A lot has been written about how to achieve good outcomes for members of defined benefit (DB) pension schemes. A strong employer covenant, well-managed investments...
Information relating to the privacy policy of the site
This section contains information with reference to the users of the (brightwellpensions.com) website, and how we process their data.
This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003 (Section 7: Right to access personal data and other rights.), and for the purposes of Article 13 of UK GDPR / Data Protection Act 2018 no. 2016/679, concerning the protection of individuals regarding the processing of personal data and the free movement of such data for subjects who interact with the Brightwell homepage:
The information is provided only for (brightwellpensions.com) and not for other websites that may be consulted by the user through links contained therein.
The purpose of this document is to provide information on the methods, timing and nature of the information that the data controllers must provide to users when connecting to the web pages of (brightwellpensions.com) regardless of the purpose of the connection itself, according to UK and European legislation where applicable.
The information may undergo changes due to the introduction of new rules in this regard, therefore the user is invited to periodically check this page.
Data processing
1. Data Controller
The controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. He also deals with security profiles.
With regard to this website, the data controller is: BTPSM trading as Brightwell (Registered in England and Wales No. 05154287, VAT GB 300737635) with registered office at One America Square, 17 Crosswall, London, EC3N 2LB can be contacted by telephone at 020 3978 5100 or by email hello@brightwellpensions.com.
2. Responsible for data processing
The controller is the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Pursuant to Article 28 of UK GDPR / Data Protection Act 2018 no. 2016/679, upon the appointment of the data owner, the person responsible for the processing of site data.
3. Place of data processing
The processing of data generated by the use of brightwellpensions.com takes place at One America Square, 17 Crosswall, London, EC3N 2LB and BTPSA Ltd, Venture House, Venture Way, Chesterfield, S41 8NR
If necessary, the data related to the newsletter service may be processed by the data controller or persons appointed by him for this purpose at the relevant office.
Cookies
1. Type of Cookies
The site brightwellpensions.com uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his preferences or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user’s expectations, offering a more personalised browsing experience and remembering choices made previously.
A cookie consists of a small set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.
Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent the saving of some or all cookies. However, in this case the use of the site and the services offered may be compromised. To proceed without changing the options relating to cookies, simply continue browsing.
Below are the types of cookies that the site uses:
2. Technical cookies
This website uses small text files called ‘cookies’ which are placed on your computer or device whenever you visit our website. This allows the site to remember who you are and serves several purposes. Below is a list of the cookies used on this website:
Purpose
Name
Description
Strictly Necessary
ASP.NET_SessionId
Our cookie ensures that you are logged in securely and only you see your information for the duration of your visit.
Security
__AntiXsrfToken
Used as a security measure against hackers to stop cross site scripting.
Security
AuthCode
Used as a security token during login and registration.
Site Appearance
ComplianceCookie
Used to indicate that you have read this notice.
Analytical
_ga; _gat (Google Analytics)
We use Google Analytics to help us understand how users use our web site. This allows us to improve the quality and content on our site for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web site. Click here to learn more about Google Analytics and deleting or rejecting the Google cookies.
The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of his Internet browser. This deactivation may slow down or prevent access to some parts of the site.
The use of technical cookies allows the safe and efficient use of the site.
The cookies that are inserted in the browser and retransmitted through Google Analytics or through the statistics service of bloggers or similar are technical only if used for site optimisation purposes directly by the owner of the site, which can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies.
From the point of view of duration, temporary session cookies can be distinguished that are deleted
Data processed
1. Data processing methods
Like all websites, this site also uses log files in which information collected in an automated manner is stored during user visits. The information collected may be as follows: – internet protocol (IP) address; – type of browser and device parameters used to connect to the site; – date and time of visit; – web page of origin of the visitor (referral) and exit; – possibly the number of clicks.
The aforementioned information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed based on the legitimate interests of the owner. – internet protocol (IP) address; – type of browser and device parameters used to connect to the site; – date and time of visit; – web page of origin of the visitor (referral) and exit; – possibly the number of clicks.
The aforementioned information is processed in an automated form and collected in an exclusively aggregated form to verify the correct functioning of the site, and for security reasons. This information will be processed based on the legitimate interests of the owner.
2. Purpose of data processing
The data collected by the site during its operation are used for the purposes indicated above and for the following purposes: – Purposes related to the data request for marketing and / or advertising activities by sending newsletters, through Google Ads / Facebook retargeting campaigns; – Purposes related to the management and provision of products and services offered by brightwellpensions.com – Purposes based on the consent of the interested party for the communication of their data to any partners of the Data Controller for the performance of contractual obligations.
The retention of data will be carried out for the period strictly necessary to achieve the aforementioned purpose and in any case not exceeding 7 years.
The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the purpose indicated above.
3. Data provided by the user
As indicated above, the optional, explicit, and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.
4. Support in configuring your browser
The user can also manage cookies through the settings of their browser. However, deleting cookies from your browser may remove the preferences you have set for the site.
For more information and support you can also visit the specific help page of the web browser you are using.
User rights
Art. 13 – 23, c. III of UK GDPR / Data Protection Act 2018 lists the user’s rights.
The site therefore intends to inform the user about the existence of the rights of where personal data is collected directly from the data subject
If the processing is based on art. 6, paragraph 1, or on art. 9, paragraph 2 the user has the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Information Commissioners Office, as the authority responsible for monitoring Data Protection within the UK.
This site processes user data in a lawful and correct manner, adopting appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of your data. The processing is carried out using IT and / or telematic tools, with organisational methods and with logic strictly related to the purposes indicated.
In addition to the owner, in some cases, categories of employees involved in the organisation of brightwellpensions.com (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) may have access to the data.