Privacy Notice

  1. About this privacy notice

    1. Partners Capital LLP is registered in England with registration number OC332859 and has its registered office at 5th floor, 5 Young Street, London W8 5EH (authorised and regulated by the Financial Conduct Authority; VAT number 927 2939 90) (“Partners Capital”) and other companies in the Partners Capital group collect and use certain personal data about you.
    2. We consider privacy to be fundamental to our relationship with our current clients and prospective clients. We are committed to maintaining the confidentiality, integrity and security of their personal data. Accordingly, we have developed internal policies to protect personal data while allowing clients’ needs to be met.
    3. This privacy notice sets out the basis on which any personal data about you that you provide to us or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.
    4. The primary purpose of this notice is to inform our current clients of our privacy policies. However, prospective clients also fully benefit from the protections outlined in this document. The key difference for prospective clients versus our current clients is that in most cases, the data that we hold on prospective clients will be considerably less comprehensive, oftentimes, limited to an email address and publicly available information.
    5. For the purposes of data protection law, we are a data controller in respect of your personal data and are responsible for ensuring that we use your personal data in compliance with data protection law.
    6. We use the following definitions in this privacy notice:
      • "we," "us" or "our", means Partners Capital LLP; and
      • “personal data” means data that relates to a living individual who can be identified from the data (either by itself or when it is combined with other data).
  2. Personal data that we collect about you

    1. We collect and process different types of personal data about you as described below:
      1. Personal data that you provide to us or one of our affiliates. This includes information about you that you give us by filing in forms or by communicating with us, whether face-to-face, by phone, e-mail, through our website partners-cap.com (the “Site”) or otherwise. Such information may include:
        • Basic personal data (such as first name; family name; email address; phone number; address; city; postcode; country);
        • Any information that you choose to share with us (whether through our Site, through populating this Discretionary Management Agreement or otherwise) which may be considered personal data; and
        • Information about your dependants, banking relationships and bank account details, tax information, national insurance number, passport or ID card details, employment details, information about your PEP (Politically Exposed Person) status and source of wealth information.
      2. Personal data that we collect or generate about you. Such information may include:
        • Information about our business relationship with you and our interactions with you;
        • When you submit identifiable comments or other content to us, we collect whatever information you supply and use this information to communicate with you if requested, and otherwise fulfil the purpose of the content submission;
        • Call recordings, data relating to IT usage and risk profile information.
      3. Information we obtain from other sources.
        • We may collect and store information that is publicly available on websites such as Companies House and from information sources we subscribe to such as Thomson Reuters World Check-One.
  3. How we use your personal data

    1. Your personal data may be stored and processed by us in the following ways and for the following purposes:
      1. For the management and administration of our business;
      2. Creating, improving and developing our products and services, and the operation of our Site;
      3. Assessing risk profiles, tailoring our product and service offerings to different client needs;
      4. Contacting you about programs, products or services that we believe may be of interest to you, and new product or service announcements or event invitations;
      5. Contacting you to respond to your requests or inquiries and provide user support;
      6. Conducting market research, surveys, and similar inquiries to help us understand trends and user needs across product categories or user groups;
      7. Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorised access to or use of personal data, our Site or data systems;>
      8. In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
      9. Investigating and resolving disputes and security issues and enforcing our legal rights; and/or
      10. For the administration and maintenance of databases storing personal data.
    2. We are entitled to use your personal data in these ways because:
      1. We need to do so in order to perform our contractual obligations with you;
      2. We have obtained your consent;
      3. We have legal and regulatory obligations that we have to discharge;
      4. We need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or
      5. The use of your personal data as described is necessary for our legitimate business interests, such as:
        • allowing us to effectively and efficiently manage and administer the operation of our business;
        • conducting market research or business analysis;
        • maintaining compliance with internal policies and procedures; and
        • promoting our business.
  4. Disclosure of your personal data to third parties

    1. We may disclose your personal data to our affiliates in the circumstances described below:
      1. In the provision of services and for the management and administration of our business. Data relating to Know Your Customer (KYC) checks and to perform Anti-money laundering (AML) checks.
    2. We may share your personal data with third parties for the following purposes:
      1. Service providers: We share your personal data with third party agents and contractors for the purposes of providing services to us (for example, accountants, professional advisors, IT and communications providers). These third parties will be subject to appropriate data protection obligations and they will only use your personal data as described in this privacy policy;
    3. Business partners: For example, this could include asset managers or other business intermediaries;
    4. Legal process, safety and terms enforcement: We may disclose your personal data to the extent required by law, for example if we are under a duty to disclose your personal data to any legal or government regulatory authorities in response to their requests for such information or to assist in investigations. We may also disclose your personal data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect you or us, or to enforce our legal rights or contractual commitments that you have made; and
    5. Business transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.
  5. Transfer of personal data outside the European Economic Area

    1. The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers.
    2. Where we transfer your personal data from a country within the EEA to another country outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. In relation to personal data being transferred outside of the EEA, for example, this may be done in one of the following ways:
      1. the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for personal data;
      2. the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
      3. where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
      4. in other circumstances the law may permit us to otherwise transfer your personal data outside Europe.
    3. In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
    4. You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “How to contact us” section below.
  6. How long we keep your personal data

    1. How long we will hold your personal data for will vary and will be determined by the following criteria:
      1. the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
      2. legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
  7. Your Rights

    1. In all the above cases in which we collect, use or store your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
      1. The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
      2. The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
      3. In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to us;
      4. The right to request that we rectify your personal data if it is inaccurate or incomplete;
      5. The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
      6. The right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request; and
      7. The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
    2. You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
    3. You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.
  8. How to contact us

    1. If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to Olivier Piccoli who is the Data Protection Officer DPO@partners-cap.com