Privacy policy

Lubbock Fine is committed to protecting the privacy of those with whom it interacts, and Lubbock Fine recognises the need to respect and protect information that is collected or disclosed to us (called "Personal Information", explained below).

This Privacy Notice is intended to tell you how we use your Personal Information and is in a layered format to give you enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can't find the information you need, you can contact Lubbock Fine by reference to the details set out in section 1 below.

1. Who we are

Lubbock Fine and its related legal entities provide financial planning, financial advice, investment management services and accountancy and tax services (the "Lubbock Fine Group"). The Lubbock Fine Group consists of the following entities:

• Lubbock Fine LLP
• Lubbock Fine Wealth Management LLP
• Lubbock Fine Resourcing Limited
• Russell Bedford (Dubai) Limited
• Lubbock Fine Limited

This privacy notice is issued on behalf of the Lubbock Fine Group so when we mention "Lubbock Fine", "we", "us", or "our" in this privacy notice, we are referring to each of the legal entities which make up the Lubbock Fine Group and which (1) is the contracting party for the purposes of providing or receiving services, (2) posted a position for which you are applying; or (3) you have a role or relationship with. We are the controller of your Personal Information (as defined below).

Lubbock Fine LLP is the entity responsible for this website and it has a current registration (number ZA829353) in the Data Protection Register. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the following details:

• Lubbock Fine, Paternoster House, 65 St Paul's Churchyard, London, EC4M 8AB
• +44 (0)20 7490 7766
• dataprotection@lubbockfine.co.uk

2. What is Personal Information, and which Personal Information do we collect about you?

For the purposes of this Privacy Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.

We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

• Identity and Contact Data includes first name, last name and title, address, email address and telephone number.
• Applicant Data includes Identity and Contact Data about job applicants, CV, professional experience, education, academic and professional qualifications, information provided and collected from interviews and assessments and references from your named referees.
• Financial Data includes your bank account details, investment and pensions details, your business interests and shareholdings, income and tax codes and identifiers
• Technical Data includes internet protocol (IP) addresses, usage session dates and duration, page views, how you use our website the type of browser used while visiting our website and the numbers of users who visit our website.
• Services Data includes information about how you use our services, details of which services you have received from us, our correspondence and communications with you and information about any complaints or enquiries you make to us.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Special categories of data includes information about your health.
• Criminal convictions data includes information about criminal convictions and offences.

We also collect Identity and Contact Data about your close family members and dependants in order to provide our service to you effectively.

We also collect, use and share aggregated anonymous or pseudonymised data, such as statistical or demographic data for any purpose. This data could be derived from your Personal Information but is not considered personal data in law as it does not directly or indirectly reveal your identity.

For example, we may anonymise your Services Data to analyse which demographic of users are using our services.

However, if we combine any of this data with your Personal Information so that it can directly or indirectly identity you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

3. How is your Personal Information collected?

We collect information when a user visits our website, and/or contacts us whether by the telephone, email or post. We use different methods to collect data from and about you including:

a). Personal Information that you provide directly. You may give us your Identity and Contact Data, and the Identity and Contact Data of your close family members and dependents, Marketing and Communications Data, Services Data, Special Categories of Data and Criminal Convictions Data by filling in forms, requesting information about our services, subscribing to our services or by corresponding with us by email, phone or otherwise.

You may give us your Applicant Data if you apply for a job with us.

b). Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies. Please see section 10 below.

c). Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from third party analytics providers, such as Google Analytics.
• Identity and Contact Data from third parties such as your employer, our clients, or from our member network firms.
• KYC ('know your customer') information from Dow Jones and/or Experian.
• If you are applying for a job with us, we may collect Identity and Contact Data and Applicant Data from your previous employer or recruitment agency, as well as professional social networking sites such as LinkedIn.
• Identity and Contact Data from publicly available sources, such as Companies House or the Land Registry.

4. How do we use your information?

We will only use your Personal Information when the law allows us to do so. Most commonly, we will use your Personal Information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The Legitimate Interests we rely on are set out next to each purpose below.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Information although we will get your explicit consent to process any Special Categories of Data.

Purposes for which we will use your Personal Information

We may use the Personal Information that we collect for the following purposes. For each purpose, we describe the legal bases we rely on to justify such use of your Personal Information.

Marketing communications

We may use your Personal Information to provide you with email notifications and other communications by email, on the basis that it is in our legitimate interests to use your Personal Information for these purposes in developing our services and growing our business. For further information on this, see the 'Your Choices' section of this Privacy Notice.

Combining Personal Information

We may combine the Personal Information that we collect from you (including information received from other members of the Lubbock Fine Group) to the extent permitted by applicable law. For example, we may combine various different databases that contain your Personal Information to allow us to provide better support services and more personalised content (such as marketing).               

Change of purpose

Where we need to use your Personal Information for another reason other than for the purpose for which we collected it, we will only use your Personal Information where that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. To whom do we disclose your information?

​We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We may disclose your information to the following entities:

• Members of the Lubbock Fine Group
  We may need to transfer your Personal Information to other members of the Lubbock Fine Group to provide the services and/or any assistance you request. All Lubbock Fine Group members are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.
• Service Providers
  We use third party service providers to help us to administer certain activities and services on our behalf, such as IT and cloud services, administration services, marketing services and banking services.  We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
  a) IT Service Provider - we use Exponential-e Ltd to provide us with IT and cloud services
  b) Administration services - we use Oyez Professional Services Ltd to provide us with administration services
  c) Marketing services - we use Nu Creative Ltd to provide us with marketing services
  d) Banking services - we use Barclays PLC to provide us with banking services
• Anonymous statistics
  We prepare and develop anonymous, aggregate or generic data and statistics for various reasons (such as aggregate usage statistics including "page views" on the website, and analysing how users use our content). As this data is anonymous (i.e. you cannot be identified from it) we do not consider this information to be Personal Information. As such, we may share it with any third party (such as other members of the Lubbock Fine Group, our partners, advertisers or otherwise).
• Third parties when required by law
  We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies (in which case such agencies or regulators will be acting as controllers as well); to protect the users of the website (e.g. to prevent spam or attempts to defraud them); to operate and maintain the security of the website (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property.
• Other parties in connection with corporate transactions
  We may disclose your Personal Information to a third party (or other member of the Lubbock Fine Group) in the event that all or substantially all of our business or assets are or are intended to be sold or otherwise assigned to another entity.
• Other parties at your direction
  We may share Personal Information about you with third parties when you request such sharing, such as your legal or other professional advisers.

6. What do we do to keep your information secure?

We are certified by the government backed Cyber Essentials scheme, protecting our firm against common cyber-attacks.

​We have put in place appropriate physical and technical measures to safeguard your Personal Information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. When we use service providers to assist us in processing your Personal Information, we have written contracts in place with such service provider which means that they cannot do anything with your Personal Information unless we have instructed them to do it.

However, please note that although we take appropriate steps to protect your Personal Information, no website or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

International Transfer of Data

The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to the United States of America, the United Arab Emirates or in any other country where Lubbock Fine, other members of the Lubbock Fine Group or our service providers maintain facilities.

By using the website and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located.

Where we transfer your Personal Information outside the EEA to third parties, we will ensure that appropriate transfer agreements and mechanisms, such as the EU Standard Contractual Clauses, are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. We will only transfer your Personal Information outside the EEA in accordance with applicable laws or where you have given us your consent to do so.

7. Data retention - How long we will store/keep your personal information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 are subject to regulatory requirements to retain your data for specified minimum periods. These are generally:

• Six years for audit files and working papers
• Six years for accounts preparation working papers
• Six years for general tax papers including correspondence
• Five years for investment business
• Indefinitely for pension transfers and opt-outs
• Three years for insurance business

These are minimum periods during which we have a legal obligation to retain your Personal Information. We reserve the right to retain data for longer where it is in our legitimate interests to do so, including for back-up and archival purposes.

When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

In some circumstances you can ask us to delete your Personal Information (see section 8 below).

8. Accessing your personal information and other rights you have 

​Lubbock Fine will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Information:

• Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
• Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time.  In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 1.
• Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
• Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
• Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.
• Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information.
• Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
• Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.

Enforcing your rights

If you wish to enforce any of your rights under applicable data protection laws, then please see section 1 below. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.

Complaints

If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner's Office (www.ico.gov.uk) which is the data protection regulator in the UK which is where Lubbock Fine is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.

9. Third party links

Our website may contain links to other third party websites that are not operated by Lubbock Fine. These linked sites and applications are not under Lubbock Fine's control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

10. Cookies

For more information on how we use cookies, please see our cookie policy.

11. Your preferences (e.g. marketing related emails or otherwise)

When you request information on or from the website, or otherwise communicate with us, we and other members of the Lubbock Fine Group may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you marketing-related correspondence by email related to our products. When we process your Personal Information for marketing purposes, we do so on the basis that we have obtained your consent to use your Personal Information for these purposes, or on the basis that we are permitted to do so as it is in our legitimate interests, namely the promotion of our business.

We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.

We do not share your Personal Information for marketing purposes with companies outside of the Lubbock Fine Group.

To opt out of receiving marketing-related correspondence from Lubbock Fine, please click "Unsubscribe" from any marketing or promotional email you receive from us.

12. Changes to this Privacy Notice​

It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on our website.

Last updated: 10 May 2021