Privacy Policy

This privacy policy aims to give you information on how the companies in the Praemium UK Regional Group (see Glossary) collect and process your personal data.  This includes what you tell us about yourself, what we might learn by having you as a customer, and the choices you might express to us about what marketing you want us to send you.

It is important that you read this privacy policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. 

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

The data protection law in the UK and Channel Islands changed on 25 May 2018. This privacy notice may continue to change.

 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 

  • Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, tax identifier, passport number.
  • Contact Data includes home address, mailing address, email address and telephone numbers.
  • Financial Data bank account details, and in some cases financial status and history.
  • Transaction Data includes details about payments and other details of products and services.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our systems.
  • Profile Data includes your username and password, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

On some occasions, we might collect or process Special Categories of Personal Data about you. (Special Categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In Praemium terms this would be limited to health data where the adviser opts to collect such information. Also, for AML purposes we collect information about criminal convictions and offences.
 

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide you with goods or services. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

HOW IS YOUR PERSONAL DATA COLLECTED?  

 We use different methods to collect data from and about you or your business including through: 

  • Financial Advisers.  May give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data they provide when you :
  • apply for or use our products or services;
  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • request marketing to be sent to you;
  • when you request that we update your data;
  • take part in a promotion or survey; or
  • give us some feedback.
  • Other companies within the Praemium Group
  • Automated technologies or interactions. As you interact with our systems, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our  cookie policy for further details.
  • Other third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below
  • Technical Data from the following parties:

(a)  data providers such as product providers

(b)  search information providers based inside OR outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as bank account and address verification engines.
  • Identity and Contact Data from data brokers or aggregators such as credit reference agencies.
  • Identity and Contact Data from publicly availably sources [such as Companies House based inside the EU.

 

HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract that we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new or prospective customer

 

  • Identity
  • Contact

 

Performance of a contract with you:

Necessary for our legitimate interests

To deliver our service, including:

(a) to make and manage payments

(b) to manage fees, changes and interest

(c) to collect and recover money that is owed to us

 

  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications

 

(a) Performance of a contract with you
 

(b) Necessary to comply with a legal obligation
 

(a + b) Necessary for our legitimate interests (being efficient about how we fulfil our legal and contractual duties

 

(c) Necessary for our legitimate interests

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

  • Identity
  • Contact
  • Profile
  • Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To develop and carry out marketing activities

  • Identity
  • Contact
  • Profile
  • Marketing and Communications

Necessary for our legitimate interests

To detect, investigate, report and seek to prevent financial crime.

  • Identity
  • Contact
  • Financial
  • Transaction

Necessary to comply with a legal obligation

To manage risk for us and our customers

  • Identity
  • Contact
  • Financial
  • Transaction

Necessary to comply with a legal obligation

Necessary for our legitimate interests

To obey laws and regulations that apply to us

  • Identity
  • Contact
  • Financial
  • Transaction

Necessary to comply with a legal obligation

To respond to complaints and seek to resolve them.

  • Identity
  • Contact
  • Financial
  • Transaction

Performance of a contract

Necessary to comply with a legal obligation

To enable you to partake in a survey

 

  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

  • Identity
  • Contact
  • Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and

 

Necessary to comply with a legal obligation

 

To deliver relevant website content and measure or understand the effectiveness of the content we serve to you

 

  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

  • Technical
  • Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

 

MARKETING  

If you are our client, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

THIRD-PARTY MARKETING  

We will get, or ensure that you have provided your express opt-in consent before we share your personal data with any company outside the Praemium Group for marketing purposes.

 

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

  

COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our web products may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy

 

CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where we are the Controller of your personal data, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

INTERNATIONAL TRANSFERS  

We share your personal data within the Praemium Group. This may involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based, or store data outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. 

Whenever we transfer your personal data out of the EEA, we will have in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we transfer data to them if they are party to the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact us if you would like further information.

 

DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION  

We will keep your personal information for as long as you are a customer of ours.

After you stop being a customer, we may keep your data indefinitely for one of these reasons:   

  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to rules that apply to us.
  • If we cannot delete it for legal, regulatory or technical reasons.
  • For research or statistical purposes.

If we do, we will make sure that your privacy is protected and only use it for those purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary below  to find out more about these rights: 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us

 

NO FEE USUALLY REQUIRED   

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

GLOSSARY   

LAWFUL BASIS  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means any freely given, specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action, which signifies agreement to the processing of the personal data relating to you.

 

THIRD PARTIES  

INTERNAL THIRD PARTIES  

Other companies in the Praemium Group acting as joint controllers or processors and who are based in Jersey, Australia, Yerevan, Hong Kong, China and the United Arab Emirates and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES  

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, Jerseyand Australia who provide consultancy, banking services, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS  

You have the right to:

Request access to your personal data (commonly known as a “data subject access  request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Praemium UK Regional Group includes:

  • Praemium Portfolio Services Limited
  • Praemium Administration Limited
  • Praemium (UK) Limited
  • Praemium International Limited 
  • Smartfund Investment Management
  • Smartfund Nominees Ltd
  • Praemium Trustee Limited
  • Wensley MacKay Ltd
  • WM Trustee Services Limited
  • Plum Software Limited

Data Privacy Manager

We have appointed a Data Privacy Manager who is responsible for addressing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

CONTACT DETAILS  

Full contact details are: 

Name: Sue Smith  Position: Data Protection Manager

Email address: DataPrivacyManager@Praemium.com

Postal address: 4th Floor, Salisbury House, London Wall, London EC2M 5QQ

Telephone number:  0203 873 5566

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), The Jersey Office of the Information Commissioner, can be accessed via www.oicjersey.org.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data Protection Officer 
Praemium (UK) Limited
4th Floor, Suite 643-659
Salisbury House,
London Wall
London EC2M 5QQ

Contact Praemium

4th Floor, Suite 643-659
Salisbury House,
London Wall
London EC2M 5QQ

+44 (0)207 562 2450