Privacy Policy

Last updated: April 2024

1. Purpose

This page explains what you should expect from us, why and how we will use your personal data, and whether we intend to share it with anyone.

2. Data Controller

Imperium Advice by My Pension Expert Ltd is the data controller unless we state otherwise. We also trade as My Pension Expert, My Equity Release Expert, My Will Expert, and My Money Expert.

You can contact us by email at compliance@imperiumadvice.com, by phone (01302 639540), or by post to the Data Protection Officer, My Pension Expert, Colonnades House, Duke Street, Doncaster DN1 3BW. Our Data Controller is Andrew Megson, our Chief Executive Officer.

3. Processing Personal Data

Most of the data we process is provided by you as part of our discussions about financial products.

We get limited data from Companies within our Group or third parties (normally your name, contact details and basic information about what you’re looking for) if you’ve enquired about pensions, annuities, equity release, or investments.

If you’re applying for a job with us, we’ll tell you how we use your information in a separate note which we’ll send as part of any application. You can request this using any of the methods above.

3.1. What data we collect

Information about you (e.g. name, date of birth, gender, address)
Health data (e.g. height, weight, smoking status and where applicable medical conditions)
Financial Data (e.g. pension size, property value, income and outgoings)
Historical or Social data (e.g. “soft” information about you, your objectives, employment history if you are a job applicant)
Contact details (e.g. phone number, e-mail)
Technical data (IP address, device type etc)

3.2. What we do with your data

We use data to deal with your enquiry, provide illustrations and process applications, analyse the effectiveness of our processes and systems, and communicate with you where there are legitimate interests to do so.

What We Do	What data and why
Contact you to fulfil an enquiry	We’ll use any data you share with us to make sure we can answer questions, provide illustrations.
Provide illustrations	We need personal data to provide you with personalised illustrations. This might include health data; we’ll ask for your consent and explain why we need that before we take any special category data. We use a third party to provide illustrations, so we share information about you to generate these. We may use a third party to post these illustrations to you.
Process applications	If you choose to apply for a product, we’ll use the information you’ve given us to fulfil that application. This means any info you provide will be shared with a third party (the provider you choose), and your old provider; you’ll give your consent before an application is made. When we process an application, we’re required to check your identity; this involves sharing data with Smart Search, who gather information from all available credit bureaus.
Administer our sites, analyse effectiveness of our sites	We need to understand where and how our sites are accessed to make sure they work for you.
Analyse our customer journey and processes	We use technical and personal data to understand what we can do to improve things for our customers.
Marketing activity (either online or solicited direct marketing)	We use personal and technical data to keep you up to date about services relevant to the enquiry you make. You can opt out of marketing at any time.

This data will be held electronically on secure servers, only for as long as it’s needed (see section 5 – How long do we keep your data?).

We don’t make any decisions by “automated processing”. A person always has the final say.

We record all our calls to monitor our service, keep records of what we’ve agreed, and cut down on paperwork.

3.3. Phone, email, or letter?

We do what we can over the phone and email, because it’s instant and efficient. We don’t like sending too much information by email, especially when it relates to your personal information: it’s encrypted when it leaves us but email isn’t the most secure way of communicating, please bear that in mind if that’s how you want to communicate with us.

There are some things we like to send out by letter to make sure you have a permanent “hard copy”.

3.4. Cookies

Cookies are little bits of information (unique to you) that our websites send to your device. They allow us to remember where you’ve been if you access our sites again, and sometimes track where you’ve been on our sites. If we use cookies, it’s in line with current EU and UK laws.

Cookies are used by us to work out how many unique users we get to our sites, recognise if a user has visited us before, and log information about your device to allow us to track website usage and resolve problems. We use Google Analytics to gather statistics on site usage. Google may aggregate data they receive and we have no control over their data collection.

We also use them to customise the website to mobile / tablet / desktop users and track how effective our advertising has been (by recording which links etc got you to us in the first place).

4. Transferring Data to 3^rd Parties – Overview

We’ll only transfer data to third parties:

When its necessary to fulfil your enquiry or application
When you request us to
When we have to by law (e.g. to verify you or if we are required to inform any regulator / ombudsman / government agency)
If we buy or sell any business or assets
For our legitimate interests; for example, identifying customers to our advertisers to tailor our advertisements (your data is not used by them in any other way), or sharing customer data with Trustpilot

If, for any reason, we transfer your data outside the European Economic Area (for example if a supplier’s servers are held overseas) we make sure appropriate protection is in place.

5. How Long Do We Keep your Data?

Pensions and Equity Release are long term products, so if you make an application with us we keep the data we used to assess suitability indefinitely.

Where you have not made an application with us, but we hold some personal data, we delete data if we no longer need it. You can of course ask us to delete any information we do not need at any time (see section 6 below).

6. Your rights

You have rights around what happens to your personal data:

Right of access – we will supply a copy of your personal data on request, you can contact us at compliance@imperiumadvice.com
Right to rectification – if you think we have something wrong, you can tell us and we’ll put it right
Right to erasure – you can ask us to delete personal data because you don’t want us to hold it anymore. Please note if you have made an application with us there are certain things we have to keep to comply with law or regulation. We’ll tell you if there’s anything we can’t delete, and why.
Right to restriction of processing – if you think we are handling your data inappropriately, but you still want us to retain it, you can ask us to restrict what we do with it.
Right to data portability – you can ask us to transfer any data we hold about you to someone else

The Information Commissioner’s Office has more information about each of these rights here.