Privacy Policy

1. About us
2. Our processing of your personal information 

• Prospective clients 
• Existing clients 
• Clients’ family members, business associates or beneficiaries 
• Other business partners 
• Users of our website 

3. What marketing activities do we carry out? 

4. How long do we keep personal information for?

5. What is our approach to sending your personal information overseas 

6. How do we protect your information? 

7. Cookies 

8. Google analytics 

9. Monitoring 

10. Hyperlinks 

11. Your rights 

12. Contacting us 

13. Updates to this notice

In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”. The Partner on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.

We also use details of any unspent criminal convictions for fraud prevention purposes.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.

In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us.

This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system. 2.1 a What personal information may we collect? General information such as your name, address, phone numbers and email addresses, date of birth and gender.  Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement.  Employment information such as job title, employment history and professional accreditations. 0 0 3 | Partner website privacy policy  Financial information: - Bank details - Financial reviews (fact finds) - Information relating to your personal finances such as your financial liabilities and assets, income and outgoings - Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders.  Information relevant to the services we provide such as: - previous and current investments - information about your lifestyle - attitude to investment risk - existing plan details - objectives - copies of your will - information about any trusts you have  Information about your family including information about your dependants.  Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.  Information obtained during telephone recordings.  Information we may have gather from publicly available sources such as the electoral roll, internet search engines and social media sites such as LinkedIn where you have been flagged as a PEP and we need to carry out enhanced due diligence. 2.1 b What special categories of personal information may we collect?  Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.  We may collect details about your health which are relevant to your application (e.g. as part of a pension or income protection need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client) or where you have disclosed such information to us because it explains your risk appetite for investments.  In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form. 2.1 c How will we collect your personal information? We will collect information directly from you when:  you enquire about or apply to receive our wealth management services; and  you contact us by email, telephone and through other written and verbal communications. 4 | Partner website privacy policy We will also collect your personal information from:  Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.  St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found at: www.sjp.co.uk/site-services/privacy 2.1 d What will we use your personal information for? There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so. We will rely on the following “Lawful Basis” when we process your “personal information”:  We need to use your personal information to enter into the client agreement, for example, we need to use your personal information to assess whether we can provide services to you and to set you up as a client on the St. James’s Place client relationship management system.  We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you and we are required to report to St. James’s Place on our relationship with you.  We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights. When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:  You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your health information.  There is a substantial public interest such as prevention and detection of fraud.  We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.  It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.