Privacy Policy

This website is operated and provided by HUB Financial Solutions Limited, a company which is part of Just Group plc*.

HUB Financial Solutions Limited is authorised and regulated by the Financial Conduct Authority and registered with the UK Information Commissioner’s Office with registration number Z964954X.

The Pension Buddy Service is not regulated by the Financial Conduct Authority.

Please read this Privacy Policy together with the Terms of Use ("Terms") and our Cookie policy which govern your use of this website.

We respect the privacy of every individual who visits our website and have developed this policy because we want you to feel confident about the privacy and security of your personal information.

By using our website you acknowledge that you have read and understood the terms of this privacy policy and the use of personal information described.

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 wholly or partly 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.

The Pension Buddy service collects the following information about you:

Personal data: your name, date of birth, gender, telephone number, address, email address, dependants, marital status, information relating to your financial circumstances (for example your pension values, income and existing investments), bank account details, details of product options you may consider, IP address and media access control (MAC) address.

Special categories of data: Sensitive information such as information about your physical health.

Technical and cookies information: information to measure and analyse the use and effectiveness of our services, and to customise the targeting of advertising relating to our services.

We will process your personal information for our legitimate interests for the following purposes:

• To identify and advise on which products or services best suit your requirements or needs.
• For administration and to support your choice through updates on policy or product changes.
• For the purpose of providing automated advice including recommendations for your future objectives.
• To allow you to create an account and communicate with us.
• To invite you to take part in customer research, potentially using specialist market research.
• To comply with legal and regulatory obligations.
• For business and analysis purposes including protecting your data through secure storage and backups.
• For the prevention and detection of fraud.

The companies within Just Group provide an extensive range of different financial products and services and may distribute the personal information you have provided to other companies in the Just Group (when applicable) to help identify and tailor products and services that may be of interest to you. You will be asked to provide your explicit consent to allow your data to be stored and used in this way.

We may obtain your (or your appointed Power of Attorney’s) consent in order to:

• Obtain your marketing preferences and communicate with you in accordance with preferences or options you have selected through email, telephone or SMS (text message).
• To send you marketing literature covering our range of products and services and we may continue to do this after your policy has ended.
• Use your personal data for automated decision-making, including profiling for research and marketing purposes as well as actuarial and statistical analysis.

We will seek to obtain your explicit consent where we are required to process any special categories of personal data (such as, medical information).

In the event that we intend to process your personal data for new purposes requiring your consent, we will contact you to ask your consent for such new purposes.

The personal information we hold about you may be shared with the following recipients subject to security, contractual and transfer adequacy safeguards as appropriate:

• Other companies in the Just group.
• Business partners/service providers who assist us in providing the services we offer through our website applications and third party comparison portal(s).

The following categories of business partners and close affiliations assist us in the provision of ancillary services and only use your personal information to the extent necessary to perform their functions:

• Providers for pricing/underwriting purposes. These providers may share your personal information with their group companies for the same purpose.
• Service providers for the provision of support services such as reinsurance, product administration, receiving and sending marketing communications, data analysis and validation, IT support services, archiving, auditing, business administration and other support services and tasks.
• Business partners who may have referred you to us to provide them with relevant management information.
• Other companies in the event we undergo a re-organisation or are sold to a third party.
• Regulators and public authorities who have a legal right to request and process your personal information.
• Other companies in the Just group, where relevant, for management information purposes.

We may also disclose your personal information if legally entitled or required to do so. For example, if required by law or by a court order or if we believe that such action is necessary to prevent fraud or cybercrime, or to protect the Site or the rights, property or personal safety of any person.

Where we have provided you with a service, we will keep your personal information for as long as is necessary for the purposes described in this policy (in line with the data minimisation principle) for a maximum period of 90 days after the service has expired. After this your personal information will be deleted or anonymised in compliance with our established data protection policy.

Anonymised personal information will not be considered as personal since no individual can be identified by that information. We use anonymised information for further actuarial and business analysis, business research and reporting to help us to develop our products and services.

Cookies are small files on websites that are downloaded to your computer or mobile device when you visit the website. Some cookies are necessary for the proper functioning of the website, but many are optional and you should be able to choose what cookies you want to allow. Cookies may contain information about your general internet usage, the type of internet browser or mobile device in use, your IP address and operating system and, in some cases, your previous website browsing behaviour.

When you visit any Just Group website or web page, we will only use this information to:

• Assist us in providing a more effective service and to collect broad demographic information for aggregate use.
• Help us to improve our websites to deliver a better and more personalised service.
• Estimate our audience size and usage pattern.
• Store information about your preferences and allow us to customise our website according to your individual interests.
• Speed up your searches.
• Recognise when you return to our website.

When you visit our website, you can change your cookie preferences at any time by going to Cookie Policy (pensionbuddy.co.uk) and clicking on ‘change your consent’.

Please refer to our cookie policy for a full explanation of cookie use and your management options for the control of cookies.

We may monitor or record your calls and text messages and other communications, such as emails, in accordance with UK law, and in particular for business purposes such as:

• Quality control and training.
• Processing necessary for the entering into or the performance of a contract.
• Preventing unauthorised use of our telecommunications systems and web sites and/or services.
• Ensuring effective systems operation.
• Meeting our legal obligations.
• Preventing or detecting crime.
• Anything as needed in relation to our legitimate interests.

We have security measures in place to protect against the loss, misuse and alteration of personal information under our control as required by current data protection laws.

For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

Your personal data is sent to, and stored on, secure servers located in the UK or countries within the European Economic Area (EEA). In the event that your information is transferred outside of the UK or EEA (e.g. because any of our advisers or service providers have IT systems located in other jurisdictions), we will ensure that your data is subject to appropriate safeguards, including relying on a recognised legal adequacy mechanism that it is treated securely and in accordance with our privacy policy.

We reserve the right to amend or modify the privacy policy at any time and in response to any changes in applicable data protection and privacy legislation.

If we decide to change our privacy policy, we will post those changes on this page and may place notices on other pages of our website, so that you are aware of the information we collect and use 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.

You have options and choices over how we use your personal information. We may provide you with the tools to manage your account or to change your marketing communication preferences at any time. We may retain a record of your stated objection to the processing of your personal information including an objection to receiving marketing communications. That would be for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further during the term of your objection.

In terms of your rights, you can:

• Request to see and have copies of the personal information we hold on you.
• Request your data to be corrected or erased where appropriate.
• Request to restrict/object to the processing of your personal data.
• In certain circumstances, where your request relates to data you provided to us and where technically possible, you may request to receive your personal data in a commonly used electronic format or to have the data sent in that format to another provider.
• Withdraw your consent to certain processing activities at any time. For example, to object to direct marketing or profiling for market research and marketing purposes.

Requests for your personal information shall be provided free of charge. However, where requests are repetitive, or manifestly unfounded or excessive, we may charge you a reasonable fee to cover the administrative costs of providing the information or we may refuse to act on the request.

If you have any questions or comments about this privacy policy or our practices, or if you wish to make a request or exercise any of your rights, you can contact us:

• By email at: dataprotection@wearejust.co.uk.
• By telephone on 01737 233288
• By writing to us at: Data Protection Officer, Just Group plc, Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP.

If you remain unhappy with the response you receive from us, you can also refer the matter to the Information Commissioner's Office.

* Just Group includes (Just Retirement Limited, Just Retirement Money Limited, HUB Financial Solutions Limited, Just Retirement Management Services Limited, Just Re 1 Limited, Partnership Home Loans Limited, Paying for Care Limited, Partnership Services Limited, Partnership Life Assurance Company Limited and Partnership Group Holdings Limited.

The registered office for Just Group plc (reg. no. 08568957), Just Retirement Group Holdings Limited (reg. no. 06930326), Just Retirement (Holdings) Limited (reg. no. 05078978), Just Retirement Limited (reg. no. 05017193), Just Retirement Money Limited (reg. no. 09415215), Just Retirement Management Services Limited (reg. no. 04682458), Partnership Life Assurance Company Limited (reg. no. 05465261), Partnership Home Loans Limited (reg. no. 05108846), Partnership Services Limited (reg. no. 05465380) and HUB Financial Solutions Limited (reg. no. 05125701) is Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP. Each company mentioned is registered in England and Wales and a member of Just Group.

Just Retirement Limited and Partnership Life Assurance Company Limited are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. HUB Financial Solutions Limited, Just Retirement Money Limited and Partnership Home Loans Limited are authorised and regulated by the Financial Conduct Authority.