Privacy Policy

Privacy Notice
As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide. 
This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.
“We”, “Us” “Our” refers to the Partner named on this website.
Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy

Table of Contents About us 

1. Our processing of your personal information
2. Prospective Client
3. Existing Clients
4. Clients’ Family Members, Business Associates or Beneficiaries
5. Other Business Partners
6. Users of our Website
7. What marketing activities do we carry out?
8. How long do we keep your personal information for?
9. What is our approach to sending information overseas?
10. Your rights
11. Cookies
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 named on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management. 

1. Our processing of your personal information  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 refer to the section that best describes your relationship with us. 

2. Prospective clients
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. 
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.

• 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.
• 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. 

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.

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.
• We will also collect your personal information from:
• Publically 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 

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

Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your  special categories of personal information
To verify your information.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to verify your identity).	You have given us your explicit consent.  It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations.	We need to use your information in order to establish, exercise or defend legal rights. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To set you up as a client on client relationship management systems and to communicate with you in respect of your application and service preferences.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to establish you as a client).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.	You have given us your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent.	We have a valid business reason (to send you selected communications about other products and services we offer)	Not applicable
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys).	We have a valid business reason (to develop and improve the products and services we offer).	You have given us your explicit consent.

  Who will we share your personal information with?  We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• 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.
• Third parties who provide sanctions checking services including Experian. 
• Compliance consultants including the Consulting Consortium.
• Financial crime and fraud detection agencies.
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Our insurers.
• The police, HMRC and other crime prevention and detection agencies. 
• Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

  3.  Existing clients  This section will apply if you currently receive wealth management services from us. This section will set out how we use your information. 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 or bank statement and evidence of benefit entitlement. 

• • Employment information such as job title, employment history and professional accreditations.

• 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 or where you have been flagged as a PEP.
• 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 contained in client review meeting records and file notes 
  • Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
  • Information about your family including information about your dependants.
  • Information obtained during telephone recordings where applicable. 

• 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. 

• Your marketing preferences and details of your customer experience with us.
• Information which we have gathered from publicly available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and we need to carry out enhanced due diligence. 

What special categories of information will 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 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 we are applying for income protection insurance we will need to ask you about any medical conditions and information about lifestyle choices such as whether you drink alcohol or smoke so that appropriate insurance can be obtained) 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.

How will we collect your personal information?  We will collect information directly from you when:

• you register to receive our services and complete and return to us all applicable application forms; and
• you contact us by email, telephone and through other written and verbal communications.

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.
• Any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
• St. James’s Place group companies.
• Third parties such as Experian who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services. 

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 or perform the client agreement that we hold with you. For example, we need to use your personal information to provide our services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims. 
• 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.
• We have a valid business reason to use your personal information 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 relevant 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.

  Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your  special categories of personal information
To carry out identification checks  and checks against sanction lists and politically exposed persons (PEP) screening	It is necessary to enter into your client agreement. We have a valid business reason (to carry out necessary compliance checks). We have a legal and regulatory obligation.	It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights. You have given us your explicit consent.
To verify your information throughout the course of our services.	It is necessary to enter into or perform your client agreement. We have a legal and regulatory obligation. We have a valid business reason (to verify your identity and to undertake client due diligence throughout the course of our relationship).	You have given us your explicit consent.  It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights.
To set you up as a client on the St. James’s Place client relationship management system and to communicate with you in respect of your service preferences.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to establish you as a client).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To provide services in accordance with your client agreement.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).	You have given us your explicit consent.  We need to use your information in order to establish, exercise or defend legal rights.
To arrange and implement any of our recommendations e.g. investing into certain funds or arranging a product or insurance policy for you.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).	You have given us your explicit consent.  We need to use your information in order to establish, exercise or defend legal rights.
To carry out annual reviews and reviews of ongoing suitability of your current arrangements	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we are providing appropriate services according to your circumstances).	You have given us your explicit consent.  We need to use your information in order to establish, exercise or defend legal rights.
To prevent and investigate fraud.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to prevent and detect fraud and other financial crime).	We have a substantial public interest to prevent fraud We need to use your information in order to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations.	We need to use your information in order to establish, exercise or defend legal rights. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To communicate with you and resolve any complaints that you might have.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to communicate with you, record and investigate complaints and ensure that complaints are handled appropriately). We need to use your information in order to comply with our legal and regulatory obligations.	We need to use your information in order to establish, exercise or defend legal rights.
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys).	We have a valid business reason (to develop and improve the products and services we offer).	You have given us your explicit consent.
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively)	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To apply for and claim on our own insurance.	We have a valid business reason (to maintain appropriate insurance)	We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.	You have given us your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent.	We have a valid business reason (to send you selected communications about other products and services we offer)	Not applicable

  Who will we share your personal information with?  We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• Third parties who provide a service in relation to the management of your investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where you are buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
• St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy 
• Third parties who provide sanctions checking services including Experian. 
• Compliance consultants.
• Financial crime and fraud detection agencies.
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Our insurers.
• The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

  4. Clients’ family members, business associates or beneficiaries  This section will apply if your personal information has been provided to us by a client to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or partner, dependant mentioned in a will or trust document, another beneficiary  a business partner) and will set out how we use your information. What personal information may we collect?

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.

• Your relationship to our client.

• Financial information relating to your financial liabilities, such as a property portfolio which is owned jointly between you and our client.
• Any information which is relevant to the services we provide for our client.

What special categories of personal information may we collect?

• We may collect details about your physical and mental health which are relevant to your the services we provide for our client (for example where you are the client’s partner and you have a medical condition which means that you are unable to work and therefore our client has a higher need for investment return and a lower risk appetite).

• Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.

• In limited circumstances, we may also collect information concerning your sex life or sexual orientation for example where you are in a civil partnership with our client.

How will we collect your personal information? 

• Directly from our client.
• From documents directly provided to us by our client, such as wills or trust documents where you are listed as a dependant or employment related documents and you are listed as a business partner of our client. 
• From any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and from any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
• St. James’s Place group companies.

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 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.
• We have a valid business reason to use your personal information 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 which may have been provided to us by your family member, spouse, partner or business associate who is our client.
• 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.

Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your  special categories of personal information
To provide services to our clients	We have a valid business reason (to fulfil our contractual obligations to our clients and advise on the most appropriate investments for their personal circumstances)	You have given us your explicit consent and this has been provided to us by our client.
To prevent and investigate fraud.	We have a valid business reason (to prevent and detect fraud and other financial crime). We need to use your information in order to comply with our legal obligations.	We have a substantial public interest to prevent fraud We need to use your information in order to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations.	We need to use your information in order to establish, exercise or defend legal rights. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively)	You have given us your explicit consent and this has been provided to us by our client. We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.	You have given us your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent.	We have a valid business reason (to send you selected communications about other products and services we offer)	Not applicable

Who will we share your personal information with?  We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• Third parties who provide a service in relation to the management of our client’s investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where our client is buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy 
• Compliance consultants including the Consulting Consortium
• Financial crime and fraud detection agencies.
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Our insurers.
• The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax adviser.

5.  Other business partners  If you are a business partner such as a products provider, portfolio or fund manager or contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information. What personal information may we collect?

• General information such as your name, address, business phone numbers and email addresses.

• Employment information such as job title, business cards and professional accreditations.
• Information about your clients, your employees and the services and products you offer.
• Your bank details and information obtained from checking sanction lists and credit checks.
• Information which we have gathered from publicly available sources such as internet search engines and generally obtained as part of the due diligence process conducted by St. James’s Place group companies.

How will we collect your information? 

• Directly from you
• St. James’s Place group companies.
• Publicly available sources such as internet search engines.
• From service providers who carry out sanctions checks.

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 or perform the contract that we hold with you. 
• We have a legal or regulatory obligation to use such personal information. For example, we may be required to carry out certain background checks. 
• We have a valid business reason to use your personal information 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 including reviewing the performance of our business partners.

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. Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your  special categories of personal information
To carry out fraud, credit and anti-money laundering checks on you	It is necessary to enter into a contract with you. We have a valid business reason (to assess your suitability as a business partner). We need to use your information in order to comply with our legal obligations.	Not applicable
To carry out due diligence on you.	We have a valid business reason (to ensure that you can provide guarantees in terms of confidentiality and security measures you implement to protect the information we are sharing with you about our clients).	Not applicable
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations, for example to pay your invoices for the services you have provided.	Not applicable
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively)	Not applicable
For compliance and monitoring purposes.	It is necessary to enter into a contract with you. We have a valid business reason (to ensure we are compliant and carrying out appropriate monitoring activities).	Not applicable

Who will we share your personal information with?  We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found https://www.sjp.co.uk/site-services/privacy.
• Your agents or employees as appropriate.
• Third parties who provide sanctions checking services including Experian. 
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Our insurers.
• Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

6. Users of our website  If you use our website, this section will be relevant to you and sets out our uses of your personal information.  What personal information may we collect?

• General information submitted via the website, for example where you provide your details in the contact section such as your name, contact details and company name.
• 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.

How will we collect your personal information?  We will collect your information directly from our website.  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 have a valid business reason to use your personal information, necessary for our everyday business operations and activities, for example to maintain business records and to monitor usage of the website. 

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. Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your  special categories of personal information
To respond to any enquiries you have submitted.	We have a business reason (to respond to your enquiries).	Not applicable

Who will we share your personal information with?  We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to:

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy
• Third parties who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as IT suppliers and website providers. 

• What marketing activities do we carry out? 

We carry out the following marketing activities depending on the relationship that we have with you: Where you are a prospective client We will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about our wealth management services that we offer which you might be interested in.  In these letters, we inform you that we will contact you via telephone to discuss our service offerings unless you notify us that you do not wish to receive such a call.  As part of our follow-up telephone call we will discuss the wealth management services we offer which you might be interested in and we will answer any questions that you may have.   Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you. We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so.  We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this. Where you are an existing client  We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so. We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have consented to receive this.  General marketing practices If you wish to opt out of marketing, you may do so by clicking on any “unsubscribe” link or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us using the details set out in section 7 to update your contact preferences. Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you. 8. How long do we keep personal information for?  We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to. If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 7.   9.What is our approach to sending your personal information overseas  There are a small number of instances where your personal information is transferred to countries outside of the European Economic Area (“EEA“) such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

• entering into data transfer contracts and using specific contractual provisions that have been approved by European data protection authorities otherwise known as the “standard contractual clauses”. You can find out more about standard contractual clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en;  
• transferring personal information only to companies in the United States who are certified under the “Privacy Shield”. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome or
• we will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en 

We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you. Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:

Country of transfer	Reason for the transfer	Method we use to protect your information
Hong Kong, Singapore, Shanghai	Provision of data to international offices to support clients living overseas.	We have standard contractual clauses in place

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 7.  10. Your rights  You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 7 if you wish to exercise these rights; we will not usually charge you.  We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

• in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
• in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.

We will of course inform you if any of the above situations arise and if we are unable to comply with your request The right to access your personal information  You are entitled to a copy of the personal information we hold about you and certain details of how we use it.  We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information. We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.  It would be helpful if could please complete the Data Subject Request Form, available from your Partner, to request a copy of the information we hold so that we can ensure we have all the relevant information we need to appropriately respond to your request. The right to rectification  Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it. The right to restriction of processing   In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.   The right to withdraw your consent   Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.  The right to erasure   You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request. The right to object to direct marketing  You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time.  You can do this either by clicking on the “unsubscribe” button in any email that we send to you or by contacting us using the details set out in section 8.  Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you. The right to object to processing  In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data. The right to data portability In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.  When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request Rights relating to automated decision-making   We do not carry out any automated decision making to provide products and services to you. The right to make a complaint with the ICO  If you believe that we have breached data protection laws when using your personal information, you have a right to complain to the Information Commissioner’s Office (ICO). You can visit the ICO’s website at https://ico.org.uk/ for more information.  Please note that lodging a complaint will not affect any other legal rights or remedies that you have.  11. Cookies  The Think Wealth Limited website uses cookies – small text files that are stored on your computer or in your browser – to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors’ rights of privacy, this information is anonymous and no individual visitor can be identified from it. You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org. 12. Contacting us  If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our St. James’s Place Data Protection Officer at St. James’s Place plc, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom, dpo@sjp.co.uk and 01285718453. 13. Updates to this notice  From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up to date notice.  This notice was last updated on [   {01/04/2020}  ].