Amended: 27th June 2018
Please read the following terms and conditions of use carefully before using this website.
Retirement Advantage (a Canada Life Company) provide those who are in, at or approaching retirement with a range of simple, secure and flexible products to suit their needs.
We take collection and management of your Personal Data very seriously.
This Privacy Notice (PN) explains how the information held by Retirement Advantage (referred to as “Retirement Advantage”, “we” or “us” throughout this notice) will be treated.
Any personal information provided to us by a policyholder, joint policyholder, employer policyholder, trustee, insured person, beneficiary, claimant or member (referred to as ‘you’ or ‘your’ in this PN), will be treated in accordance with current Data Protection legislation, and any successor legislation.
What is personal information?
Personal information means any information about you which is personally identifiable, including your name, age, address, telephone number, email address, financial details, and any other information from which you can be identified. It will also include genetic and biometric data, location data and online identifiers which may identify you, such as your internet protocol (IP) address (the unique personal address which identifies your device on the internet) and mobile device IDs.
What do we collect?
We will collect the following information about you and your dependants (this includes your authorised Power of Attorney) when you use our services or we may collect it indirectly from our business partners, such as financial intermediaries:
· Personal data: your name, date of birth, telephone number, address, email address, dependants, marital status, IP address and media access control (MAC) address.
· Sensitive/special categories of personal data: gender and other sensitive information such as information about your physical and mental health. We recognise that information about health is particularly sensitive information.
· Financial information: information that may relate to your financial circumstances (for example your pension values, income and existing investments), bank account details and details of product options you may consider.
· Technical Information: such as details on the devices and technology you use.
· Public Records: This includes open data such as the Electoral register, Land register or information that is openly available on the internet.
· Documentary data and national identifiers: Information that is stored on your passport, driving license, birth certificate, and National Insurance number.
As well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. If you are providing information about another person, then we expect you to ensure the other person knows you are doing so and are content with their information being provided to us. You might find it helpful to show them this PN and if they have any concerns to contact us directly. If personal information is submitted about another person (for example spouse/partner), then by signing this form, you confirm that they have agreed to providing their information for the information to be used and shared as set out in this PN.
How your information will be used?
Reference to “your information” and “your Personal Data” shall mean Personal Data and or / Special Categories of Personal Data (such as medical data), that is disclosed to us, for which an identifiable individual (Data Subject) is the focus.
The information provided to us may be used:
· To provide any requested product or service and to deal with any enquiries and requests we may receive;
· In relation to the performance of a contract with you or to take steps to enter into a contract with you;
· To underwrite and administer a Retirement Advantage product. This may include an automated underwriting process taking into account the Special Categories of Personal Data provided;
· To prevent, detect or investigate financial crime;
· To better understand our customer and improve customer engagement. This may include research, statistical analysis, profiling and customer analytics which allow us to make certain predictions and assumptions about your interests, and make correlations about our customers to improve our products;
· For the purposes of complying with applicable legal and regulatory obligations;
· To perform a task carried out in the public interest or in the exercise of official authority vested in Retirement Advantage, your data controller.
Some of the information we collect as part of an application for a policy may be provided to us by a third party. This may include information we and our subsidiaries already hold about you and your dependant, including details from previous quotes and claims, information we obtain from publicly available records, our trusted third parties and from industry databases, including fraud prevention agencies and databases.
There may be a scenario where your information could be processed outside of the European Economic Area (EEA). In this situation we confirm that only the minimum amount of data will be processed, and appropriate security measures in accordance with the Data Protection legislation will be applied.
Legal basis for processing:
Where processing of data is necessary for entering into a contract with Retirement Advantage or for the performance of a contract which you (the data subject) are aware of the legal processing of Personal Data, this is based on Article 6.1(b) of the General Data Protection Regulation (GDPR).
Processing of Special Categories of Personal Data (for example health or medical data) is based on Article 9.2(g) of the GDPR in that processing is necessary for reasons of substantial public interest and conducted on the basis of applicable law where the only data processed will be that necessary for the aim specified in order to respect the Data Subject’s rights and interests.
Sharing Personal Data
Where necessary and only for the purposes mentioned above, information (including medical data) may be shared with:
· Other companies within The Canada Life Group (UK) Limited and any future owners of our business and/or affiliates;
· Service providers, such as reinsurers, third party administrators, professional advisors, tracing agencies and/or research companies;
· Doctors or any relevant medical professional;
· With credit agencies (for the purpose of identification verification);
· Agencies and third parties for the purposes of preventing, detecting or investigating financial crime; and/or
· Mortgage funding providers;
· Regulators or such authority if required to do so by law or by any court order or if we have consent to do so.
We may use electronic searches, including credit reference agencies that will record any credit searches on your file.
For retirement income, we insure risks assumed by us with special insurance companies (reinsurers). For this, it may be necessary to submit your contract data and claim data to a reinsurer, Hannover Re, so that they can form their own opinion about the risk. In addition, it is possible that the reinsurer supports our company due to its special expertise in the risk or claims assessment or other related purposes. We transmit your data to the reinsurer only insofar as this is necessary to perform the obligations of our insurance contract with you. Hannover Re will also act as Controller of your data. The fair processing notice for Hannover Re is available at https://www.hannover-re.com/privacy.
For equity release, we will disclose details of this application and any resulting offer of advance to our solicitor, Eversheds Sutherland, in connection with the work they do on our behalf in relation to your loan or your property. Eversheds Sutherland will also act as Controller of your data. The fair processing notice for Eversheds Sutherland is available at www.eversheds-sutherland.com.
Personal information collected via professional advisers including quotation requests and application forms will be shared within the Canada Life group of companies to provide professional advisers with product information which may be relevant for their client’s needs and requirements.
The data provided will not be used for any longer than is necessary and in accordance with FCA record keeping guidelines. Personal Data and Special Categories of Personal data will be:
· Deleted after 6 months if the data used is for a product quotation that does not proceed to a policy; or
· Retained on file for 6 years after a policy has ended.
· Deleted after 2 years if the data used is for a mortgage illustration that does not proceed to completion; or
· Retained on file for 7 years after mortgage redemption.
Individual rights under the General Data Protection Regulation (GDPR)
GDPR provides individuals (Data Subjects) with various rights including the right to be told what Personal Data is held by Retirement Advantage and the right to request that any inaccuracies in respect of their Personal Data are corrected. Details of all individual rights are shown below:
1. The right to be informed – you have the right to be informed how your personal data will be used. For example this may be set out in a company’s privacy notice.
2. The right of access – you have the right to access your personal data and supplementary information. For example you may wish to access your data to become aware of and verify the lawfulness of the processing.
3. The right to rectification – you have the right to have your personal data rectified. For example if you feel it is inaccurate or incomplete.
4. The right to erasure – you have the right in specific circumstances to request the deletion or removal of personal data where there is no compelling reason for its continued processing. For example, your personal data was unlawfully processed.
5. The right to restrict processing – you have the right to restrict the processing of your personal data in certain circumstances. For example you wish to contest the accuracy of your personal data.
6. The right to data portability – you have the right to obtain and reuse your personal data for your own purposes. For example you may wish to move, copy or transfer personal data from one information technology environment to another in a safe and secure manner.
7. The right to object – you have the right to object to your personal data being used for processing based on legitimate interests or for a task in the public interest. For example you no longer want your personal data used for direct marketing.
8. Rights in relation to automated decision making and profiling – you have the right to challenge decisions that are made using an automated approach including profiling. For example you may want to request human intervention where you do not agree with an automated decision.
Notification of Changes to our Privacy Notice
We reserve the right to amend or modify the PN at any time and in response to any changes in applicable Data Protection and privacy legislation.
If we decide to change our PN, we will post these changes on our website so that you are aware of the information we collect and how we use it at all times.
If at any point we decide to use or disclose information we have collected, in a manner different from that stated at the time it was collected, we will notify you.
Detailed information relating to your individual rights can be obtained via the Information Commissioner’s Office – see ‘further information’ section for contact details.
These terms of trading are subject to English law and to the exclusive jurisdiction of the English courts.
All information and content on Retirement Advantage’s website is subject to applicable statutes and regulations, furnished ‘as is’, without warranty of any kind, expressed or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, or non-infringement.
Any website content is intended to be general in nature and for interest. The content is not a substitute for professional tax, professional legal advice or professional financial advice. Retirement Advantage is not providing tax, financial or legal advice on this website. Decisions based on information contained in Retirement Advantage’s site are the sole responsibility of the visitor, and in exchange for using Retirement Advantage’s site, the visitor agrees to hold Retirement Advantage harmless against any claims for damages arising from any decision that the visitor makes based on such information.
Retirement Advantage will employ procedures to ensure that all information provided via this site is accurate and error-free and that all services furnished by Retirement Advantage via the internet are reliable and uninterrupted. Retirement Advantage makes no warranty that such information is accurate or error-free or that such services will be error-free, continuously available or free from viruses, worms, programming errors or other harmful components.
Nothing contained in this website should be construed as a solicitation or offer or recommendation to take out one of our products. The information on our website does not constitute advice. You must obtain relevant independent professional advice before making any decision.
If you would like to speak with a qualified independent adviser please visit http://www.retirementadvantage.com/find-an-adviser for details.
The pages on this website are intended for access and use by UK residents only and comply with appropriate UK legislation and regulation.
Telephone calls may be recorded for training and quality monitoring purposes. Retirement Advantage is a trading name of MGM Advantage Life Limited. Registered no. 08395855. Retirement Advantage is a trading name of Stonehaven UK Ltd. Authorised and regulated by the Financial Conduct Authority. Registered in England and Wales. Registered number: 05487702. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Retirement Advantage and the Retirement Advantage logo are trademarks of MGM Advantage Life Limited. Registered in England and Wales. Registered office 110 Cannon Street, London EC4N 6EU.
Modification and monitoring of website
Retirement Advantage reserves the right, at its discretion, to change, modify, add, or remove portions of this information or the content of our website at any time. We suggest that you check this information periodically for changes. This information can be accessed from the link at the bottom of our website pages.
If you use this website after we post changes to the information or the content of the site, you accept such changes. Retirement Advantage expressly reserves the right to monitor any and all use of this website.
Monitoring our communications with you
Monitoring or recording of your calls, emails and other communications may take place in accordance with UK law.
This may take place for business purposes, such as:
· quality control and training
· processing necessary for the entering into or the performance of a contract
· to prevent unauthorised use of our telecommunication systems and websites
· to ensure effective systems operation
· to meet any legal obligation
· in order to prevent or detect crime
· for the purposes of the legitimate interests of the data controller
If you communicate with us by email, we may keep your email, together with your email address and our reply, for our business records. We give the same protection to our electronic communications as we do to information we receive by post or phone.
We will take all reasonable steps to ensure that any information you provide on our websites (including the use of our Equity Release KFI Generator by advisers) is kept secure. However, messages sent by email cannot be guaranteed to be completely secure as they may be intercepted, lost or corrupted. We are therefore not responsible for the accuracy of the messages sent by email over the internet - whether from us to you or from you to us.
If you ask us to email you information that is personal or confidential, we may need to ask you for extra information to confirm your identity and to give us authority to send that information to you. Alternatively we may look to provide this information to you by another means.
Use of data for direct marketing purposes and updating your personal data
Marketing activity on a business to business basis is based on Article 6.1(f) of the GDPR in that processing is necessary for the purposes of the legitimate interests by the controller, in that there is a reasonable expectation that Retirement Advantage will contact you for the purpose of communicating product, industry and regulatory information.
At each point of data collection, and within each communication, you are given the opportunity to opt-out of receiving future direct marketing material from Retirement Advantage. If you do not opt-out of such communications, Retirement Advantage may provide information on our products, services, events, and training and education programmes. If at any time you want Retirement Advantage to stop sending such communications, you can ask us to remove your details from our contact list.
We will never release information about our customers or business partners to any other person or organisation for marketing purposes. We do not sell, rent or trade your information to others. We may give general statistics about our customers, sales, and related site information to other companies however these statistics will not include any information that personally identifies you, unless we have said otherwise in this policy.
If you have further queries with regards to your personal data or want to verify, update or amend your personal data please feel free to contact us at:
firstname.lastname@example.org, or write to: Retirement Advantage, 110 Cannon Street, 6th floor, London, EC4N 6EU
email@example.com, or write to: Retirement Advantage, Highdown House, Yeoman Way, Worthing, West Sussex BN99 3HH
Verification, updating or amendment of personal data takes place within one month of receipt of the request.
Should there be any queries regarding Personal Data or individuals rights under the Act, please contact Retirement Advantage’s Data Protection Officer in writing at:
110 Cannon Street
You also have the right to talk to the Information Commissioner’s Office whose main role is to uphold information rights in the public interest.
Phone: 0303 123 1113
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Links to third-party websites
Retirement Advantage is not responsible for the content of any site owned by a third party connected to this website via hyperlink. As a convenience to our users, some of the documents on this website contain links to information created and maintained by other organisations. Please note that Retirement Advantage does not control, cannot guarantee, and is not responsible for the accuracy, timeliness, or even the continued availability or existence of this outside information.
Retirement Advantage does not endorse or make any representations about the companies, products, or materials accessible through these hyperlinks. If you opt to hyperlink to other Websites accessible through Retirement Advantage’s website, you do so entirely at your own risk. Furthermore, no representation or warranty is provided for any software that you may download from a link from this website. Retirement Advantage is not responsible for the privacy policies of third party websites therefore we advise you to read the privacy policies of other websites before registering any personal data.
By using these third party websites, you consent to their privacy policies.
We not collect personal data through third party sites.
Limitation of liability
In no event shall Retirement Advantage be liable for any direct, incidental or consequential damages, including, but not limited to, (i) loss of anticipated profits, benefits, use, or data or (ii) injury caused by any performance, failure of performance, error, omission, interruption, deletion, defect, delay in operation of transmission, computer virus or worm, communications line failure, theft or destruction or unauthorised access to, alteration of, or use of information, resulting from the use of or access to this site.
It is possible that all or a portion of the forgoing disclaimers or limitations of liability may not be enforceable in the jurisdiction in which you reside.
Retirement Advantage maintains a copyright in the text, logos and graphics contained throughout this website, except where specifically noted below. Unauthorised copying, reproducing, uploading, downloading, duplicating or transmitting of any material contained on this website is prohibited.
Adobe, Acrobat, Acrobat Reader, and the Acrobat logo are trademarks of Adobe Systems Incorporated.
Termination of access to site
You understand that, if at any time you no longer agree with these Terms of Site Access, your sole remedy shall be to cease using the site. In addition, upon receipt of written instructions from you, Retirement Advantage will take action to prevent access to the site by you or other persons previously authorised by you to access the site on your behalf.
Cookies and IP address
When you visit our website we may routinely gather supplementary information about you such as the type of mobile device you use, the internet browser you have and the journey you have taken to reach the website (i.e. have you come directly or via another means – a link for example). In addition we will collect your IP address (your IP address is unique and helps us identify your device on the internet. We cannot identify you from this data. The reason we need your IP address is that it helps us provide a more effective service via our website and enables us to collect broad demographic information for summative use.
Our cookies help us:
· Make our website work as you’d expect
· Remember your settings during and between visits
· Improve the speed/security of the site
· Allow you to share pages with social networks like Facebook
· Continuously improve our website for you
· Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)
· Collect any personally identifiable information (without your express permission)
· Collect any sensitive information (without your express permission)
· Pass data to advertising networks
· Pass personally identifiable data to third parties
· Pay sales commissions
You can learn more about all the cookies we use below.
More about our cookies
Website function cookies: Our own cookies
· Remembering your search settings
· Allowing you to add comments to our site
There is no way to prevent these cookies being set other than to not use our site.
Social website cookies
So you can easily like or share our content on the likes of Facebook and Twitter we have included sharing buttons on our site.
Cookies are set by:
The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
Anonymous visitor statistics cookies
We also use technology to determine how people who phone us arrived on our website (e.g. from a search engine or by clicking on an advert). This is to help us to identify how people heard about us. Please be aware that if you call us, using a phone number on the website we can potentially tell how you arrived on our website. Again this ultimately helps us keep down costs for you.
Turning cookies off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (Learn how here).
Doing so however will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites
Google Analytics Demographics and Interest Reports
Retirement Advantage uses Google Analytics Demographics and Interest Reporting on this website. This allows Retirement Advantage and Google’s third party vendors to analyse the following information:
· Age identifiers
· Gender Affinity
· Categories In-Market
· Other Categories
Google will use information from your web and app browsing history to personalise advertising you see across the web, together with your Google Analytics data for cross-device marketing.
You can opt out of Google Analytics using the Google Analytics Opt-out Browser Add-on and you can control the ads you experience (or opt out of personalised ads altogether) at My Account.
The KFI Generator is a dedicated website with secure entry for use by advisers who have been directly authorised to have access. This access is agreed by Retirement Advantage as part of our adviser registration process. Our KFI Generator is an on-line tool for the use of producing client KFIs.
Using the Equity Release KFI Generator & Retirement Income quote system and dashboard – this section of the Privacy Notice only applies to financial advisers, paraplanners or administrators of Financial Services companies.
KFI Generator tool
You will be asked to log in using your username (your registered email address) and password. If this is your first time logging in, you will need to use the password emailed to you by Retirement Advantage. If you have used the KFI Generator before, you will have changed your password to something more memorable.
Quote system and dashboard
Following your initial registration for the tool (via an online form) you will receive a passcode which is made up of three words. Entering these words will verify you email address. Once this is done you will be able to enter your username and set your password.
Both tools use a cookie in order to provide a secure login. This cookie is used solely by each individual tool, and does not store any personal information. The data is not shared with any third parties.
After logging in to the tools, all page accesses are logged for security and audit purposes. Page accesses are linked to each individual logged in. We use such data to ensure we can provide you with support in the event that you encounter an error with the tools, or if we need to ensure compatibility with certain web browser technologies. We may audit the access logs in the event of an issue with the tools, or in the event that we suspect malicious or illegal activity.
The Retirement Income quote system and dashboard runs on Windows devices in Internet Explorer 11, Google Chrome (C41+) or Firefox browsers. Accessing the dashboard via iOS (Apple) or Android devices is not recommended.
Equity Release KFI Generator - Email addresses
We require this information to provide you with a better service, and in particular for the following reasons:
· We may periodically send promotional emails about new products, special offers or other information that we think you may find interesting, using the email address which you have provided assuming you have provided individual consent to do so
· We may use the information we collect to verify your identity or for analytical purposes, and to assist us in improving our processes, products and services.
· We will use your email address to send you automated emails at relevant stages of your KFI applications.
Equity Release KFI Generator and Retirement Income Quote system and dashboard - Passwords
In order to provide you with maximum protection, we ask you to choose a password to access these tools. Your password is unique to you and helps us to protect your client's personal information. You must keep this password safe and must not disclose it to anyone.
You will need your password to be able to produce KFIs/quotes for your clients. If you have forgotten your password or are worried someone else may know your password, please click the 'Forgotten password?' link under the password box on the homepage of both tools to reset your password.
Equity Release KFI Generator and Retirement Income quote system and dashboard Restricted access
These tools are only available to advisers who are registered with Retirement Advantage.
If you would like to register please:
Email - firstname.lastname@example.org for access to the Equity Release KFI Generator
Complete an online form for access to the RI quote system and dashboard.
Before using these tools, please make yourself familiar with our products. We have a user guide available for the KFI Generator and our sales support team can provide a demo of the Retirement Income Quote system and Dashboard.
If you have any queries while using the:
KFI Generator, please contact our Adviser Support Team on 0800 068 0212.
Retirement Income Quote system and Dashboard, please contact us on 0800 032 7689.
Our KFI Generator is a secure site that uses 256-bit Secure Sockets Layer (SSL) security, subject to your web browser limitations, to encrypt data in transit between your browser and the server.
Equity Release KFI Generator - Client data
We may however disclose and /or use any information or data you give us for the purpose of crime prevention, conducting market research, preparing strategic or other marketing plans or gauging product sales or product performance. We may also exchange the information with associated companies, service providers or agents with which we have a contractual relationship, or to any party in connection with the approved uses of such information set out above.
Notification of changes
© Retirement Advantage 27th June 2018