Privacy Notice

September 2023

Partners Wealth Management LLP is aware of its obligations under data protection law and is committed to processing your personal data securely and transparently. This Privacy Notice sets out, in line with UK GDPR and Data Protection Act 2018, the types of personal data that we hold on you and how we use that information.

In this Privacy Notice we refer to ourselves as “PWM”, “us” and/or “we”.

Who we are

This is the Privacy Notice of Partners Wealth Management LLP of 1 Angel Court, London, EC2R 7HJ. Our business is the provision of financial planning and investment advice and in our engagement with clients and prospective clients we will need to hold your personal data. We set out below important information about our processing of personal data relating to living individuals and reference the purposes for which we do so in the context of our business.

The information we collect

So we can provide you with a service that meets your precise financial goals and needs, we obtain certain information about your personal and financial situation and this may include the following information:

Identity details such as your name, age, date of birth, gender and national insurance number;
Personal and professional contact details, including your address, email, phone number and mobile number;
Personal financial information, including bank details, sources of wealth, existing investments, tax returns, and employment details;
Details concerning your attitude to investment risk. This is collected via the completion of a questionnaire with guidance from our Advisers;
Lifestyle information (such as hobbies and interests);
Information on associated third parties, such as your spouse, children and beneficiaries of trusts;
Account activity. This information is generated and collected through the provision of our services to you through third party providers;
Information collected as part of anti-money laundering checks including on occasion information on criminal convictions and offences;
Internal Protocol (IP) address. This information is collected passively when you use our website or client portal; and
Use of our website. This information is collected through cookies as further explained in our Cookies Notice.

We may record our phone calls with you where we have a regulatory obligation to do so.

We may also collect some special categories of personal data, such as information about health conditions, where this is relevant to the service we are providing to you.

Where you provide us with personal data relating to others, such as family members, you confirm that you have their consent or are otherwise entitled to provide this information to us and for us to use it in the ways described in this Privacy Notice.

We may be provided with the information listed above by either yourself, such as when engaging with us or using our services, or by others, such as:

Your relatives and other mutual contacts;
Your parent(s) or legal guardian in relation to minors;
Trustees of a trust you are connected with;
Money laundering checks
Trust beneficiaries; and
Your registered agent or introducer.

How and why we use this information

We have published this Privacy Notice so that you understand what we do with your personal data.

We may use your personal data as follows:

Welcoming you as a client;
Dealing with you as a client;
To carry out checks for the purposes of keeping your money and personal data secure, detecting and preventing fraud and money laundering, and to check your identity before we provide services to you
Performing our services to clients which involve processing personal data about others associated with them, such as a spouse, parent, guardian, child, other family member, a representative of our client, or a trustee, settlor or beneficiary;
Operating our business;
Educating you about financial products via face to face and online events;
Adhering to our regulatory obligations; and
Informing you about our services (marketing).

Our legal basis for using your personal data

We only use your personal data where such use is permitted by laws that protect your privacy rights. We will process your personal data in the ways described below:

We have your consent (if consent is needed);
We need to use the information to perform a contract with you;
We need to use the information to comply with our legal obligations; or
It is fair to use the personal data either in our legitimate interests or someone else’s legitimate interests. This can include where it is in our legitimate interests to market additional products or services to you and we think they may be of interest to you.
In the case of sensitive personal data (also known as special categories of personal data), it is in the substantial public interest (for example, to support you if you are or become a vulnerable client)

Who we share your information with

We may share your personal data with:

Third party service providers where it is necessary to facilitate the services we provide to you;
Members of your family, including your spouse, partner or other adult members of your family or dependants, if you are one of our private clients and where it has been agreed that our services will include these third parties;
Representatives, trustees, settlors or beneficiaries if you are one of our charity or trust clients, and in each case, where it has been agreed that our services will include these third parties;
Very infrequently, we are required by law to report matters to law enforcement agencies for the prevention and detection of crime, including the police and the National Crime Agency. In certain circumstances we are not permitted to inform you that we’ve done so or intend to do so;
HM Revenue & Customs;
The Financial Conduct Authority, the Financial Ombudsman, the Information Commissioner’s Office and other regulatory bodies;
Fraud prevention agencies;
With our professional advisers (including accountant, lawyers and internal and external auditors) who are subject to confidentiality provisions;
With other members of our corporate group;
Where otherwise required in connection with us providing our services and carrying out our legal obligations under our agreement with you;
Where it is in the public interest to disclose such information; or
At your request or with your consent.

Where your information is processed

You acknowledge that your personal data may be sent internationally, including to countries outside of the European Economic Area. We will always take steps to ensure that any such transfer complies with applicable data protection laws. This involves establishing adequate contracts with third parties who may transfer your personal data internationally (where necessary) and these contracts will incorporate standard data protection clauses as approved by the ICO to safeguard your data protection rights.

How long do we keep your information?

We have a legitimate interest to keep all records relating to our business for our internal purposes and to deal with queries or complaints which may arise.

As a regulated business we also need to keep records for 5 years or longer if required.

We keep personal data of clients only where and for so long as it is necessary to provide you with our products and services while you are a client and afterwards for so long as necessary to meet our legal or regulatory obligations or, if longer, for in relation to claims which could be made against us. Our normal practice is to keep client information for at least 5 years after you cease to be a client.

Your rights in relation to Data Protection

You have several rights under data protection law with respect to how your personal information is held and used by us. More information can be obtained from the Information Commissioner’s website. If you wish to request to exercise any of these rights or if you would like further information about them, you can contact us using the details set out in the ‘How to Contact Us’ section below. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection law.

Where we use consent as the lawful basis for processing your personal data, you have the right to withdraw this consent at any time. This will not affect the lawfulness of any processing of this personal data that we carried out before your withdrawal. If you choose to withdraw your consent to us processing your personal data, we may not be able to provide you with certain products and services.

You have the right to ask for a copy of the personal information we hold about you in a written format, free of charge.

You also have the right, at no cost, to require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information. In order for us to do so, you must inform us of any changes to your personal information so that we can keep it up to date.

In some cases, you have the right to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.

You have the right to have the personal information we hold about you erased in certain circumstances unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations. We may not be able to provide our products and services to you if you ask us to erase your personal information.

You have certain rights to obtain and reuse your personal information for your own purposes across different organisations for example, if you wish to move to a new financial services provider. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely, without affecting its usability.

How to contact us

If you have any questions about this Privacy Notice or the personal data we will obtain and process about you, please contact:

Partners Wealth Management,
1 Angel Court,
London,
EC2R 7HJ.

Email us: data.protectionpwm@partnerswealthmanagement.co.uk

If you do not believe we have handled your information as set out in our Privacy Notice, or you otherwise wish to complain about our handling of personal data relating to you, please contact us at the above address.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire
SK9 5AF.

Tel: 0303 123 1113

www.ico.org.uk

Changes to this Privacy Notice

If we decide to change this Privacy Notice, we’ll post the updated Privacy Notice on our website so that you’re always aware of what personal information we collect, how we use it and under what circumstances we disclose it.