Terms & Conditions

Please read this information carefully. Access to this website is confirmation that you have understood and agree to be bound by all of these terms and conditions.

TERMS & CONDITIONS

1. We do our best to ensure that the website operates properly at all times, but we make no warranties as to the availability or accessibility of the website, and (save as otherwise set out in these terms and conditions) we will not be liable for any damages, loss, costs or expenses incurred by you as a result of any lack of availability or accessibility of the website.

2. Nothing within these conditions operates so as to exclude, limit or restrict our liability for death or personal injury.

3. Where you deal as a consumer, nothing in the above exclusions affects your statutory rights.

4. All Intellectual Property Rights and goodwill in or relating to the contents of the website belong to either ourselves, to a member of the St. James’s Place group or to our suppliers.

Nothing contained in these conditions or the website should be construed as granting by implication, estoppel, personal bar, or otherwise, any licence or right to use any of the trade marks without our permission. However, copying and printing of those web pages which contain the trademarks is permitted within the scope of the licence below.

You may download to a local hard disk and print extracts from the website solely for personal, non-commercial use. You may also recopy downloaded extracts to others for their personal, non commercial use.

You may not reproduce part or all of the contents of the website in any form unless it is for personal, non commercial use.

You may not copy or otherwise incorporate into or store in any other website, electronic retrieval system, publication or other work any of the content of the website in any form (whether hard copy, electronic or other).

You may not frame or link to the website or any part of it without our express permission.

SITE DISCLAIMER

The information published on this website is provided as a convenience to visitors and should be used for information purposes only and is subject to change without notice. None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact one of our personnel.

While we use reasonable efforts to ensure that the information contained on this website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. We accept no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. These documents should not be copied, reproduced or redistributed, in whole or in part.

No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros. Links from this website exist for information only and we accept no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by us or St. James's Place. Links to this website are not permitted without our prior written consent. Please note that clicking on links to external websites will cause you to leave this website.

This website is powered by Siteset Digital.

PRIVACY POLICY

As Partners within the St. James's Place Wealth Management Partnership, I 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 I 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 I provide.

This Privacy Policy explains when and why I collect your personal information as part of my provision of wealth management services, and also explains how I use your information. If requested, I will provide you with a copy of this Privacy Policy for your records.

"I", "me" "my" 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 the St. James's Place Privacy Policy. The St. James's Place Privacy Policy can be found here.

1. About me

In order for me to deliver such financial services and deal with any correspondence that may arise, I need to collect and process personal information. This makes me a "data controller".

Eleanor Coleman Hong Kong will be acting as data controller of your personal information, jointly with St. James's Place Wealth Management.

2. My processing of your personal information

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

Sometimes I 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, I may need access to information about your health. Details about your health might also be needed for me to make reasonable adjustments when providing my services to you.

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

Where you provide personal information to me about other individuals (for example, members of your family or other dependents) I 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, I have split it into different sections. Please click on the section below that best describes your relationship with me.

Prospective clients

This section will apply if you are a prospective client and I 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 I 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 I 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 my use of cookies. You can find more information about this in my cookies policy which can be found at https://www.sjp.co.uk/site-services/privacy.
Information obtained during telephone recordings.
Information I may 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 I need to carry out enhanced due diligence.

What special categories of personal information may I collect?

Details about any criminal convictions and any related information which have been obtained from my 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.
I may collect details about your health which are relevant to your application (e.g. as part of a pension or income protection need I 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 me because it explains your risk appetite for investments.
In limited circumstances, I may also collect other special categories of data as detailed on a separate consent form.

How will I collect your personal information?

I will collect information directly from you when:

you enquire about or apply to receive my wealth management services; and
you contact me by email, telephone and through other written and verbal communications.

I 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

What will I use your personal information for?

There are a number of reasons I use your personal information and for each use I need to have a "lawful basis" to do so.

I will rely on the following "Lawful Basis" when I process your "personal information":

I need to use your personal information to enter into the client agreement, for example, I need to use your personal information to assess whether I can provide services to you and to set you up as a client on the St. James's Place client relationship management system.
I have a legal or regulatory obligation to use such personal information. For example, my regulators require me to hold certain records of my dealings with you and I are required to report to St. James's Place on my relationship with you.
I have a valid business reason to use your personal information which is necessary for my 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 my business models and undertake strategic and operational business analysis.

In each case I assess my need to use this personal information for these purposes against your rights to privacy to ensure I are protecting your rights.

When I use your "special categories of personal information", I must have an additional "legal ground" and I will rely on the following legal grounds in these circumstances:

You have given your explicit consent to my use of your special categories of personal information. In some cases I are not able to offer you certain advice or financial products unless I have your health information.
There is a substantial public interest such as prevention and detection of fraud.
I need to use such special categories of personal information to establish, exercise or defend legal rights, such as when I 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	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. I have a valid business reason (to verify your identity).	You have given me your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where I suspect fraud). I need to establish, exercise or defend legal rights.
To comply with my legal or regulatory obligations.	I need to use your information in order to comply with my legal obligations.	I 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 I 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. I have a valid business reason (to establish you as a client).	You have given me your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where I suspect fraud).
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	I have a valid business reason (to run my business efficiently and effectively).	You have given me your explicit consent. I 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 me your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where I don't require your consent.	I have a valid business reason (to send you selected communications about other products and services I offer)	Not applicable
To provide improved quality, training and security (for example, through recorded or monitored phone calls to my contact numbers, or carrying out customer satisfaction surveys).	I have a valid business reason (to develop and improve the products and services I offer).	You have given me your explicit consent.

Who will I share your personal information with?

I will not sell or transfer your personal information to anyone unless I have a valid purpose as set out above and I will only disclose it to the following parties:

Other Partners within the Partnership to provide specialist services where I 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.
My regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
Selected third parties in connection with any sale, transfer or disposal of my business.
My insurers.
The police, HMRC and other crime prevention and detection agencies.
Third parties including self-employed contractors who I have entered into contractual arrangements with to provide services I need to carry out my everyday business activities such as business administration, partner support specialists, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, my subcontractors and tax advisers.

Existing clients

This section will apply if you currently receive wealth management services from me. This section will set out how I use your information.

What personal information may I 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 I 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 me 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 my use of cookies. You can find more information about this in my cookies policy in section 7 below.
Your marketing preferences and details of your customer experience with me.
Information which I 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 I need to carry out enhanced due diligence.

What special categories of information will I collect?

Details about any criminal convictions and any related information which have been obtained from my 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.
I may collect details about your health which are relevant to your application (e.g. as part of a pension need I may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client or where I are applying for income protection insurance I 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 me because it explains your risk appetite for investments.
In limited circumstances, I may also collect other special categoroies of data as detailed on a separate consent form.

How will I collect your personal information?

I will collect information directly from you when:

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

I 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 me 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 I have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.

What will I use your personal information for?

There are a number of reasons I use your personal information and for each use I need to have a "legal ground" to do so.

I will rely on the following "Lawful Basis" when I process your "personal information":

I need to use your personal information to enter into or perform the client agreement that I hold with you. For example, I need to use your personal information to provide my services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims.
I have a legal or regulatory obligation to use such personal information. For example, my regulators require me to hold certain records of my dealings with you.
I have a valid business reason to use your personal information which is necessary for my 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 my business models and undertake strategic and operational business analysis.

In each case I assess my need to use this personal information for these purposes against your rights to privacy to ensure I are protecting your rights.

When I use your "special categories of personal information", I must have an additional "legal ground" and I will rely on the following Lawful Basis in these circumstances:

You have given your explicit consent to my use of your special categories of personal information. In some cases I are not able to offer you certain advice or financial products unless I have your relevant health information.
There is a substantial public interest such as prevention and detection of fraud.
I need to use such special categories of personal information to establish, exercise or defend legal rights, such as when I are facing legal proceedings or want to bring legal proceedings ourselves.

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. I have a valid business reason (to carry out necessary compliance checks). I have a legal and regulatory obligation.	It is in the substantial public interest to prevent or detect unlawful acts (where I suspect fraud). I need to establish, exercise or defend legal rights. You have given me your explicit consent.
To verify your information throughout the course of my services.	It is necessary to enter into or perform your client agreement. I have a legal and regulatory obligation. I have a valid business reason (to verify your identity and to undertake client due diligence throughout the course of my relationship).	You have given me your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where I suspect fraud). I 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. I have a valid business reason (to establish you as a client).	You have given me your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where I suspect fraud).
To provide services in accordance with your client agreement.	It is necessary to enter into or perform your client agreement. I have a valid business reason (to ensure that I fulfil my contractual obligations to clients).	You have given me your explicit consent. I need to use your information in order to establish, exercise or defend legal rights.
To arrange and implement any of my 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. I have a valid business reason (to ensure that I fulfil my contractual obligations to clients).	You have given me your explicit consent. I 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. I have a valid business reason (to ensure that I are providing appropriate services according to your circumstances).	You have given me your explicit consent. I 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. I have a valid business reason (to prevent and detect fraud and other financial crime).	I have a substantial public interest to prevent fraud I need to use your information in order to establish, exercise or defend legal rights.
To comply with my legal or regulatory obligations.	I need to use your information in order to comply with my legal obligations.	I 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 I 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. I have a valid business reason (to communicate with you, record and investigate complaints and ensure that complaints are handled appropriately). I need to use your information in order to comply with my legal and regulatory obligations.	I 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 my contact numbers, or carrying out customer satisfaction surveys).	I have a valid business reason (to develop and improve the products and services I offer).	You have given me your explicit consent.
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	I have a valid business reason (to run my business efficiently and effectively)	You have given me your explicit consent. I need to use your information in order to establish, exercise or defend legal rights.
To apply for and claim on my own insurance.	I have a valid business reason (to maintain appropriate insurance)	I 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 me your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where I don't require your consent.	I have a valid business reason (to send you selected communications about other products and services I offer)	Not applicable

Who will I share your personal information with?

I will not sell or transfer your personal information to anyone unless I have a valid purpose as set out above and I will only disclose it to the following parties:

Other Partners within the Partnership to provide specialist services where I 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.
Other Partners within the Partnership where there is a change to the clients servicing Partner.
Third parties who provide a service in relation to the management of your investments or facilitate the arrangement of products I recommend such as product providers, portfolio and fund managers, insurers where you are buying income protection products. Where I 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 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.
My regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
Selected third parties in connection with any sale, transfer or disposal of my business.
My insurers.
The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who I have entered into contractual arrangements with to provide services I need to carry out my everyday business activities such as business administration, partner support specialists, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, my subcontractors and tax advisers.

Clients' family members or business associates

This section will apply if your personal information has been provided to me by a client to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or dependant mentioned in a will or trust document or a business partner) and will set out how I use your information.

What personal information may I collect?

General information such as your name, address, phone numbers and email addresses, date of birth and gender.
Your relationship to my client.
Financial information relating to your financial liabilities, such as a property portfolio which is owned jointly between you and my client.
Any information which is relevant to the services I provide for my client.

What special categories of personal information may I collect?

I may collect details about your physical and mental health which are relevant to the services I provide for my 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 my 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 me when that IFA was acquired by St. James's Place group companies.
In limited circumstances, I may also collect information concerning your sex life or sexual orientation for example where you are in a civil partnership with my client.

How will I collect your personal information?

Directly from my client.
From documents directly provided to me by my 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 my 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 me when that IFA was acquired by St. James's Place group companies.
St. James's Place group companies.

What will I use your personal information for?

There are a number of reasons I use your personal information and for each use I need to have a "legal ground" to do so.

I will rely on the following "Lawful Basis" when I process your "personal information":

I have a legal or regulatory obligation to use such personal information. For example, my regulators require me to hold certain records of my dealings with you.
I have a valid business reason to use your personal information which is necessary for my 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 my business models and undertake strategic and operational business analysis.

In each case I assess my need to use this personal information for these purposes against your rights to privacy to ensure I are protecting your rights.

When I use your "special categories of personal information", I must have an additional "legal ground" and I will rely on the following Lawful Basis in these circumstances:

You have given your explicit consent to my use of your special categories of personal information which may have been provided to me by your family member, spouse, partner or business associate who is my client.
There is a substantial public interest such as prevention and detection of fraud.
I need to use such special categories of personal information to establish, exercise or defend legal rights, such as when I are facing legal proceedings or want to bring legal proceedings ourselves.

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

Who will I share your personal information with?

I will not sell or transfer your personal information to anyone unless I have a valid purpose as set out above and I will only disclose it to the following parties:

Other Partners within the Partnership to provide specialist services where I 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 my client's investments or facilitate the arrangement of products I recommend such as product providers, portfolio and fund managers, insurers where my client is buying income protection products. Where I 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 at www.sjp.co.uk/site-services/privacy
Compliance consultants including the Consulting Consortium
Financial crime and fraud detection agencies.
My regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
Selected third parties in connection with any sale, transfer or disposal of my business.
My insurers.
The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who I have entered into contractual arrangements with to provide services I need to carry out my everyday business activities such as business administration, partner support specialists, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, my subcontractors and tax adviser

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 my behalf, this section will be relevant to you and sets out my uses of your personal information.

What personal information may I 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 I 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 I collect your information?

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

What will I use your personal information for?

There are a number of reasons I use your personal information and for each use I need to have a "legal ground" to do so.

I will rely on the following "Lawful Basis" when I process your "personal information":

I need to use your personal information to enter into or perform the contract that I hold with you.
I have a legal or regulatory obligation to use such personal information. For example, I may be required to carry out certain background checks.
I have a valid business reason to use your personal information which is necessary for my 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 my business models and undertake strategic and operational business analysis including reviewing the performance of my business partners.

In each case I assess my need to use this personal information for these purposes against your rights to privacy to ensure I are protecting your rights.

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. I have a valid business reason (to assess your suitability as a business partner). I need to use your information in order to comply with my legal obligations.	Not applicable
To carry out due diligence on you.	I 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 I are sharing with you about my clients).	Not applicable
To comply with my legal or regulatory obligations.	I need to use your information in order to comply with my 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.	I have a valid business reason (to run my business efficiently and effectively)	Not applicable
For compliance and monitoring purposes.	It is necessary to enter into a contract with you. I have a valid business reason (to ensure I are compliant and carrying out appropriate monitoring activities).	Not applicable

Who will I share your personal information with?

I will not sell or transfer your personal information to anyone unless I have a valid reason as set out above and I 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 at http://www.sjp.co.uk/site-services/privacy.
Your agents or employees as appropriate.
Third parties who provide sanctions checking services including SmartSearch.
My regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
Selected third parties in connection with any sale, transfer or disposal of my business.
My insurers.
Third parties including self-employed contractors who I have entered into contractual arrangements with to provide services I need to carry out my everyday business activities such as document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, my subcontractors and tax advisers.

Users of my website

If you use my website, this section will be relevant to you and sets out my uses of your personal information.

What personal information may I 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 my use of cookies. You can find more information about this in my cookies policy which can be found below

How will I collect your personal information?

I will collect your information directly from my website.

What will I use your personal information for?

There are a number of reasons I use your personal information and for each use I need to have a "legal ground" to do so.

I will rely on the following "legal ground" when I process your "personal information":

I have a valid business reason to use your personal information, necessary for my everyday business operations and activities, for example to maintain business records and to monitor usage of the website.

In each case I assess my need to use this personal information for these purposes against your rights to privacy to ensure I are protecting your rights.

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.	I have a business reason (to respond to your enquires).

Who will I share your personal information with?

I will not sell or transfer your personal information to anyone unless I have a valid purpose as set out above and I 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 at www.sjp.co.uk/site-services/privacy
Third parties who I have entered into contractual arrangements with to provide services I need to carry out my everyday business activities such as IT suppliers and website providers.

3. What marketing activities do I carry out?

I carry out the following marketing activities depending on the relationship that I have with you:

1. Where you are a prospective client

I will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about my wealth management services that I offer which you might be interested in.

In these letters, I inform you that I will contact you via telephone to discuss my service offerings unless you notify me that you do not wish to receive such a call.

As part of my follow-up telephone call I will discuss the wealth management services I offer which you might be interested in and I will answer any questions that you may have.

Where I have obtained your personal information from a marketing list from a third party, I will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for me to market to you.

I will use also your personal information to provide you with information about my wealth management services and any newsletters and event invites where you have provided your consent for me to do so.

I will also provide you with information of St. James's Place wealth management products and other third party products which I think may interest you where you have indicated that you would like to receive this.

2. Where you are an existing client

I will use your personal information to provide you with information about my wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services I offer or where you have provided your consent for me to do so.

I will also provide you with information of St. James's Place wealth management products and other third party products which I 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 me when I call you. Otherwise you can always contact me to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, I may still send you communications in connection with the services I offer you.

4. How long do I keep your personal information for?

I 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 my 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, I are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which I 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 12.

5. What is my approach to sending information overseas?

There may be some instances where your personal information is transferred to countries outside of the European Economic Area ("EEA") such as when I transfer information to my other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on my behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, I will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. I will do so in a number of ways including:

entering into data transfer contracts and using specific contractual provisions that has 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
I 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

I 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 I have with you.

Depending on my relationship and your particular circumstances, I might transfer personal information anywhere in the world. An example of my regular data transfers outside the EEA is set out below:

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

If you would like further information regarding my data transfers and the steps I take to safeguard your personal information, please contact us using the details set out in section 12.

6. How do I protect your personal information?

At St. James's Place, I take my responsibility to look after your personal information and privacy seriously. In today's world, I have all seen a growing trend in cybercrime and security breaches. I have a number of security measures in place to help prevent fraud and cybercrime.

I have a dedicated group, the "Information Security Oversight Committee", that provides oversight and guidance to my information security and privacy programme.

The executive body responsible for privacy and data security is the Information Security Oversight Committee (ISOC) - chaired by the Chief Technology Officer, a member of the Executive Board. ISOC has a reporting line that enables effective escalation of issues up to the Board where appropriate.
I educate and train my employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.

My employees, Partners and contractors take part in an annual Information Security training and awareness program and must agree to adhere to the Data Protection Act and my own Information Security Policy that are designed to keep your information safe. These are refreshed each year to reflect the current trends that are being observed across the information security landscape. Information Security awareness also forms part of my new employee induction program. I also educate my employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to my Financial Crime team.
When you login, or send me information on the internet I protect the security of this information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).

When you use your web browser to login, view or share information with me, all electronic information exchanged is encrypted using 2048bit SSL (Secure Sockets Layer) certificate. You are able to identify this by looking for the HTTPS:// and the padlock in the address bar at the top of your browser:
I will always interact with you in a safe, secure and consistent manner.
To keep your information secure and to protect my clients from fraud, St. James's Place will only interact with you in the following ways. If in doubt, call your St. James's Place Partner directly or alternatively the St. James's Place Information Security Team on 01285 555-1234. When interacting with you, I will:
- Only send funds that you have requested to be withdrawn to a verified bank account in your name.
I will not: Ask you for your password over the phone. Send you an unsolicited email with a link to my login page asking you to enter your Online Wealth Account credentials. Ask you for payment or credit card details by email or telephone. Call you to notify you of a problem, and then request you call me back immediately to discuss the problem further.
I continually review my physical and logical security controls in place across the business.

Physical controls - As well as protecting your digital information, St. James's Place also protects their premises and physical locations where personal data may be used and stored. These measures include security guards, security entrances, secure disposal of confidential waste and hardware, CCTV, personal card access and locks on doors and file storage cabinets, with a 'clear desk' policy to ensure all information is locked away and protected. Logical controls - St. James's Place uses technical security measures to make sure my systems where I store and use confidential information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business. All employee emails and devices are encrypted to enable secure transfer and storage of personal information.
I conduct security testing of my applications and services in a controlled testing environment before they are made available for my Clients to use.

I perform security risk assessments for each of my sites to identify and control risks.
I have a business resiliency plan with a disaster recovery and business continuity testing.
The purpose of Business Continuity Management and the St. James's Place Business Continuity Plan, is to provide an effective, predefined and documented framework to respond to an incident affecting the Group's activities. The key drivers in developing the business recovery plans are;
- To mitigate the risks that could lead to the significant disruption of my products and services to my Clients.

However, whilst I take appropriate technical and organisational measures to safeguard your personal data, please note that I cannot guarantee the security of any personal data that you transfer over the internet to me.

7. Cookies

The St. James's Place website and content provided by Asset.tv uses cookies - small text files that are stored on your computer or in your browser - to help me to monitor how visitors use my site and allow me 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 my visitors collectively, for example the number of visits the website receives. In order to respect my 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 my site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

8. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. ('Google'). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

In addition, I use Google's remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on my sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.

I will only collect personal information about you if you send me an e-mail enquiry via the 'contact me' facility or you register to receive your Unit Trust Manager's Reports by email. In order for this to happen, you will need to fill out the on line 'contact me' form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the 'contact me' form, which also tells you how this information will be used. The type of information collected to register to receive the Unit Trust Manager's Reports by email will be apparent from the details requested when you register. The information collected when you register will only be used to email your Unit Trust Manager's Reports and for no other reason.

I take all reasonable precautions to protect my visitors' information, both on and off line. If your personal information changes, please let me know and I will correct, update or remove any information that I hold about you on my active databases. I may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which St. James's Place handles data collected from you on this website, please visit the contact me page.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.

9. Monitoring

Please note that if you communicate with me electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of my business and my customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James's Place employees comply with legal obligations and St. James's Place policies and procedures (including my customer relations practices).

10. Hyperlinks

I may provide hyperlinks from this website ('the Site') to websites of other organisations including websites of associated companies. Please note that this Privacy Policy applies only to this Site and that St. James's Place will not be liable for the contents of linked websites or any transactions carried out with organisations operating those websites.

11. Your rights

You have several rights which you can exercise at any time relating to the personal information that I hold about you and use in the ways set out in this notice. Please contact me at any time using the details set out in section 12 if you wish to exercise these rights; I will not usually charge you.

I respect your rights and will always consider and assess them but please be aware that there may be some instances where I cannot comply with a request that you make as the consequence might be that:

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

I will of course inform you if any of the above situations arise and if I are unable to comply with your request.

The right to access your personal information

You are entitled to a copy of the personal information I hold about you and certain details of how I use it.

I are happy to provide you with such details but in the interests of confidentiality, I follow strict disclosure procedures which may mean that I will require proof of identify from you prior to disclosing such information.

I 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 you could please complete the Data Subject Request Form to request a copy of the information I hold so that I can ensure I have all the relevant information I need to appropriately respond to your request.

The right to rectification

Please help me 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 I hold about you, please contact me and ask me to update or amend it.

The right to restriction of processing

In certain circumstances, you have the right to ask me to stop using your personal information, for example where you think that the personal information I hold about you may be inaccurate or where you think that I no longer need to use your personal information.

The right to withdraw your consent

Where I 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 I no longer need your personal information for the purpose I originally collected it. When you exercise this right, I need to consider other factors such as my own regulatory obligation, to assess whether I 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 me and you have the right to request that I stop sending you marketing messages at any time. You can do this either by clicking on the "unsubscribe" button in any email that I send to you or by contacting me using the details set out in section 12.

Please note that, even if you opt out of receiving marketing messages, I may still send you communications which are relevant to the nature of services I offer you.

The right to data portability

In certain circumstances, you can request that I transfer personal information that you have provided to me to a third party.

When you exercise this right, I need to consider other factors such as my own regulatory obligations, to assess whether I can comply with your request

Rights relating to automated decision-making

St. James's Place do not rely on automated decision making to provide products and services to you.

The right to make a complaint with the ICO

If you believe that I 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.

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 I collect, store or use your personal information, you may contact the St. James's Place Data Protection Officer at St. James's Place (Hong Kong) Limited, 1/F Henley Building, 5 Queen's Road Central, Hong Kong, dpo@sjp.co.uk and +852 2824 1083.

13. Updates to this Notice

From time to time I may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments.

This notice was last updated on 03-06-2019.

Eleanor Coleman

Associate Partner

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