The InvestEngine Pension Plan

Terms and Conditions

This is an important document which sets out how your InvestEngine Pension Plan is operated. These Pension Terms & Conditions together with the InvestEngine Terms and Conditions for Clients forms the contract between you and us and should be kept along with all other associated documents provided to you.

Definitions

Annual Allowance
The cap on the total amount of tax relievable contributions paid into an individual’s pension schemes over an input year, as described in the Finance Act 2004.

Application
The application you make for your InvestEngine Pension Plan

Benefit
An actual or prospective entitlement to any benefit under the scheme (including any part of the pension and any payment by way of pension).

Beneficiary
The person(s) that will receive the benefit paid out from your InvestEngine Pension Plan They may, or may not, also be a dependent.

Business Day(s)
Any Monday, Tuesday, Wednesday, Thursday or Friday, which is not a Bank Holiday in England.

Capped Drawdown
Income Drawdown with a maximum income limit

Competent Authority
A national or local agency (such as the FCA, LSE or HMRC) (whether in the UK or otherwise) authority department, inspectorate, minister, ministry official or parliament

Crystallise / Crystallisation
To use a part or all of, your account to provide retirement or death benefits. It also occurs when you transfer your account to a recognised overseas pension scheme.

Dependant
Means:

A person who was married to or in a registered civil partnership with you at the time of your death;
Your natural/adopted child provided he/she (i) is under the age of 18 (or 23 if in full time education) or (ii) was in the opinion of us dependent upon you at the date of your death because of mental or physical impairment; or
A person who falls into neither of the above categories and who at the date of your death was, in the opinion of us, (i) financially dependent on you (ii) in a financial relationship of mutual dependence with you, or (iii) dependent on you because of mental or physical impairment.

FCA
The Financial Conduct Authority

Finance Act
The Finance Act 2004 and associated regulation as amended from time to time and any statutory re-enactment or modification of it.

Flexi-access Drawdown
Income Drawdown with no maximum or minimum income limit

HMRC
The Commissioners or Officers of Revenue and Customs or both of them, as the context may require

Ill Health
A tax-free lump sum payment of uncrystallised benefits that can be made, at the Trustees’ discretion, where a person has a life expectancy of less than one year.

In-specie
In relation to a transfer in or a transfer out, a transfer in the form of investments without converting them to cash

Income
To provide an income from your account other than by a purchase of an annuity

InvestEngine
InvestEngine (UK) Limited, the provider of the InvestEngine Pension Plan through which you manage your Scheme assets and from whom you will receive notifications and information about your Scheme membership.

InvestEngine App
The InvestEngine (UK) Limited application, as updated from time to time, through which you provide investment instructions, receive information from, and can pass information to, us about your Scheme membership.

InvestEngine Terms and Conditions for Clients
The InvestEngine Terms and Conditions, which include the investment terms, that applies to your InvestEngine Pension Plan

InvestEngine Pension Plan
The personal pension product under the Scheme available via the InvestEngine App.

InvestEngine website
https://www.investengine.com

Lump Sum Allowance
A limit on how much tax-free cash you can take from your pension, either via a Pension Commencement Lump Sum (PCLS) or the 25% tax free cash portion of an Uncrystallised Fund Pension Lump Sum (UFPLS). This will be set at £268,275

Lump Sum and Death Benefit Allowance
The Lump Sum and Death Benefit Allowance (LSDBA) is the total limit on tax-free withdrawals from your pension, along with any Serious-Ill Health Lump Sums and Deceased Payments where they are paid tax free. This will be set at £1,073,100.

Member
A person admitted as a Member of the InvestEngine Pension Plan and who has not ceased to be a Member

Minimum Pension Age
The age at which the regulations permit you to take benefits from your InvestEngine Pension Plan

Money Purchase Annual Allowance
A restriction on the amount you can pay into your pension and still receive tax relief when you start to access your pension pot for the first time.

Pension Commencement Lump Sum
The lump sum of money you can withdraw from a pension as a tax-free amount

Permitted Investments
The investments that are made available to you from time to time for investment via the InvestEngine App

Power of Attorney
A document that gives an individual the authority to act for another person in legal or financial matters

Registered Pension Scheme
A scheme which is registered under Chapter 2 of Part 4 of the Finance Act

Retail Client
The meaning given to it in the FCA Handbook of rules and guidance, as published from time to time

Scheme
The InvestEngine Pension Plan

Scheme Administrator
Quai Investment Services Limited. Quai Investment Services Limited has appointed Quai Administration Services Limited to provide administration support in connection with the scheme. However, Quai Investment Services Limited is responsible for the discharge of the functions conferred or imposed on the scheme administrator of the scheme.

Scheme Trustee
Quai Trustees Limited

Terms
These Terms and Conditions and any amendments from time to time

Transfer In
Any transfer in of cash or assets to your InvestEngine Pension Plan from another registered pension scheme

Transfer Out
The full or partial transfer of your InvestEngine Pension Plan to another registered pension scheme, in cash or assets.

Uncrystallised Fund
The part of pension fund which has not been crystallised as defined by the Taxation of Pensions Act 2014.

Uncrystallised Fund Pension Lump Sum
A lump sum, of which a proportion is taxed at the basic income tax rate, paid directly from your uncrystallised fund, as described by the Taxation of Pensions Act 2014

References to “you” shall mean the beneficial owner of the InvestEngine Pension Plan.

Reference to “we”, “us” or “our” is Quai Investment Services Limited.

Roles & Responsibilities

The provision and operation of the InvestEngine Pension Plan involves various entities: this section sets out the roles and responsibilities or each entity so you can clearly see who is involved and in what capacity they act.

Quai Trustees Limited (QTL) is the Scheme Trustee and therefore the owner of the assets held in respect of your InvestEngine Pension Plan. Dependent on the investment type, assets will be held in the name of InvestEngine Nominees Limited as shown in the InvestEngine Terms and Conditions for Clients.

Quai Investment Services Limited (QISL) is the FCA regulated firm with the permission to operate a Pension Scheme and is the provider of the InvestEngine Pension Plan. It is responsible for the running of the Scheme and discharging of the functions as required as the Scheme Administrator and authorises you as a Member of the Scheme to provide investment instructions to InvestEngine.

InvestEngine provides the InvestEngine App to allow all interaction and communication with regards to the InvestEngine Pension Plan, including any communication from the Scheme Trustee and Scheme Administrator.

InvestEngine will hold monies for you pending your investment instructions through the InvestEngine App as per the InvestEngine Terms and Conditions for Clients.

InvestEngine have been appointed by QISL to act as custodian in respect of the assets of the InvestEngine Pension Plan.

Operation and Investment

The terms of your agreement with us are set out in these Terms, each application, the InvestEngine Terms and Conditions for Clients , the scheme trust deed, scheme rules and the InvestEngine Pension Plan Key Features (the scheme trust deed and rules will prevail in the event of any conflict).

We do not provide advice about our products or allowable investments. The InvestEngine Pension Plan is only available to investors on an execution only basis. If for any reason you are unsure about the suitability of the InvestEngine Pension Plan for your financial circumstances, you should seek financial advice from an FCA authorised and appropriately qualified financial adviser prior to investing in an InvestEngine Pension Plan.

The InvestEngine Pension Plan is only available through the InvestEngine App; accordingly all reports and documentation will be provided to you for access via the InvestEngine App. In addition the InvestEngine website provides information about the InvestEngine Pension Plan, together with links to important information, including InvestEngine legal documents, policies and corporate information.

By applying for an InvestEngine Pension Plan, you agree that you do not require us to provide reports, statements, contract notes or other documentation associated with your InvestEngine Pension Plan other than in electronic form via the InvestEngine App. You must keep your contact details up to date so that we can notify you when any important documents are sent via the InvestEngine App.

You accept that where we are required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above.

There may be circumstances which require us to review these Terms and Conditions. In this event we will notify you via InvestEngine of any amendments to these Terms at least 30 days prior to the change taking effect. However, we do reserve the right in extreme circumstances to vary these Terms with shorter notice e.g., a change to an existing, or implementation of a new regulatory requirement which we must action immediately.

You authorise us to provide HMRC, the FCA and any other relevant authority with all the relevant information about your InvestEngine Pension Plan and its investments as required by them.

In accordance with the FCA rules we have categorised you as a Retail Client. As a Retail Client you will benefit from the greatest level of protection available under the regulatory system.

If you materially breach these terms then we reserve the right, without further notice, to close your InvestEngine Pension Plan, require you to transfer out your InvestEngine Pension Plan to an alternate provider; or any combination of these.

Starting your InvestEngine Pension Plan

Your InvestEngine Pension Plan will be set up when you have provided InvestEngine with all details required as part of your application. We reserve the right at our absolute discretion to refuse your application without providing any reason for our decision.

You may not open an InvestEngine Pension Plan if you are a US Person as defined by the US Internal Revenue Service. If at any point you become a US Person as so defined, then you must inform us immediately, and we will require you to close your InvestEngine Pension Plan.

You may only open an InvestEngine Pension Plan if you are UK resident over the age of 18, or you have prior agreement to transfer in an existing UK pension fund. If you cease to be a UK resident, then you must inform InvestEngine immediately.

You have the right to cancel your application. You can find our cancellation form in the InvestEngine Pension Plan Key Features Document and you have 30 calendar days from receipt of your application to inform us that you have changed your mind and wish to cancel your application. We will proceed with your application during the cancellation period and follow any investment instructions that you have given to InvestEngine. If you choose to cancel your application during the cancellation period, any investments held in your account will be sold and we will return any contributions. The amount to be repaid may be less than the amount paid to us if the value of the investment has fallen at the time it is sold.

You also have cancellation rights in respect of any transfers in that you instruct us to receive from other pension providers. You have 30 calendar days from receipt of your transfer in notice to notify us that you have changed your mind and wish to cancel your transfer. InvestEngine will follow any investment instructions that you have given to them during this 30-day cancellation period. If you choose to cancel your transfer in under the terms of the cancellation rights, any investments acquired by the transferred monies will be sold and, together with any cash from the transfer in, will be returned to the original pension provider. The amount to be repaid may be less than the amount paid to us if the value of the investment has fallen at the time it is sold.

PLEASE NOTE: it may not always be possible to return a pension transfer payment to the original pension scheme if you cancel after the transfer has been received by us. In these circumstances you will need to arrange for another pension scheme to accept the transfer. Any funds will be retained until such a time as a replacement provider has been notified to us.

Contributions and Transfers In

Contributions may be single or regular and can only be paid in sterling. Contributions are subject to certain minimums which are set out in the InvestEngine Terms and Conditions for Clients and may be varied from time to time.You may transfer in cash from another registered pension scheme to your InvestEngine Pension Plan. Alternatively, if you are transferring a pension where investments are held via an investment platform service and the pension investments that are held are also available under the InvestEngine Pension Plan, then you may request for those investments to be transferred in-specie. If those investments are available from InvestEngine with lower fund management fees you will have the option to convert those investments.

We may decline any contribution or transfer in entirely at our discretion.

All contributions and transfer in values we receive will be applied to your InvestEngine Pension Plan.

We will automatically claim basic rate tax relief from the government on your behalf and apply it to your InvestEngine Pension Plan. We will do this on any contribution you make personally or from a third party and you will continue to receive tax relief up until your 75th birthday. You are responsible for informing us if you are not entitled to tax relief on the whole or part of a contribution.

If you pay one of the higher rates of income tax, you’re entitled to receive tax relief at the higher rate; this additional relief is claimed through your annual self-investment tax return, or by applying direct to HMRC and is paid to you, not your InvestEnginePension Plan.

It is your responsibility to monitor your contribution limits. If you become subject to a reduced annual allowance (known as the Money Purchase Annual Allowance Rules) as a result of flexibly accessing your pension benefits then you are obliged to inform Invest Engine of this immediately and provide the date that this occurred.

Contributions to your InvestEngine Pension Plan cannot be refunded other than:

In accordance with your instruction to cancel your InvestEngine Pension Plan; or
Where conditions are met to allow a “refund of excess contribution lump sum”payment to be made i.e. where your contribution exceeds your earnings in a tax year; or
Where explicit instruction is received from HMRC or other relevant authorities.

Other pension benefits from a registered pension scheme may also be transferred in to your InvestEngine Pension Plan, subject to the consent by the Scheme Trustee, applicable legislation and HMRC rules. The terms of any such transfer in, will be agreed between you and us.

If you transfer capped drawdown benefits to us we may require them to be converted to being a flexi-access drawdown account upon receipt. This will only trigger the Money Purchase Annual Allowance Rules (if you are not already subject to them) the day after you first receive a taxable income payment from your InvestEngine Pension Plan.

Cash

Contributions made via the InvestEngine Pension Plan will be transferred to the Scheme Trustee(s). Once the contribution has been recorded in your InvestEngine Pension Plan it will be transferred to the Scheme Trustee(s) in order to be accepted as a contribution to the scheme.

All monies held by the Scheme Trustee(s) is in an account designated as a trust account and segregated from our funds in accordance with the FCA rules.

The trust account is a pooled account with one or more banks. In the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank. The banks we use are entirely independent of us and we do not accept any liability for any default or delay in the distribution of funds in the event of their failure.

Interest may be payable on accounts containing your money. Any interest earned will be retained by Quai Investment Services Limited.

Fees, Charges and Expenses

The fees and charges payable and the timing of these fees in respect of your InvestEngine Pension Plan and the circumstances in which they may be increased are set out on the InvestEngine website at: https://investengine.com/costs/ and in the InvestEngine General Client Terms available via the InvestEngine App and website at https://investengine.com/terms/.

We will also be entitled to charge the following costs to your InvestEngine Pension Plan:

All expenses incurred by us (including claims, losses, and liabilities) in acquiring, holding, disposing of or valuing any investment or other asset of your InvestEngine Pension Plan;
An amount equal to any tax for which we become (or reasonably expect to become) liable in respect of your InvestEngine Pension Plan if your InvestEngine Pension Plan does not constitute pension business as defined in Section 431b of the Income and Corporation Taxes Act 1988 (ICTA).

We may reimburse ourselves in respect of liability, charges, or costs by way of making a charge to your InvestEngine Pension Plan as we may reasonably determine which we have incurred as a result of one of the following events occurring:

We become liable to pay any tax or levies imposed on your InvestEngine Pension Plan or on any contribution paid by you; or
We become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which we are (or become) a member, to the extent directly or indirectly attributable to your InvestEngine Pension Plan.

The above will not apply to the extent that the relevant event is attributable, directly, or indirectly, to any fraud, negligence, wilful default, or regulatory breach on our part.

All charges, costs, and liabilities which we are entitled to charge to your InvestEngine Pension Plan will be paid by us from your InvestEngine Pension plan. If at any time the credit balance on your InvestEngine Pension Plan is not enough to cover all such charges, costs, and liabilities in full, we may:

Require you to make a cash contribution to your InvestEngine Pension Plan; or
Dispose of assets in order to pay the amounts due.

Lump Sum Allowance and Lump Sum and Death Benefit Allowance

There are two limits which determine the maximum amount of tax-free cash that can be taken from all your pension arrangements which are known as the Lump Sum Allowance and the Lump Sum and Death Benefit Allowance. These limits are £268,275.00 and £1,073,100.00 respectively.

If the value of tax-free cash that you can take from your pension exceeds either the Lump Sum Allowance or the Lump Sum and Death Benefit Allowance, you will be liable to pay a tax charge on the amount over it, at your marginal rate. Any applicable charge will be deducted from your InvestEngine Pension Plan before any money is paid to you.

Payments Out

Taking Benefits

You may normally choose to crystallise some or all of your InvestEngine Pension Plan at any time on or after minimum pension age. If you wish to make an application to take benefits then please contact support@investengine.com

If you choose to take pension benefits from your InvestEngine Pension Plan then you should seek financial advice or seek guidance from MoneyHelper. If you do not wish to do this then we will accept authorised instructions from you directly but may require further attestations or declarations to ensure that you have understood the potential risks.

You may be able to crystallise your InvestEngine Pension Plan before minimum pension age if:

We are satisfied that you are and will continue to be incapable of carrying on your current occupation due to physical or mental impairment. You will need to provide evidence that we require; or
You had transitional rights at April 2006 to a protected pension age under Schedule 36 of the Finance Act 2004 and you satisfy the conditions.

When you crystallise part or all of your InvestEngine Pension Plan to draw benefits you can normally choose to take up to 25% of the amount crystallised (subject to the Lump Sum Allowance) as a single or as a number of pension commencement lump sum without incurring a tax charge. A higher or lower amount may be available if you had transitional rights at 6 April 2006 and you satisfy the conditions.

If the value of the benefits crystallised exceeds your personal Lump Sum Allowance or Lump Sum and Death Benefit Allowance, there may be an additional tax charge, based on your marginal rate of tax.

The remainder of the amount crystallised after the payment of any pension commencement lump sum, any pension commencement excess lump sum and any additional tax charge will be allocated to provide a pension income for you in the form of:

Flexi-access drawdown; or
A lifetime annuity bought from an insurance company of your choosing; or
A combination of the above; or
A small funds lump sum

If you choose to take flexi-access drawdown then:

You can request regular or ad hoc payment of income directly from your InvestEngine Pension Plan. There is no maximum or minimum limit on how much you can withdraw each year, however, we may require you to maintain a minimum amount in your InvestEngine Pension Plan if you wish for it to remain open.
If you request a regular income we will pay your income either monthly, quarterly, half-yearly or yearly. Payment is made on the 1st of the month, or where the 1st is a non-business day, the next available business day, or any other date that we may subsequently advise. We will make the payments by direct credit to your personal bank account net of all relevant taxes. We will stop payment after receiving notification of your death.
You can ask us to increase, reduce, stop or restart payments or make one off payments from time to time. If you wish to change the level of your payment you must provide instruction to InvestEngine at least 10 (ten) business days before the payment date.
You must ensure that sufficient cleared funds are held in your InvestEngine Pension Plan 10 (ten) business days before the payment date or we will not be able to make the payment. If insufficient funds are available to make the payment in full, no partial payment will be made.
The day after we first make a payment of income to you from your flexi-access drawdown fund you will become subject to a reduced annual allowance, known as the Money Purchase Annual Allowance (MPAA) for the remainder of your lifetime. We will notify you this has occurred and the effective date. It is your responsibility to inform any other pension schemes of which you are a member and to ensure that your contributions to all pension schemes (including the InvestEngine Pension Plan) remain within the permitted maximums.
You can choose to buy a lifetime annuity at any time with part of, or, the entire drawdown pension fund. You can also transfer your flexi-access drawdown fund to another provider.

If you choose to buy a lifetime annuity you must select the features you require from the relevant annuity provider. We do not offer annuities. To facilitate your request, we will transfer your pension fund in cash to your chosen annuity provider and cease to have responsibility for those benefits.

If you choose to take an uncrystallised fund pension lump sum then:

You can take a lump sum directly from your uncrystallised fund. 25% of the lump sum will be tax free with the remainder subject to Pay as You Earn Tax at your marginal rate.
There is no maximum or minimum limit on the amount of the lump sum; however, we may require you to maintain a minimum amount in your InvestEngine Pension Plan if you wish for it to remain open.
There is no limit on the number of uncrystallised fund pension lump sum that you can withdraw from your InvestEngine Pension Plan.
We will pay your uncrystallised fund pension lump sum net of all relevant taxes by direct credit to your personal bank account.
The day after we first make an uncrystallised fund pension lump sum payment to you, you will become subject to a reduced annual allowance, known as the Money Purchase Annual Allowance (MPAA) for the remainder of your lifetime. We will notify you this has occurred and the effective date. It is your responsibility to inform any other pension schemes of which you are a member and to ensure that your contributions to all pension schemes (including the InvestEngine Pension Plan) remain within the permitted maximums.

A tax charge may arise as a result of taking pension commencement lump sum if you have recycled the lump sum in whole or in part. Recycling will arise if;

The amount of contribution from all sources paid to all registered pension schemes in respect of you is greater than 30% more than might have been expected based on previous contributions; and
The pension commencement lump sum plus any similar lump sums from any registered pension scheme taken in the previous 12 months exceeds £7,500; and
The cumulative amount of the additional contribution exceeds 30% of the pension commencement lump sum; and
The recycling was pre-planned.

Should a tax charge arise you agree that such tax shall either be paid from your InvestEngine Pension Plan or paid by you personally, as the case may be.

Transfer Out

Any request to transfer the assets from your InvestEngine Pension Plan to another provider must be made via an approved transfer provider application, subject to the applicable legislation and HMRC rules.

If we agree, we may transfer assets out of your InvestEngine Pension Plan:

To another pension scheme that is a registered pension scheme within the meaning of section 153 of the Finance Act 2004 or which under that section is treated as a registered pension scheme; or
In accordance with any court order

We will not make a transfer unless:

We have an authorised instruction from the receiving provider to make the transfer; and
We have received all required documentation and information from you, or the receiving provider, that we in our reasonable opinion believe is necessary; and
We have received all charges due to us or to InvestEngine; and
All costs chargeable to your InvestEngine Pension Plan and all liabilities of your InvestEngine Pension Plan have been satisfied.

If you wish to transfer out in cash, there must be sufficient cash in your InvestEngine Pension Plan. You need to sell investments held in your InvestEngine Pension Plan prior to the transfer taking place. You should bear in mind that some assets, such as property funds and REITs, may not always be able to be sold immediately.

After satisfaction of all liabilities and the transfer of all assets from your InvestEngine Pension Plan, we will close your InvestEngine Pension Plan and you will cease to be a member of the scheme.

Pension sharing order

If we receive a pension sharing order under the Welfare Reform and Pensions Act 1999 in respect of your rights under the scheme, we must comply with it. This will reduce the value of your InvestEngine Pension Plan.

Unauthorised Payments

If we make any payments or transactions that are considered unauthorised under HMRC rules, a tax charge may apply. If we know the value to the tax charge, we can pay it from your InvestEngine Pension Plan. If we do not know the amount we may deduct an amount that we decide or may delay making a payment to you.

We rely on information provided by you, your dependant or beneficiary to calculate the tax charge. If we are unable to take the tax charge from your InvestEngine Pension Plan you, your dependent or beneficiary will need to reimburse us.

We can refuse a transaction if we believe that it could lead to an unauthorised payment charge or any other tax charge.

Serious Ill Health

Serious ill health is defined by HMRC as likely having less than a year to live. If you are suffering from serious ill health, you can take all your benefits as a single lump sum (known as a ‘serious ill health lump sum’) at any age. Benefits can be paid subject to the following conditions:

A registered medical practitioner must provide us with written evidence stating that your life expectancy is less than a year. The completed declaration will then need to be received and accepted by us before the serious ill health lump sum can be paid. We may withhold a payment until this has been provided.
You must have some of your Lump Sum and Death Benefit Allowance Remaining at the time of payment.

We will make payment directly to you by bank transfer to a UK bank account held in your name.

Payment of Benefits on Death

In the event of your death the Scheme Trustees retain absolute discretion to pay any individual or individuals in the proportions that they see fit following deduction of all fees, taxes and charges due at the time of payment. Any nomination made by you will be considered but is not binding and may not be followed.

Upon your death benefits may be used to provide income or paid as a lump sum as defined in the Finance Act 2004.

Personal Information

We may use your personal information, including your sensitive personal information, and store it on our systems and may otherwise process it for the administration of your InvestEngine Pension Plan. We need to know your personal information in order to provide you with the services as set out in these Terms and ensure your InvestEngine Pension Plan is administered as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements. You can find our Privacy statement in Appendix one.

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you.

We may disclose personal information if it is required to do so by law or are requested to do so by the Financial Conduct Authority, or any other relevant regulatory authority.

You can ask questions about how we have handled your personal information or raise a complaint about how we have handled your personal information, by emailing the Data Protection officer as shown in the Privacy Statement. If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure visit https://ico.org.uk/concerns/

Annual Reporting and Valuations

We will provide you with a Statutory Money Purchase Illustration (SMPI) each year which will include what you can expect to receive on retirement based on the current value.

The value of your InvestEngine Pension Plan is based on the total value of the assets, along with any cash balance, at the reporting date. We may, from time to time, adopt such valuation rules as we in our opinion consider appropriate.

Termination

These Terms , as amended from time to time, will continue to apply until the provision of the InvestEngine Pension Plan is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated via the InvestEngine App.

If we terminate or suspend your InvestEngine Pension Plan we reserve the right to request you to dispose of the assets and hold the proceeds in cash pending receipt of instructions from you to transfer your InvestEngine Pension Plan to another registered pension scheme.

Complaints and Compensation

If you wish to make a complaint in relation to the services provided by Quai Investment Services Limited, then please contact InvestEngine using your InvestEngine App message facility, by email to support@investengine.com or by writing to:

InvestEngine (UK) Limited
4th Floor, 57 Great Suffolk Street
London
SE1 0BB

Quoting your name and InvestEngine Pension Plan account number.

InvestEngine will immediately carry out an investigation of your complaint in line with its complaints policy and will provide a written response, communicating the outcome of the investigation to you. Details of the complaint handling process are available on request.

If you are not happy with the response and you wish to take the matter further you can refer it, without giving up any other rights you may have, to one of the following:

The Pensions Ombudsman
10 South Colonnade
Canary Wharf
E14 4PU
Telephone: 0800 917 4487
Email: enquiries@pensions-ombudsman.org.uk
Website: https://www.pensions-ombudsman.org.uk/

Financial Ombudsman Service
Exchange Tower
London
E14 9SR
Telephone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
Website: https://www.financial-ombudsman.org.uk

We participate in the Financial Services Compensation Scheme (FSCS) which pays compensation for financial loss only to eligible claimants when an authorised firm is in default and will carry out an investigation to establish whether or not this is the case. The scheme provides protection if an authorised investment firm is unable to pay claims against it. The amount of compensation depends on the basis of your claim. Compensation levels are subject to change and for up-to-date details please refer to www.fscs.org.uk

If your investment underperforms or loses value because of market movements, this is not covered by the FSCS. Your capital is at risk when investing in securities.

Further information about compensation arrangements including eligibility, rules and compensation limits is available from the Financial Services Compensation Scheme website at www.fscs.org.uk

General

These Terms shall be deemed to have been made in England and shall be governed by and construed in all respects in accordance with the laws of England. The parties (Quai Investment Services Limited and you) agree to submit to the non-exclusive jurisdiction of the Courts of England and Wales.

If any of the terms included in these Terms is held by any Competent Authority to be unenforceable or invalid in whole or in part, the validity of the other provisions of these Terms and the remainder of the affected term in question shall be affected by such invalidity.

Appendix One Privacy Statement

Quai Investment Services Limited (Quai) will be known as the Data Controller of the personal information you provide to us. The company registration number for Quai is ZB125709 and the registered address is: Unit 16 Tesla Court, Innovation Way, Peterborough, PE2 6FL.

Quai is committed to protecting and respecting your privacy. Our Privacy Statement is to let you know:

How and why we collect personal information
What we do with it
When and why we share it with other organisations
How long we keep it for; and
The rights and choices you have with regards to your personal information

Contact Us

If you have any questions about how we have handled your personal information or wish to raise a complaint about how we have handled your personal information, you can contact our Data Protection Officer at compliance@quaifmc.com.

If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure see: https://ico.org.uk/concerns/.

How we collect personal information

You, your financial adviser or your employer may give us information about you by completing application forms (paper versions or our online services) or by contacting us by phone, email or letter.

The personal information we gather may include, but is not exclusive to:

Your name
Address
Date of birth
National Insurance Number
Gender
Email address
Telephone number
Bank account details
Medical information (in certain limited circumstances)
Any further information required as part of a product application

Why we need it and what we do with it

We use your personal information in the following ways:

To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
To comply with our legal and regulatory obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime.
If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.
To confirm your identity and address, this includes using automated decisions when we carry out financial crime checks.

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you.

We keep the personal information we collect from you, your employer, and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

We hold personal information securely and limit access to those who need to see it.

The personal information we collect may be transferred to and stored at a destination outside the UK. This could be to another company within the Quai group of companies or to external service providers working on our behalf.

Where any such processing takes place, appropriate controls, such as adoption of agreements containing the appropriate standard clauses, will be put in place to ensure that the personal information is protected in the same standard as if it were in the UK.

How long we keep it

In most circumstances we will retain personal information for the lifetime of a plan or product or for up to seven years after the end of the relationship with us. This is to ensure we comply with our record keeping obligations, as set out by the FCA and other regulatory and legislative requirements.

Certain circumstances dictate that we retain some specific information for longer, i.e. pension transfer information, HMRC tax records etc.

Our retention obligations are reviewed on a regular basis to ensure that we do not keep personal information longer than we are legally obliged to.

When we have no on-going legitimate business need to hold your personal information, we will either delete it or anonymise it. If we can’t do this we will securely store your personal information, only use it for a purpose we’ve already communicated to you, and isolate it from any further processing until archives are deleted.

What is your data protection rights?

Under data protection law, you have rights including:

Your right of access – you have the right to ask us for copies of your personal information.
Your right to rectification – you have the right to ask us to rectify personal information you thinks is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your right to access. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact us at:

Data Protection Officer
Quai Investment Services Limited
Unit 16
Tesla Court
Innovation Way
Peterborough
PE2 6FL

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at the above address.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICOs address:
Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline Number: 0303 123 1113
ICO Website: https://www.ico.org.uk