Privacy Notice

This is a Privacy Notice for the Reality Group. We respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you about how we look after your personal data, and tell you about your privacy rights and how the law protects you.

At Reality Group we provide advice and services specifically relating to financial products. This requires us to collect personal and sensitive information from our clients based in the United Kingdom and internationally.

Collecting personal information about you is essential to our ability to conduct our business. We will only collect the information necessary for these purposes and we commit to protecting such information to the highest of standards.

This Privacy Notice applies to personal data which we collect and process in relation to all of the services we provide. It applies to any personal data which you may provide through our website, when you agree to receive any newsletter or other regular communications from us, or when you use any mobile application which we may develop for access to our services.

It is important that you read this Privacy Notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

This Privacy Notice sets out the information summarised in the table of contents below

• who we are
• the categories of personal data we collect
• our principles of data protection
• how we collect your data
• how we use your data
• who we may share your data with
• how we protect personal information
• retention of personal information
• your legal rights
• how to contact us

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1. who we are

Reality Group consists of three separate trading companies:

This Privacy Notice is issued on behalf of the Reality Group so when we mention “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Reality Group responsible for processing your personal data. Reality Capital Ltd is the controller and responsible for this website.

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2. the categories of personal data we collect

When we say ‘personal data’ we are referring to information about you from which you can be identified. Personal data does not include data where your identity has been removed (anonymised data). The personal data which we collect and process could include:

• your name and contact information such as your home and / or business address, email address and telephone number;
• identity and biographical information including your nationality, date of birth, tax status, passport /national identity card, details of country of domicile, your employment and employment history, job title and role, educational profile, interests and other
• information in relation to your financial situation such as income, expenditure, assets and liabilities, source of wealth, as well as your bank account details and other information necessary;
• technical data about your internet protocol (IP) address and the browsers/devices which you use to access our website;
• data about how you use our website; and
• information obtained from an understanding of your goals and objectives and other information provided to us in connection with our professional services.

We do not normally collect any ‘Special Categories of Personal Data’ about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

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3. our principles of data protection

Our approach to data protection has been built around our company principles which are at the heart of everything we do relating to personal data. We take a human approach to how we process personal data by being open, honest and transparent.

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4. how we collect your data

Most of the information we collect, we collect directly from you. When we are assessing the suitability of a transaction, we will ask you to provide certain personal information that may include, but not be limited to, the items listed under 2. The categories of personal data we collect.

Occasionally, we might collect personal data about you from other sources, such as publicly available materials or trusted third parties. We may use this information to supplement the personal data we already hold about you, to better inform, personalise and improve our services, and to validate the personal data you provide.

We collect only the information we need for the purposes we have identified to you and we will only use fair and lawful means to do so. Where we collect personal data, we will only process it to the extent that the law allows us to do so. Most commonly we will process your personal data:

• where we need to perform a contract we are about to enter into, or have entered into, with you; or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those legitimate interests; or
• where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

If you do not want to provide us with personal data, you do not have to, but it might mean we cannot perform our role to a suitable standard in order to meet your requirements.

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5. how we use your data

How we use your personal data will depend on whether you are a client, a representative of a client, a business contact or otherwise. First and foremost, we may use your personal data to conduct any services you’ve requested, and to manage our relationship with you. We may also use your personal data for the following purposes:

• providing a proposal to you or your organisation in relation to the professional services we offer and for client engagement purposes, which may include conducting background checks;
• managing our relationship with you and/or our clients, which could include sending you a newsletter or other regular communications about our services;
• collecting and providing information that may be required during the pre-contract phase and/or information we may require to commence the transaction;
• disclosing any information which you give to us to selected third parties for the purposes of finding the best available product for you and progressing any application;
• fulfilling our obligations under our terms of engagement, to inform you of any covenants that may fall due during the term of your facility;
• dealing with any complaints or feedback you may have; and
• any other purpose for which you provide us with your personal data.

We will never share your personal data with any third party for marketing purposes unless we have your express prior opt-in consent.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

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6. who we may share your data with

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

• third parties that may require personal information for us to fulfil our obligations to you under the terms of our contract. In the cases that we are yet to be formally instructed we would anonymise any personal data or achieve your prior consent;
• regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
• intermediaries or other professional advisers (such as accountants or solicitors) to whom we introduce you; and
• other people where we have your consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow any third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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7. how we protect personal information

Security is a priority for us when it comes to your personal data. We have comprehensive security procedures to safeguard and protect personal information against theft, loss, unauthorised disclosure, copying, and unauthorised use or modification. These include various organisational measures such as having appropriate policies, procedures and technological measures in place such as the use of passwords, two factor authentication and antivirus software.

We are responsible for all personal information in our possession. In some instances, service providers, representatives, lenders, insurers and any of their service providers, may be located in other jurisdictions. They will only process your personal data on our instructions and will be subject to a duty of confidentiality. If we need to transfer your personal data to any of these third parties outside of the United Kingdom we will only do so in compliance with data protection laws and by applying the relevant safeguards for the protection of your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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8. retention of personal information

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it. We will only keep your personal data in our records for as long as reasonably necessary to fulfil the purposes for which we collected it, or as required for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will retain your personal data for as long as we have a relationship with you and for a period of time afterwards to fulfil the purposes set out in this Privacy Notice. Personal data that is no longer required will be destroyed, erased or made anonymous. When we destroy personal data, we will use safeguards to prevent unauthorised access to the information during the destruction process.

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9. your Legal rights

Under data protections laws you have certain rights relating to personal data we hold about you. We will make all reasonable efforts to ensure that any personal information we collect and keep is accurate, complete and current as required for the identified purpose. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of any changes.

You have rights to:

• request access to the personal data we hold about you and other information;
• require us to correct any inaccuracies and ensure that the personal data we hold about you is correct and up to date;
• require us, in certain circumstances, to restrict processing, or to erase any of your personal data;
• object to our continued processing of your personal data;
• request restriction of processing of your personal data;
• request transfer of your personal data; and
• withdraw your consent, where our use of your personal data is based on that consent.

You can exercise these rights at any time by sending an email to enquiries@reality-group.co.uk or by writing to us at 4 Old Park Lane, Mayfair, London, W1K 1QW. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

If you do wish to access your personal data (or to exercise any of the other rights) we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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10. how to contact us

If you are not happy with how we are processing your personal data, please let us know by sending an email to enquiries@reality-group.co.uk or by writing to us at 4 Old Park Lane, Mayfair, London, W1K 1QW. We will review and investigate your complaint and try to get back to you within a reasonable time frame. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We keep this Privacy Notice under regular review. This version was last updated on 1st July 2020.

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