Data processing terms
Version [1.0]. In effect from [date].
Draft for legal reviewThe short version
- These terms apply whenever your advisors use Florin with a client.
- Florin does not sell data.
- Every provider that handles client data is listed here, with what it does and where.
- If an incident affects client data, we tell your firm within [notice period].
- When the agreement ends, your firm gets its records: [export and exit terms, to confirm].
1. Roles
[controller and processor positions, to confirm] Your firm brings the client to Florin. The client also has their own agreement under the Client terms.
2. What is processed
Florin handles five kinds of personal data in a plan.
| Category | Examples | Whose data |
|---|---|---|
| Identity details | Name, nationality, contact details and identity documents. | The client |
| Family and guardians | Partner, children, guardians, the executor and the people who inherit. | The client and the people they name |
| Assets in bands | Property, investments and pensions, by country and in rough bands. Never exact figures. | The client |
| Documents | Fact finds, existing wills, the will, its Arabic translation and the registered will. | The client |
| Advisor entries | Answers an advisor enters, files they upload, and messages with the client. | The client and your advisors |
3. Instructions
We use the data to provide Florin as set out in the Platform terms. Florin does not sell data. Use of the data to improve the service: [position on service improvement, to confirm].
4. People with access
The client always sees their own plan. Their advisor sees it while the client allows it, and your firm’s admin sees only the stage each plan has reached. People at Florin: [who at Florin can open a client’s plan, and when].
5. Security measures
Our measures are set out on Security and privacy. [how data is protected]
6. Providers we use
These providers handle client data for us.
| Purpose | Provider | Location |
|---|---|---|
| Hosting | [provider] | [location] |
| Database | [provider] | [location] |
| [provider] | [location] | |
| Translation | [provider] | [location] |
| Payments | [provider] | [location] |
Before we add or change a provider: [notice of provider changes, to confirm].
7. International transfers
Data is kept in [where data is stored]. When it moves to another country: [transfer safeguards, to confirm].
8. Requests from individuals
A client can see their plan, download their documents and ask for their data to be removed. When a request about a client’s data reaches your firm or reaches us: [how we help each other answer it, to confirm].
9. Incidents
If a security incident affects client data, we tell your firm within [notice period]. [What the notice contains, to confirm]
10. Audits
Send your security questionnaire to [security contact email] and we will answer it. [Audit rights, to confirm]
11. Return and deletion at the end
When the agreement ends, your firm gets its records: [export and exit terms, to confirm]. Data is then kept for [retention period] and deleted, apart from [records kept after removal].
Questions about this document: [legal email]
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