Welcome to the Y TREE Limited (Y TREE) Privacy Policy.
Y TREE respects your privacy and is committed to protecting your personal data. This Privacy Policy will provide you with information on how we handle the personal data that you or third parties provide to us. It will also outline your privacy rights and explain how the law safeguards your information.
Please refer to the Glossary for an explanation of certain terms used in this Privacy Policy.
In signing our Terms & Conditions you have agreed to provide this Privacy Policy to all individuals whose personal data you provide to us so that they can understand how we will process their personal data. Please share a link to this page with them.
This Privacy Policy will give you information on how Y TREE collects and processes your personal data through our Y TREE platform which includes our mobile app, the use of our website and any other medium we make available to provide our products and services and our advice to you (the “Y TREE Platform”). This encompasses all interactions, including both face-to-face meetings and digital communications.
By ‘personal data’ we mean any information about you that you or third parties provide to us. It does not include data where your identity has been removed (anonymous data).
Privacy is fundamental to our relationship with clients and we are committed to protecting your personal data and privacy online and maintaining the confidentiality and security of that personal data. Your personal data will be used for a number of different
purposes such as delivering our services to you and others, as well as fulfilling our legal and regulatory obligations.
It is important that you read this Privacy Policy together with any fair processing policy or notice 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 Policy supersedes any other privacy policy with us.
By using our Y TREE Platform you acknowledge that you have read and understood this Privacy Policy.
Y TREE is the controller under UK applicable data protection law and is responsible for processing your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Policy).
We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy. If
you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Officer in the following ways:
Full name of legal entity: Y TREE Limited
Email address: dpo@y-tree.com
Postal address: 130 Shaftesbury Avenue, London, W1D 5EU
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 decide whether you would like to contact us in the first instance.
Our Privacy Policy is reviewed regularly. This version was last updated in July 2024.
It is important that the personal data we hold about you is accurate and current. Please inform us if there are any changes to your personal data during your relationship with us. We retain the right to modify this Privacy Policy periodically by updating it on our Y TREE platform.
The Y TREE Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Y TREE Platform, we encourage you to read the privacy policy and the terms and conditions/site terms of every website you visit.
We may collect, use, store or otherwise process different kinds of personal data about you which we have grouped together as follows:
The Data Aggregation Service which we reference in our Terms & Conditions, involves the aggregation of what we refer to in our Terms as Client Financial Information, processing the information into an aggregated financial view and presenting it to you. The Data Aggregation Service involves us processing personal data about you in order to present your own investment information in an aggregated way on the Y TREE Platform. When we use the term ‘aggregation’ in this particular way, we do not mean that we use anonymous data for the Data Aggregation Service. Instead, we use your personal data for this service. There is more detail about this in our Terms & Conditions. It is important to distinguish between personal data used for the Data Aggregation Service and Behavioural Data (below).
We will collect, use, and share Behavioral Data, such as statistical or demographic data, for various purposes. Behavioral Data may be derived from your personal data; for instance, we may remove all identifiers from data sets (i.e. anonymise) so that the remaining information cannot be linked to any person. This anonymised data is not considered personal data under UK data protection law since it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific platform feature. However, if we combine or link Behavioral Data with your personal data in a way that can directly or indirectly identify you, we treat the combined data as personal data, and it will be used in accordance with this Privacy Policy.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us. We will notify you of this if necessary.
When applicable law allows us to do this, we will, in our absolute discretion, record, monitor and retain all communications (which may include the recording and monitoring by a third party appointed by us), including email and other electronic messaging, telephone conversations, face to face conversations, transcriptions of physical and digital meetings and other electronic communications with you (including communications via the Y TREE Platform). We will normally record telephone conversations and keep copies of relevant electronic communications (and may record mobile phone or other mobile handheld electronic communications device based conversations) between you and us. We may rely on these recordings in the event of a dispute.
The types of personal data relevant to this includes all data as listed in the bullets above. If you mention any of that data in your communications with us, or if we do that, it will be processed when we record and monitor communications.
We use different methods to collect data from and about you including through:
We may record calls for quality and training purposes to enable us to deal effectively with queries and complaints, improve our service and to fulfil our regulatory obligations.
We will only use your personal data when permitted to do so by law. Most commonly, we will use your personal data in the following circumstances:
Please refer to the Glossary below for further details on the types of lawful basis we will rely on to process your personal data.
Typically, we do not use consent as the primary legal basis for processing your personal data. However, if you are a prospect and not a client, we will seek your consent before sending direct marketing communications. For clients, we may, in certain instances, rely on legitimate interests instead of consent.
The table below references both consent and legitimate interests for marketing via email or electronic means. You retain the right to object to marketing at any time by contacting us. Further details are provided below.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To undertake checks on you and/or members of your Family Group |
(a) Identity (b) Contact (c) Financial (d) Vetting (e) Family |
(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to ensure you are not involved or connected with an illegal activity and that our services are suitable for you) |
| To respond to queries from you via our website (before you become our client) |
(a) Identity (b) Contact (c) Other Data requested on our site |
For our legitimate interests in corresponding with individuals making enquiries via our website |
| To register you as a new customer |
(a) Identity (b) Contact (c) Financial (d) Profile (e) Skills Data |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms, services or Privacy Policy (b) Asking you to leave a review or take a survey (c) To deal with complaints brought under our complaints policy (described on our website) |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Skills Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| Direct marketing communications (which means anything other than providing the Y TREE services). |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Skills Data |
(a) In the case of electronic marketing (for example, emails), for some clients we have consent, for other clients we rely on this as being necessary for our legitimate interest and for our own marketing to you about our own products/services/advice. You will know which lawful basis applies to our email/electronic marketing because consent means we ask for an opt-in from you whereas legitimate interests means we offer you the opportunity to opt-out. (b) In the case of marketing by post, telephone or face to face interactions (not emails or electronic) we rely on this as being necessary for our legitimate interests if you are our client and for our own marketing to you about our own products/services/advice. |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c ) With your consent |
| To administer and protect our business and the Y TREE Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (c) Necessary to comply with a legal obligation |
| To deliver Y TREE Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) With your consent |
| To use data analytics to improve the Y TREE Platform, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage (c) Activity (d) Profile |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Y TREE Platform Updated and relevant, to develop our business, improve our services and service delivery and to inform our marketing strategy) Note that by law we will need to ask you for a consent to place cookies on your machine/device – that is not our lawful reason under data protection laws for processing the underlying data that we collect when we use those non-essential cookies, instead it is in our legitimate interest (as above) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) – this is the lawful basis for the underlying analysis about what might interest you. |
| For recording and monitoring of communications |
a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security,to improve our services and service delivery, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| For our Data Aggregation, Reporting and Analysis Service |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Activity |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To calculate the percentage of users accessing a specific Y TREE Platform feature or your currency exposure, market risk levels and other exposures and liquidity |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Activity |
Necessary for our/your legitimate interests (to improve the Y TREE Platform features and functionalities as to assist you in understanding your own investment information). |
| To make sure that we take account of your health and/or vulnerability status or that of a member of your family so that we can provide our services to you in an appropriate way. |
(a) Identity (b) Contact (c) Health Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) In addition, we need a supplementary legal basis to process Health Data because it is a sensitive type of data. We will ask for your explicit consent or that of your family member (for example if they are a joint account holder) unless the law allows us to process this type of data for other very limited reasons. This is the case when we need to process your Health Data for the establishment, exercise or defence of legal claims or for reasons of substantial public interest. Those substantial public interest reasons come from the UK’s Data Protection Act 2018. |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
On our Y TREE Platform, we request that you tick a box if you would like to receive communications from Y TREE, indicating your consent.
You can request to cease receiving marketing messages from us at any time by contacting us through the provided contact details in this Privacy Policy. Each marketing email and other electronic marketing communication from us will include a reminder of this option and will provide instructions on how to unsubscribe.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies on our website, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.
We will only utilise your personal data for the purposes for which we initially collected it, unless we reasonably determine the need to use it for another compatible reason. If you require an explanation regarding how the processing for the new purpose aligns with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis upon which we rely to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and in accordance with this Privacy Policy.
We will not sell or transfer your personal data to anyone unless necessary as part of a restructuring or sale of our business or assets or unless we have another valid purpose as set out above. We will only disclose it to third parties as service providers if they have entered into contractual arrangements with Y TREE. This includes third parties who provide services we need to carry out our everyday business activities such as IT suppliers including IT support, cloud platform and data hosting providers who help us with the operation of our Y TREE Platform, systems and applications; third party debt recovery organisations where we need to recover money owed to us; marketing service providers including companies who send out surveys and marketing communications on our behalf; survey providers who help collate client feedback for us; and website providers.
We require all third parties who are our processors (sometimes called data processors) to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers 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.
It is different when we need to disclose your data to the Court, regulators and law enforcement authorities. We do not need contracts with those recipients of personal data.
There are a small number of instances where your personal data may be transferred to countries outside of United Kingdom (“UK”) and/or the European Economic Area (“EEA”) such as when we transfer information to third party suppliers who are based outside of the UK and EEA or when third parties who act on our behalf transfer your personal data to countries outside the UK and EEA. Where such transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal data is adequately protected. We will do so in a number of ways including:
Sometimes we can transfer your personal information to countries outside the UK and EEA where it is necessary for the performance of the contract we have with you.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA to countries which do not have adequacy under UK data protection laws.
We are required by law to put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors within our own organisation/working for us and other third parties that have a business need to know (other than the Court, regulators and law enforcement authorities because business needs are not relevant to them). Our own people and our own processors (service providers) will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data (more on this below).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Please see the reference to Behavioural Data above.
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
If you wish to exercise any of the rights set out above, please contact us.
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.
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) especially in circumstances when we do not already know that you are the person contacting us. If you contact us via the Y TREE Platform we would not usually need this extra information.
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 from the date on which we receive the request or (if later) the date on which we have the proof of identity/verification detail mentioned above. 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.
If you ask a third party to make a request we will usually need to make sure that they have your authorisation so we will ask for that along with proof of identity/verification. Our time limit for responding won’t start until we have all that information from them.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold on you, as well as some supplementary information about it, and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have withdrawn your consent (this might be relevant to marketing to – as explained above), where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes . In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you as required by applicable UK data protection law.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Object to automated decisions being made about you using your personal data. We are only mentioning this right for completeness so that you know it is part of UK data protection law. We do not use your personal data to make decisions about you based solely on automated processing using a computer not a human and the law only lets people do that in the UK if it is necessary for entering into or for performing a contract, is authorised by local law, or is with your explicit consent. If we were going to start to use your personal data in this way we’d update our Privacy Policy and we’d notify you about that.