Privacy policy
This policy (together with any other documents referred to in it) explains how your personal data is collected, processed and protected. By visiting and using the Dodl app and website (dodl.co.uk), you are accepting and consenting to the practices described in this policy.
From time to time, the app or website may contain links to and from other websites, including those of our advertisers and affiliates. If you follow a link from/to any of these websites, please note that they have their own privacy policies and we don’t accept any responsibility or liability for your data if you choose to use these websites. Please check these policies before you submit any personal data to these websites.
This policy includes:
- Details of the types of personal data Dodl may collect and store
- The legal basis for using your personal data
- How Dodl captures and receives this personal data
- How Dodl uses your personal data
- How Dodl may disclose and share your personal data with third parties
- Where Dodl stores and protects your personal data and how long it will be held for
- Your legal rights in relation to your personal data Dodl holds
- How you can get in contact for more information
AJ Bell Management Limited (company number 03948391) and AJ Bell Securities Limited (company number 02723420), both of which are registered in England and Wales at 4 Exchange Quay, Salford Quays, Manchester M5 3EE, may act as data controller.
Dodl has appointed a Data Protection Officer who can be contacted at the address shown above or by email at hello@dodl.co.uk.
The table below confirms the personal information Dodl collects from you, along with why your data is collected and the legal basis for doing so:
Residential and contact information | |
---|---|
Data collected: |
Including details of your:
|
Purpose of processing: |
Verifying your identity Contacting you about products, services, regulatory obligations, and contractual obligations Seeking your consent for transactions and changes to terms and conditions |
Legal basis: |
In order to fulfil our contractual obligations to contact you and update you on product changes, and in order to comply with regulatory requirements |
Socio-demographic | |
Data collected: |
Including details of your:
|
Purpose of processing: |
Developing products and services Defining customer types and target markets Complying with regulatory requirements and managing risk effectively |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements |
Family circumstances | |
Data collected: |
Including details of your:
|
Purpose of processing: |
Understanding your circumstances Paying benefits appropriately from your account/s |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory and legislative requirements |
Transactional information | |
Data collected: |
Including details of:
|
Purpose of processing: |
Efficiently completing transactions you instruct, or that we must undertake for legal or regulatory reasons. |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements |
Technical | |
Data collected: |
Each time you visit the website, we may automatically collect the following information:
|
Purpose of processing: |
Developing products and services Defining customer types and target markets |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements |
Special and one-off items of information | |
Data collected: |
Including details of your:
|
Purpose of processing: |
Paying benefits appropriately from your account/s |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements |
Legal | |
Data collected: |
Including:
|
Purpose of processing: |
Verifying your identity, authority and eligibility in relation to the products and services we provide to you |
Legal basis: |
In order to fulfil our contractual obligations and in order to comply with regulatory requirements |
The legal basis for using your personal information
Dodl will only collect, use, and share your personal information where there’s an appropriate legal basis to do so. This may be because:
- you’ve provided your consent to Dodl using your personal information– for example, when you opened your account and agreed to our terms and conditions
- the use of your personal information is in Dodl’s legitimate interest as a commercial organisation – to verify your identity or communicate with you about the products and services that you use or may wish to use. In these cases, Dodl will look after your information at all times in a way that is proportionate and respects your privacy rights. You have a right to object to processing, as explained below
- Dodl’s use of your personal information is necessary to perform a contract or take steps to enter into a contract with you – for example, on opening an account for you or instructing an investment
- Dodl’s use of your personal information is necessary to comply with a relevant legal or regulatory obligation, for example providing information on investment transactions to the FCA and reporting holdings, payments, accruals, and charges to the relevant tax authorities
If you would like to find out more about the legal basis for which we process personal information, please get in touch via the in-app chat.
Information you give
You may give information by filling in forms on the app or website or by getting in contact by phone, email or otherwise. This includes information you provide when you register to use Dodl, apply for an account, search the app, enter a competition or promotion, take part in a survey, or when you interact with the app or website in any other way. This also includes any occasions when you report a problem with the app or website. The information you give may include your name, address, email address, phone number, financial information and/or other relevant personal details.
By submitting such details, you confirm that you are entitled to disclose information about, or provided by, any third party.
Information Dodl receives from other sources
Information about you may also be received if you use any of the other platforms or services operated or provided by Dodl. In such cases, when the data is collected, you’ll be informed that it may be shared internally and combined with data collected on the app or website. Dodl also works closely with third parties (including, for example, business partners; external/third party service providers in technical, payment and delivery services; advertising networks; analytics providers; search information providers and credit reference agencies), and may receive information about you from them.
If you authorise a third party to contact Dodl on your behalf, this entitles them to provide, and for them to receive, information about you or the services you have with Dodl. Before any information about your account(s) is provided, Dodl will always verify the third party’s identity and right to access your information. Please see the app or website terms of use for more details.
Cookies
The Dodl website and mobile app uses cookies to distinguish you from other users. This helps to improve your experience when browsing the app and website. For detailed information on the cookies used and the purposes for which they are used, see the cookie policy.
Disclosure of your information
Your personal information may be shared with any member of the AJ Bell group, which Dodl is a part of. Full details of the companies in our group are available on request by email to hello@dodl.co.uk.
Information is shared amongst the subsidiaries to ensure that each business unit which provides platform and pension administration services has the information it needs to efficiently and effectively process transactions and other administrative duties on your behalf. It also means they comply with regulatory requirements and reporting obligations.
Your information may be shared with selected third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract Dodl enters into with them or you, including but not limited to:
- investment providers regulated and authorised to provide investment services in the United Kingdom
- data and software providers
- regulatory and tax authorities
- credit reference and fraud prevention agencies - to find out more about TransUnion (a credit reference agency) please visit their website
- analytics and search engine providers that help to improve and optimise the app and website.
Your personal information may be disclosed to third parties in the following circumstances:
- Dodl or any Group company buys any business or assets, in which case your personal data may be disclosed to the prospective seller or buyer;
- if all of part of Dodl is sold, in which case the personal data held about Dodl’s customers will be transferred to the buyer; or
- if Dodl is required to disclose or share your personal data in order to comply with a legal obligation, or to enforce or apply Dodl’s rights under this policy or terms and conditions and other agreements; or to protect the rights, property, or safety of any member of the Group, Dodl’s customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How Dodl stores and protects your personal data
Your data will primarily be held in the UK but there may be occasions when the data that collected from you is transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for Dodl or for one of our suppliers. These staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Dodl will take all steps that are reasonably necessary to ensure your data is treated securely and in accordance with this privacy policy.
All information you provide is stored on Dodl’s secure servers. Any payment transactions will be encrypted using SSL technology. You are responsible for keeping confidential any password Dodl has given you, or you have chosen, which enables you to access certain parts of the app. It’s important you don’t share a password with anyone. If you (or your representative) get in contact for details of your account, Dodl will ask some questions so that yours (or your representative’s) identity can be established. Details won’t be disclosed without satisfaction that you (or your representative) are who you claim to be.
Unfortunately, transmitting information via the internet can’t be completely secure. Although Dodl will do its best to protect your personal data, the security of your data transmitted to the app or website can’t be guaranteed; any transmission is at your own risk. Once your information is received, strict procedures and security features will be used to try to prevent unauthorised access. Dodl strongly suggests you purchase and keep up-to-date software to protect the security of your computer or device.
How long your personal data will be stored for
Your personal data will be stored for the duration of your relationship with Dodl. After that, your personal data will be stored for as long as it is legal, appropriate and necessary to do so. This includes retaining the checking/verifying identity data (that is, all anti-money laundering data) for 5 years. Other information may be stored for longer than 10 years if needed to evidence that regulatory requirements have been met and to demonstrate that information on your account(s) have been correctly recorded and reported to the relevant authorities.
Your rights
You have the following rights when it comes to your data that Dodl holds:
The right to access
You have a right to request that Dodl provides you with a copy of the personal information held on you. You also have the right to be informed of (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities your personal information may be transferred to.
The right to rectification
You have a right to request that inaccurate personal information be rectified. Dodl may seek to verify the accuracy of the personal information before rectifying it.
The right to erasure
In limited circumstances, you can request that your personal information be erased if:
- it’s no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which you are subject.
Dodl aren’t required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
The right to restriction of processing
You can ask Dodl to restrict your personal information, but only where:
- its accuracy is contested, to allow for verification of its accuracy; or
- the processing is unlawful, but you don’t want it erased; or
- it’s no longer needed for the purposes for which it was collected, but it’s still needed to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
Dodl can continue to use your personal information following a request for restriction, where:
- your consent has been given; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
The right to object to processing
You can object to any processing of your personal information which has Dodl’s legitimate interests as its legal basis – providing you believe your fundamental rights and freedoms outweigh Dodl’s legitimate interests.
If you raise an objection, Dodl will need to demonstrate that there are compelling legitimate interests which override your rights and freedoms in order to continue processing your data.
The right to portability
You have the right to ask Dodl to provide you with an electronic file containing all personal information held about you. You can give this information to other organisations if you wish to.
Right to object to how we use your personal information for direct marketing purposes
You also have the right to ask Dodl not to process your personal data for marketing purposes.
You can choose the communications sent to you by using the communication preferences area of our app or by using the manage preferences links in our emails. However, keep in mind you can’t opt-out of receiving regulatory or legal updates (e.g. information about a change in the product terms and conditions) by email. Dodl regularly reviews its records to ensure that your personal details are only retained for as long as is necessary for the purposes set out above.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
Dodl may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
If you have concerns about how your personal information is processed, you have a right to lodge a complaint with your local supervisory authority.
Dodl asks that you please attempt to resolve any issues directly first by getting in contact – although you have a right to contact your supervisory authority at any time.
Access to information
Before sending you a copy of the personal information you requested, Dodl may ask you for additional information to confirm your identity and for security purposes. Dodl reserves the right to charge a fee where permitted by law – for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by getting in contact. Subject to legal and other permissible considerations, Dodl will make every reasonable effort to honour your request promptly, or inform you if further information is required in order to fulfil your request.
Dodl may not always be able to fully address your request, for example if it goes against the duty of confidentiality owed to others, or if Dodl is legally entitled to deal with the request in a different way.
Changes to Dodl privacy policy
Any changes that may be made to Dodl’s privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please note that updates to this policy are not emailed as a matter of course, so please check back frequently to see any updates or changes to Dodl’s privacy policy.
Contact
Please send any questions or comments about this policy via the in-app chat or email at hello@dodl.co.uk