISITORS TO OUR WEBSITES
We collect information pertaining to the use of our websites especially in areas visited most frequently by users and also the services accessed by them. We do not collect information about or identify individual visitors to our websites. We use aggregated data to analyse the usage patterns of our website. The main intent of this is to derive information regarding user needs and ensure that we offer them the best online user experience while at our Websites. We may share generic information of this nature within LS Wealth Management and also with our business partners for better understanding of how the Websites are used.
If you are using a mobile device and browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.
COLLECTION OF YOUR PERSONAL INFORMATION
Guest users of our Websites
In case, you are not registered with us then very limited information about you is collected. Do refer to the earlier paragraph mentioning the extent of visitor information collected by our website.
» Registered users
Upon registering with us, you are permitting us to use your personal data for opportunities related to our services in conjunction with our clients. The data offered by you will be shared within The Company and with our affiliate institutions. Depending upon the requirement, you will be asked to furnish select information over and above your personal details. Along with these details, you may volunteer to offer any other relevant information as a part of the registration process that will support your relationship with us and the services we provide to you.
» Inquiries through contact forms/email
The provided information is stored wherever applicable in a secure cloud server, electronically in our database or in a physical database. The information will be processed as mentioned in our privacy statement. Do reach out to use if you think the information provided by you is incorrect and needs correction.
The Company reserves the right to securely delete any personal information of sensitive nature provided by you to us.
HOW WE USE YOUR PERSONAL INFORMATION
If you choose to register with us, then we may use your personal information to contact you vie email, direct mail, telephone or any other communication channels to provide you with the information or services that you have approached us for.
Your personal information will be used by us to cater to your requests for information, quotes or services. We will process the required information only and may send you relevant information as a follow up through e-mail or via post. These communications may be, but are not limited, to the following purposes:
» To update you on the new services
» To provide you with the requested information on our services
» For research or marketing purposes
» For administration of our websites and improving our services
If you no longer wish to receive emails or newsletters from us and wish to be removed from our mailing list, please send an e-mail to info@leadsolutionss.com with "Unsubscribe" in the subject heading.
Alternatively, you could get in touch with us at our correspondence address
You should provide us with adequate details to ensure that you are unsubscribed from our mailing lists and we do not contact you further.
WHY WE USE YOUR PERSONAL INFORMATION
To make our products and services available to you
We use your personal data to provide you with the information, products and services that you request from us (i.e. to complete certain tasks, processes or investments), and to communicate with you regarding those products and services that you request from us and respond to your questions and comments.
We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with your requests for services)
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make a request for products and services.
Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For administrative and internal business purposes
We may use your personal data for our internal business purposes, such as enhancing our site, improving our services and products and identifying usage trends. We may also use your data to monitor the use of our website and ensure that our website is presented in the most effective and relevant manner for you and your device and setting default options for you (such as language and store location).
It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For security and legal reasons
We use your personal data to for security and legal purposes, including but not limited to:
- Running compliance checks
- Thorough screening of client data for Anti Money Laundering and Anti Terrorist Funding purposes
- CRS and FATCA reporting
- Confirmation of investment affordability
- Ensuring the personal and financial information you provide us is accurate
- Conducting fraud checks and preventing other illegal activity
- Protection of our rights or property (or those of others)
- To fulfil our legal and compliance-related obligations
There may be other scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime/fraud or fulfil a legal requirement.
We will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
In relation to being an LS Wealth Management Client and Receipt of Client Newsletters
We use your personal data to personalise your experience with us and to:
· provide you with relevant tailored company and personal updates and investment material via email if you have given us your consent to this
· process your registration details, account activity and investment history to analyse how you invest and how best to service you or your policies. This may include information on assets and investments you have shown an interest in and any historical transactions.
· measure the effectiveness of our newsletter campaigns
We rely on your consent to send direct postal and email newsletters and updates to you as a LS Wealth Management client based on the consent we acquired from you when you became a client, as amended by you from time to time.
In other cases (for example, measuring the effectiveness of our newsletters), we will rely on our legitimate interests as a business to communicate with our clients in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
INFORMATION DISCLOSURE & THIRD PARTIES
We will never sell any of your personal data to a third party. However, in order for us to provide our services to you, we share your personal data with our trusted third party financial service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.
We will not disclose the personal information provided by you or details of your individual visits to our Website to unrelated third parties unless they are provided as required by the law as per our belief.
In order to provide you with information you have requested, your personal information may be transferred or shared with third parties who act for use for further processing in accordance with the purposes to which you have consented.
As per the appropriate conditions, we may contractually require the third party to take adequate precautions to protect the data shared and comply with the applicable law.
We work with a number of trusted financial and administrative service providers who carry out services on our behalf. When you request products and services from us, the services provided by these organisations include but is not limited to: screening, administration, delivery, payment processing.
It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.
We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.
We work with carefully selected third parties, such as life companies, investment platforms, fund houses, asset managers, fund managers, banks, insurers, insurance agents/brokers, financial advisers, management companies, etc. to manage client policies and investments and carry out requests relating to services.
SECURITY & TRANSFER OF DATA
The Company is committed to protect and secure your personal information in the best possible manner through measures which could include firewalls SSL encryption and more. This is to ensure that your personal information is protected from – unauthorised access, improper use or disclosure, unauthorised modification or alteration and unlawful destruction or accidental loss.
Bearing the mind, that Internet is an open system, The Company cannot guarantee that the personal information submitted by you will not be intercepted by others. All employees and agents of LS Wealth Management who have access to your personal information or are involved in its processing respect the confidentiality of the personal information at all times.
Also, our Websites may include links to external websites which are maintained and used by other organisations which may collect personal information from visitors to their site. At no point does The Company guarantee the content or the privacy practices of any external websites and does not accept responsibility of any of them.
We may need to transfer your personal data outside of the European Economic Area (EEA), in the following circumstances: we may transfer your data between our servicing offices…..
· Where you have requested a service which is fulfilled by one of our affiliates, associates or employees based outside of the EEA
· Where we work with a supplier which processes some of its personal data outside of the EEA.
These countries may not have the same data protection laws as the UK and the EEA and so your personal data may not be subject to the same protections. However, in such cases, we will make sure that any transfer of your personal data to countries outside the EEA is subject to appropriate safeguards as if it were being processed inside the EEA and under the guiding principles set out in this privacy policy.
Keeping in mind the global nature of The Company, transfer of your personal information to other staff, properties, affiliates and associates located across the world as per business requirements may take place from time to time.
If you would like further information please contact us.
RETENTION
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place.
We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.
LS Wealth Management holds personal information for a period of at least 12 months or for the length of the period as deemed necessary for the provision of services by us - as can be dictated by third parties such as compliance companies, management companies or financial institutions. We will not keep your personal information for longer periods unless necessary.
CHANGES TO THIS PRIVACY STATEMENT
Changes in our privacy policy made will be posted on our websites so that you are well informed on what information is gathered and along with it, the extent of disclosure.
CONSENT & YOUR RIGHTS
You have a number of rights relating to your personal information and what happens to it.
You are entitled to:
· have your data processed in a fair, lawful and transparent way;
· be informed about how your personal data is being used, an example being this privacy policy;
· access personal data we hold about you;
· require us to correct any mistakes in your personal data;
· require us to delete personal data concerning you in certain situations where there is no good reason for us to continue to process it;
· request that we transfer your personal data to you or another service provider in a simple, structured format;
· object at any time to processing of your personal data for direct marketing purposes;
· object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
· object in certain other situations to our continued processing of your personal data; and
· otherwise restrict or temporarily stop our processing of your personal data in certain circumstances.
By accessing the website and/or submitting your personal information to us as a registered client, you agree to the use of your information a set out in this privacy policy.
If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting us as outlined above.
QUESTIONS
Questions relating to the use of your personal information or requests to correct or remove your submitted personal information should be emailed to info@leadsolutionss.com.
You may also write to us at the correspondence address given above.
This Privacy Policy was last updated on 5th August 2019