Choices app - Privacy Notice
This Privacy Notice applies to the Choices app [‘Choices’] which can be downloaded from the Google Play and Apple stores.
Choices is provided by Standard Life Client Management (‘SLCM’ - a subsidiary of Standard Life Aberdeen plc; a global asset management company offering active wealth management, financial planning and advice services). Note – any reference within this Privacy Notice to ‘we’, ‘us’, ‘our(s)’ means Standard Life Client Management.
Choices is designed to help you to get the most out of your savings and investments and to provide you with better insights to make your money work harder. Currently, Choices will use insights from information collected on you (directly and via open banking) to identify relevant savings & investments products which may be of interest. As new products and features become available in Choices, we will send you a push notification and / or an email to provide you with more information and the option to invest in a range of similar savings & investment products and solutions offered by other subsidiaries of SLA plc (namely Standard Life Savings Ltd, 1825 Financial Planning and Aberdeen Standard Capital).
The remainder of this Privacy Notice contains important information about what personal (and other financial) information we will collect from you as a user of Choices and for what purpose(s), how we will use this information; who we may share this information with and why; and your choices and rights when it comes to the personal information shared with us.
If you have any questions about this Notice or the information we collect or use about you in connection with Choices, please contact;
FAO Data Protection Officer
Standard Life Aberdeen plc
1 George Street
We keep our Privacy Notice under regular review and may be required to make changes from time to time.
This version was last updated January 2021. It may change and if it does (perhaps as part of a version change to the app), changes will be notified to you when you next start Choices. The new notice may be displayed on-screen. We may also send you a push notification or an email to advise of any important changes for your attention.
Information about you that we collect and use includes:
- Information required for initial registration with Choices i.e. your name and email address
- Information to verify your identity i.e. email address and password
- Information connected to your finances e.g. your bank account details, income & expenditure, disposable income
- Information about your contact with us e.g. emails / calls
- Information about your priorities and goals e.g. savings goals / retirement planning
- Information that is automatically collected e.g. via cookies when you visit one of our websites
- Information connected to other people associated with you e.g. name, income & expenditure in relation to individuals named on joint bank accounts
We will collect your personal information directly from you, predominantly via the data you enter on Choices but also from analysis of your bank account (obtained via the open banking permissions granted to our partner, IDCO, as part of registering for Choices which is required to provide you with tailored messages to support your needs and goals).
If you are an existing customer of ours, we may also collect personal information from those records to understand you better and ensure any communication with you takes into account your existing products and services with us.
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:
- It’s necessary to provide the product or service you have requested e.g. if you wish to buy an ISA as part of Choices we may require personal information from you including your name, address, date of birth, national insurance number and bank account details.
- It’s necessary for us to meet our legal or regulatory obligations e.g. to send you important information including any changes to the Choices Terms and Conditions or for the detection and prevention of fraud
- It’s in our legitimate interests to process your information to better understand you and your needs so we can:
- send you in-app notifications to make you aware of other relevant products and services available from us or our 3rd party partners as part of Choices;
- further improve Choices and develop new functionality for users
- You have given us your permission [consent] to use your information e.g. when registering for Choices, we will ask if you wish to receive email communications from other subsidiaries of Standard Life Aberdeen plc about their savings & investments products and services (some of which may be available within Choices now or in the future). You can withdraw your consent at any time via the unsubscribe link on these emails or by contacting SLA_DPOffice@aberdeenstandard.com
We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the services or features we offer you now or in the future. We use automated decisions to tailor the functionality and products within Choices to support your financial priorities and needs e.g. placing you in groups with similar individuals to make decisions about the services we may offer you to help meet your needs.
We will also collect and use statistical and aggregated data e.g. the total number of app users, use of app features and functionality to support further development of the app and continually improve user experience.
We will be required to share your information with selected 3rd parties for the reasons outlined in ‘Why we collect and use your information’.
We will share your information with:
- Other parts of Standard Life Aberdeen plc who support us in the provision of Choices and the products and services available to you
- Our 3rd party partners:
- OKTA – delivering the secure functionality to support effective authentication of your details when signing into Choices to verify your identity
- IDCO – delivering the open banking functionality necessary to provide a secure connection to your nominated bank account and necessary insight into your finances to understand income & expenditure and available disposable income to save to meet your priorities and goals
- Companies we have chosen to support us in the delivery of Choices e.g. technology companies; software suppliers; or companies who can help us in our contact with you, for example an internet service provider
- Our regulators; including the Financial Conduct Authority (FCA) and the Information Commissioner’s Office for the UK (ICO)
- Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime
- HM Revenue & Customs (HMRC) for the processing of tax relief on ISA payments (where relevant) or the prevention of detection of tax avoidance
The majority of your information is processed in the UK or European Economic Area (EEA). However, some of your information may be processed by us or the third parties we work with in countries outside of the UK or the EEA. Where your information is being processed outside of the UK or the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties and Standard Life Aberdeen affiliates with ongoing oversight to ensure they meet these obligations.
To provide Choices and meet our legal and regulatory obligations, we will keep your personal information and copies of records we create while you are a customer [or prospective customer] of ours. If you do not proceed to use Choices and even when you no longer have a relationship with us, we will be required to keep your information for a period of time to meet our legal and regulatory obligations. The length of time will vary and we regularly review our retention periods to make sure they comply with all relevant laws and regulations.
We take the security of your information very seriously and strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, is for a defined purpose and will have appropriate safeguards applied in line with our data protection regime.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information whether it is being processed by us or a third party acting on our behalf.
We also use internal and external audit and specialist third party consultants to conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.
You have a number of rights under Data protection laws which may be exercised in certain circumstances.
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with - we do this in our Privacy Notice.
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
If your personal information is inaccurate or incomplete, you can request that it is corrected.
You can ask for your information to be deleted or removed if there is not a compelling reason for us to continue to have it.
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information - but only to ensure we don't use it in the future for those reasons you have restricted.
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you purchased an ISA via Choices and wanted to move this to another ISA provider.
You can object to us processing your personal information where: it’s based on our legitimate interests (including profiling) and for direct marketing via push notifications.
You have the right to ask us to:
- Give you information about our processing of your personal information
- Request human intervention or challenge a decision where processing is done solely by automated processes
- Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
If you require any more information on your rights and how to exercise them, you can email SLA_DPOffice@aberdeenstandard.com
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please email us at SLA_DPOffice@aberdeenstandard.com and we will do our utmost to make things right.
While we hope that we can resolve any complaints for you, you do have the option complain to the ICO (whether or not you have exhausted our complaints procedure).
The ICO's contact details are:
Information Commissioner's Office
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