How we deal with your data. Our Privacy Policy.

This policy sets out the basis on which the personal or other data collected from you, or that you provide to us (moneyinfo limited), will be protected by us and how that information will be used. It describes the kinds of information we may collect from or about you, how we use that information and your rights to access and control our use of your information.

1. The privacy & security of your data is maintained at all times.

The security and privacy of your information is extremely important to us and we have implemented appropriate technical and organisational security measures to ensure that your information is protected.

We use data and password encryption and the latest in electronic and physical security measures to give you the best possible protection. All information is securely transmitted using SSL standard encryption which creates an encrypted connection between your browser and our servers. Your information remains encrypted at all times.

Our servers are located in a secure facility that is protected by the very best in physical security, electronic security and internal security policies to ensure that your data remains secure. Security personnel monitor the system 7 days a week, 24 hours a day and access requires multiple levels of authentication.

We are committed to maintaining the confidentiality, integrity and security of any personal or other information about our users.

2. Purpose, legal basis and any concerns you may have.

All data is held securely under the provisions of the relevant Data Protection Law which includes the General Data Protection Regulation and data is provided for you for the purposes of viewing and managing your financial information.

Citygate Connect is supplied to you by us through Citygate Financial Planning who acts as our agent for that purpose. We are processing your personal data under the strict understanding that you have given explicit consent for us to do so to Citygate Financial Planning. You may withdraw this consent at any time by notifying either us or Citygate Financial Planning.

If you have any concerns in connection with your data and its processing via Citygate Connect or if you think any data held within Citygate Connect may be inaccurate or incomplete then please contact, in the first instance, Citygate Financial Planning, the Data Controller.

You may also contact us as the Data Processer at Moneyinfo Limited, email enduserservices@moneyinfo.com, by telephone 03303 600300 or by writing to us at Moneyinfo Ltd, Forward House, 17 High Street, Henley-in-Arden, Warwickshire B95 5AA.

In certain circumstances, where you have added your own data to Citygate Connect and hidden it from view by your financial adviser using the privacy controls available to you, then in these circumstances Moneyinfo Limited would be the Data Controller and you can contact us using the contact details above for any questions in connection with data you have added.

If you have a concern or would like to lodge a complaint against either us or Citygate Financial Planning you may raise your concern with the Information Commissioner’s Office (ICO). You may be eligible for compensation for damages caused if we breach of our responsibilities. For information on how to raise your concern with the ICO please see https://ico.org.uk/concerns/.

2.1. What information is held about you?

We hold personal information and other data in Citygate Connect as is necessary to provide you with the service. Most of the personal information we process is provided to us directly by you, either you have added it directly to Citygate Connect if you have permissions to do so, or Citygate Financial Planning have captured the information previously and imported it from other systems they may use.

All data held about you within the Citygate Connect database is encrypted and securely stored and retained whilst you continue to be subscribed to the service. The data held is visible to you via the Citygate Connect service and you have control over who can access any data you add yourself.

The type of personal information we collect and hold includes:

For more information about how and why we use cookies and how you can change your cookie settings please see our Cookie Policy below.

2.2. How we use your data.

Your information is only used by us in the following circumstances:

  1. to enable us to provide the Citygate Connect service to you as detailed in this Agreement;
  2. to analyse how the service is being used so that we can improve the service;
  3. to alert you to service changes and updated information;
  4. for troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  5. to third-party contractors that provide integrated services to Citygate Connect (such as data feeds to value your investments) and are bound by these same privacy restrictions;
  6. for benchmarking and data analysis purposes;
  7. to enforce our terms of use; and
  8. as otherwise set forth in this privacy policy.

We reserve the right to use, sell, rent, license, distribute and disclose Aggregated Data. We will not sell or rent your data to any third-party other than as Aggregated Data.

2.3. Your data belongs to you and you can delete your data at any time.

Your data is yours. You can request it is removed from Citygate Connect at any time. When you request us to delete your account from Citygate Connect, your data will be permanently deleted from our primary production servers and further access to your account will not be possible. This deletion will disconnect any connection we had established to your account information. However, portions of your data, consisting of Aggregated Data derived from your account information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media for a limited period whilst backup cycles complete. Citygate Connect keeps backup data to ensure that we can continue to provide the service to you in the unlikely event of malfunction of our primary production servers. We also reserve the right to retain and use any Aggregated Data derived from or incorporating your information.

If you have any queries about how we use your personal data, please contact Citygate Financial Planning in the first instance or you can email us on support@moneyinfo.com.

3. Why you should not solely rely on the information contained in Citygate Connect.

The content on Citygate Connect is provided for general information only. Whilst every effort is made to ensure that the information contained on Citygate Connect is accurate and up to date, we cannot accept any responsibility for the accuracy of the underlying data.

You should not rely on the information on Citygate Connect to decide upon or undertake transactions or financial decisions or use it for tax reporting or insurance purposes. You must obtain professional or specialist advice from your financial adviser or an alternative qualified adviser who is regulated by the Financial Conduct Authority before taking, or refraining from, any action or financial decision. Use of Citygate Connect does not constitute advice and we are neither qualified nor permitted by law to advise you in relation to financial matters.

We make no representations, warranties or guarantees, whether express or implied, that the content on Citygate Connect is accurate, free from errors or omissions, complete or up-to-date.

4. How we retrieve information from third-parties.

To provide elements of the service to you, we use third-party data processors . We have contracts in place with these data processors that ensures they cannot do anything with your personal information unless instructed by ourselves. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it only for the period we instruct.

In providing the Citygate Connect service, we also use technology supplied to us by a company called Envestnet Yodlee Inc. We have an agreement with Envestnet Yodlee that allows us to use their technology but we are not affiliated to or in any other way connected to Envestnet Yodlee which is an independent company.

4.1. Processing of data outside of the UK

When it is necessary for us to transfer your personal information outside of the UK this will only be done in accordance with the UK data protection laws.

The Envestnet Yodlee service, which enables us to provide you with Open Banking features and the ability to connect your other online accounts such as pensions or investment accounts, is a US based service and information retrieved will be processed by Envestnet Yodlee’s servers based in the US. Our contract with Envestnet Yodlee governs their processing of personal data in their role as a sub-processor, and mandates that they have appropriate security measures and controls in place to ensure that the transfer of your data is in accordance with applicable UK data protection laws and regulations.

If you would like to know more about Envestnet Yodlee then please visit their website at www.yodlee.com/clients-customers

You may see reference to Yodlee in other areas of this Agreement but we stress that the Agreement is between you and us.

4.2. Data accuracy within Citygate Connect.

The information displayed in Citygate Connect is only as up to date as the information supplied to us by third party sites, providers and Citygate Financial Planning. We do not check the data we receive from third parties for accuracy and the information displayed may be more up-to-date when obtained directly from the relevant parties.

We do not assume responsibility for the timeliness, accuracy, deletion, non-delivery or failure to store any user data, communications or personalisation settings.

5. Who will your data be shared with?

Data is visible by you and any related parties linked to you. You can set privacy on any data you add yourself and choose which related parties you wish to share your data with. Your data may be shared with our staff and the staff of Citygate Financial Planning as necessary to provide Citygate Connect to you and in their capacity as your financial adviser or wealth manager. Citygate Financial Planning's access does NOT include the ability to view or access your bank, credit card or loan statements if you have chosen to add these using the Open Banking features. This data can only be viewed by you.

5.1. Controlling your Privacy Settings

You can directly control who can view any of the data which you have added to Citygate Connect by use of the privacy control settings. See my privacy settings by clicking on the Me icon within Citygate Connect.

5.2. Your bank and credit card statements are not visible to anyone but you.

Statements from your bank, building society or credit card accounts held on the Citygate Connect can only be accessed by you using your secure log in credentials. By default your statement data is not visible to anyone but you.

This data is not visible to Citygate Financial Planning and is only accessible to employees of us in strictly controlled circumstances as required for support purposes. This access is only given to authorised individuals at moneyinfo Limited at the point a support query is raised on your account and in accordance with strict internal procedures.

5.3. moneyinfo Limited employees can access your data only in strictly safeguarded circumstances

moneyinfo Limited employees do not have direct access to the Citygate Connect database except where necessary for system management, maintenance, monitoring and backups. In this scenario, only specific nominated individuals have access. Such access is only given and used in accordance with strict internal procedures, in order to operate, develop or enhance the Service. These individuals have passed stringent employment vetting checks and are bound by confidentiality obligations and are subject to disciplinary procedures, including termination of employment and potentially criminal prosecution if they fail to meet these obligations.

5.4. Your log-in credentials are kept secure and encrypted in the Citygate Connect Service.

If you choose to connect your bank or credit card accounts using Open Banking your login credentials are managed by your bank, building society or credit card provider and are not accessible to or stored by us or Citygate Financial Planning.

Any other online login username, passwords, or security numbers you enter into the Citygate Connect service will never be accessible to any employee of Citygate Financial Planning limited or anyone from moneyinfo Limited. This information is kept separately from the Citygate Connect service and your other personal data as an additional security measure.

You are responsible for ensuring that your login credentials are kept secure and not disclosed to any other party. In the event that you feel your log in credentials have been obtained by another party you should change your password immediately.

5.5. Disclosure of your information to protect our rights or if required by law.

Notwithstanding anything to the contrary, Citygate Connect reserves the right (and you authorise us) to share or disclose your information at our sole discretion, should we deem that the disclosure of such information is necessary or appropriate:

  1. to enforce our rights against you or in connection with a breach by you of our Privacy or Security Policies or the Citygate Connect Terms of Use;
  2. to prevent prohibited or illegal activities; or
  3. when required by any applicable law, regulation, other legal process.

6. Other information regarding your data.

6.1. Marketing and other notices.

You can change your marketing preferences within the settings section of Citygate Connect to manage your email preferences and opt-out of education, marketing and service notifications. To access these settings click on the Me icon and select settings from the pop-up menu.

6.2. Deletion of Documents

Documents you upload to Citygate Connect can be deleted by you, us &/or Citygate Financial Planning. Once deleted, they are removed from our systems and we do not retain copies.

6.3. Cookies and how we use online session information.

We may store information about you in a cookie (a small file that is sent by our web server to your computer), which we can access when you make return visits to Citygate Connect. Storing cookies is usual practice for any web site that needs to remember what its users' preferences are and we use cookies to keep track of your choices in the Website. Our cookies are encoded so that they can only be accessed by us. If you would like to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that cookies are stored in. If you would like to stop cookies being stored on your computer in the future, please refer to your browser manufacturer's instructions by clicking "Help" in your browser menu. Further information about deleting or controlling cookies is available at www.aboutcookies.org.

We may collect information when you visit Citygate Connect such as the pages you have visited, your browser type or the average time you have spent on the site. Please note that when you visit our site, we may also log your IP address, a unique identifier for your computer or other access device. This information is only analysed and used to improve the design or functionality of the service or to alert you to any compatibility issues.

We use cookies to enhance the security of the service and to compile anonymous statistics about the use of the service. Here is a list of the main cookies that we use and what they are used for:

6.3.1 .NativityAuth (Session Cookie)

This cookie is strictly necessary for the website to function correctly. It remembers the user who logged in to the system. It is removed when the browser is closed.

6.3.2 RequestVerificationToken (Session Cookie)

his cookie is strictly necessary for the site to function correctly. It is used to protect the user against cross site request forgery. It is removed when the browser is closed.

6.3.3 ai_user (Persistent Cookie)

This cookie is to determine if the user has previously visited the site (within the past year). This cookie is created on first visit to the Citygate Connect website and expires one year after created.

6.3.4 _ga (Persistent Analytics)

Citygate Financial Planning may set up Google Analytics on Citygate Connect. These cookies collect information about how you use the site. This information is collected anonymously and is used to understand how users are engaging with the service. This cookie expires after 2 years. Note: Optional addition to the privacy policy if GA is switched on

7. Your data protection rights

You have rights under data protection laws in relation to your personal information. This includes the following rights:

If you wish to exercise any of the rights set out above, please email support@moneyinfo.com. Citygate Financial Planning may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. Citygate Financial Planning may also contact you to ask you for further information in relation to your request.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.