Privacy & Cookie Policy

Our Privacy Policy - your rights, your information and how we use it

2mi Financial Services Limited is committed to protecting your personal information. Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy; so please check our website for updates from time to time.

This version of our Privacy Policy was last updated April 26 2018.

Who we are

We are 2mi Financial Services Limited (“2mi”), a fully licensed financial advisory firm based on Guernsey.

This Privacy Policy applies to 2mi and also covers, but is not limited to, policies that were previously held with Alexander Forbes Channel Islands Limited, Martin-Gray (Channel Islands) Limited, Heritage Group Insurance Brokers.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact;

FAO Data Protection Officer
2mi Financial Services Limited
P O Box 12
East Suite, First Floor
1 Le Truchot
St Peter Port
Guernsey, Channel Islands
Email: [email protected]

Information we collect and use

Information about you that we collect and use includes:

  • Information about who you are, for example your name, date of birth and contact details
  • Information connected to your product or policy held on our agency (Investments, Pensions, Protection)
  • Information about your contact with us, for example meetings, phone calls, emails, letters
  • Information that is automatically collected, for example via cookies when you visit our website
  • Information classified as ‘sensitive’ personal information, for example relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
  • Information you may provide us about other people, for example joint applicants or beneficiaries for products you have with our agency
  • Information on children, for example where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)


What are cookies?

A cookie is a small file – it’s saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example - they will remember you've visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don't have to keep entering it or let us know which pages of our website you visited.

  • Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
  • Session cookies - these expire when you close your web browser


Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • an application form for a product or service
  • phone conversations with us
  • emails or letters you send to us
  • meetings with one of our financial advisers or member of staff
  • our online services such as websites and mobile device application ('Apps')


If you are a member of a group scheme, the information we collect and use will most likely have been provided by your employer on your behalf.

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources, for example to check or improve the  information we hold (like your address) or to give better contact information if we are unable to contact you directly.

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

  • it is necessary to provide the product or service you have requested. We will require some personal information including your name, address, date of birth, bank account details
  • it is necessary for us to meet our legal or regulatory obligations, for example to tell you about changes to Terms and Conditions and to meet regulatory requirements
  • it is in the legitimate interests of 2mi to deliver appropriate information and guidance regarding the policies you hold on our agency
  • it is in the legitimate interests of a third party to share information with your employer for the governance of a group scheme of which you are a member

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Who we may share your information with

We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.'

These third parties include:

  • Your employer (if you are a member of a group scheme)
  • Companies we have chosen to support us in the delivery of the products and services we offer to you
  • Our regulators and Supervisory Authority, for example the Guernsey Financial Services Commission (“GFSC”), the Office of the Data Protection Commissioner for Guernsey (“the ODPC”)
  • Guernsey Income Tax Office (“ITO”), for example for the processing of tax relief on pension payments or the prevention of tax avoidance
  • Guernsey Social Security, for example for calculating your pension benefits
  • Law enforcement, credit and identity check agencies for the prevention and detection of crime


We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed

All your information is processed in the UK and European Economic Area (EEA).

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

How long we keep your information

We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your individual rights

You have several rights in relation to how 2mi uses your information. They are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy and Terms of Business. 

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request.

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling or regulatory reason for 2mi to continue to have it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services.  In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your policy to another provider.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please write to us.

If you are still unhappy, you can complain to the Office of the Data Protection Commissioner. Their contact details are:

The Office of the Data Protection Authority
St Martin's House
Le Bordage
St Peter Port
Guernsey, GY1 1BR