Thinc Group Limited ("Thinc") is a member of the AXA group of companies. With effect from 1 January 2025, we here at AXA Services Limited ("AXA") are responsible for dealing with any outstanding or future complaints or claims from Thinc customers. To support this activity, Thinc's customer records have been transferred to us.
This Privacy Policy sets out how we will process your personal data if you were a customer of Thinc.
This policy is supplemental to, and should be read in conjunction with, our full Privacy Policy.
What personal information do we process?
We will process the personal information contained in your Thinc customer record which may include:
- contact details such as your name, address, email address, and telephone number
- identification information such as your date of birth, gender, national insurance number, passport and driving licence
- financial information such as bank details
- information regarding the advice and recommendations provided by Thinc
We may also process sensitive personal information including information about your health, where relevant.
In the event of a complaint or claim, we may process such additional information as is relevant to the circumstances of your complaint or claim.
How do we collect your personal information?
We have obtained your customer record from Thinc.
In addition, we may collect personal information directly from you and from other third parties including from credit reference agencies, such as information from the electoral register for the purpose of preventing and detecting financial crime. The search is not a credit check and your credit rating should be unaffected.
How do we use your personal information?
We will hold your personal information for record keeping purposes. Where relevant, we will use your personal information for the purposes of dealing with any ongoing or future complaints or claims relating to advice provided by Thinc, in accordance with our retention periods.
We will process your personal information on the basis of our legitimate business needs to properly consider and assess any complaints or claim. Where we process your sensitive personal information, we may do so on the basis that it is necessary to establish, exercise or defend our legal rights.
Who do we share your information with?
We may use other AXA Group companies for our general business administration. These AXA Group companies will treat your data in accordance with their obligations under data protection law.
We may also disclose your information to the following third parties:
- providers or administrators of your investments;
- any relative, guardian, attorney or lawyer that is acting on your behalf; or
- any Government department, regulator or law enforcement agency conducting enquiries.
More information
You can find further information on our data protection commitments in our full Privacy Policy, including information relating to:
- Our other processing purposes;
- How we use personal data within the AXA group and under which circumstances we may share personal data with companies outside the AXA group;
- The legitimate interests we have in the data processing and on which other legal grounds our processing is based;
- How long we generally process and store personal data;
- Your data protections rights and how you can exercise them; and
- How to contact the AXA group data protection officer.
Changes to this Privacy Policy
This Supplementary Privacy Policy will be in place for so long as necessary to deal with any outstanding or future complaints from customers relating to Thinc.
May 2025