Privacy Policy

 

1.      INTRODUCTION AND WHO WE ARE

 

Strathmore Wealth Partners Limited (“Strathmore”, the “company”, “we”, “us”) is a limited company registered in England and Wales with company number 12918613).  The registered office is at 7 Bell Yard, London WC2A 2JR.

 

During the course of business and providing advisory services to you, Strathmore may collect, use, store and is responsible for certain personal information and data. Strathmore is known as a ‘data controller’ and is regulated under GDPR by the Information Commissioner.

 

Please read this Privacy Policy carefully to understand why data is being collected and what we do with that data once in our possession. We may change this privacy policy from time to time by amending this page. Further information about data privacy may be found in any engagement letter that may be agreed between us and you.

 

2.      WHAT PERSONAL DATA WE NEED

 

"Personal data" in this Privacy Policy has the same meaning as in the EU General Data Protection Regulation 2016/679/EU (GDPR). Essentially, it means information which is connected to a living individual who can be identified from that information, either by itself or when combined with other data likely to come into our possession. Personal data can include information collected by certain cookies or tracking technologies (see below) if it builds up a profile of you.

 

If you are under the age of 18 you should not send us any personal data, including your email address.

 

The type of personal data we will request from you will depend on what you have asked us to do and the type of work we undertake. This personal data may include

 

(a)     personal data including your address, date of birth, contact information (telephone and email) and financial information.

 

(b)     identity information and documentation.

 

(c)     information regarding past engagement with us including information obtained in previous matters where we were engaged by you

 

(d)     additional information in relation to your engagement to enable us to advise you and progress your matter

 

(e)     details of visits to our website

 

Where our client is a company, we will nevertheless require the personal data described above in relation to personnel, including but not necessarily limited to directors of the company (including  but not necessarily limited to any director tasked with instructing us) and the ultimate beneficial owner or owners of that company.  We will assess the exact information required when you instruct us and advise you in detail what we require.

 

Where necessary to act in your best interests, and for the establishment, exercise, or defence of the matter in which we may be instructed or retained, we may need to process information which is very sensitive in nature such as diversity and health related details. In some circumstances we may need to share this information with third parties, for example barristers third party firms that we may be working with in the furtherance of your matter. If you volunteer sensitive personal data, you will be allowing us to process it as part of engaging our services.

 

Please note that that we use may use services such as Google Analytics on our website and further details on the type of information collected can be obtained from https://analytics.withgoogle.com/.  We will record data collected in this way automatically if you use our website, regardless of whether you become a client of the company or not. Our website may also collect “cookies” from your browser for purposes of analysing how our website is being accessed and used, and to provide enhanced functionality on our website.  This information may be disseminated to third party providers.  You may refuse our collection and use of cookies through selection of the appropriate settings on your browser. Should our website include links to other sites operated by third parties, please note that we are not responsible for information on these sites, nor for services or products offered by them. Use of such sites, including transmitting your personal data to them, is at your own risk. You should check the privacy policies (and other applicable terms and conditions) of these third-party sites.

 

3.      WHY WE NEED IT

 

In the majority of cases personal data will be restricted to basic information and information needed to complete ID checks. We may also use personal information to provide advisory services to you.

 

We shall also use and disclose personal information so far as required to carry out your instructions.

 

We may use your information for:

 

(a)     verifying your identity

 

(b)     verifying source of funds

 

(c)     to establish funding of your matter or transaction

 

(d)     communicating with you

 

(e)     processing your transaction including:

 

-         providing you with advice and dealing with your enquiries and requests

 

-         preparing documents or to complete transactions

 

-         carrying out obligations arising from any contract entered into between you and third parties on your behalf or to provide services connected to those obligations

 

-         attending meetings on your behalf

 

(f)      keeping financial records of your transactions and the transactions we make on your behalf

 

(g)     seeking advice from third parties;

 

(h)     obtaining insurance policies on your behalf

 

(i)      to carry out appropriate anti-fraud checks (by conducting online searches using a third-party identity provider).

 

(j)      responding to any complaint or allegation of negligence against us

 

(k)     to process payments

 

(l)      to comply with legal and regulatory requirements

 

(m)   to carry out marketing activities

 

Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services

 

4.      HOW WE COLLECT YOUR DATA

 

You are responsible for ensuring the accuracy of all the personal data that you provide to us, and we will not be held liable for any errors unless you have advised us previously of any changes in your personal data. We will only take instructions from you or someone you authorise in writing. Where you are acting as an agent or trustee, you agree to advise your principal or beneficial owner of the trust that their personal information will be dealt in accordance with this policy. Information may be passed to us by third parties in the course of providing our services. The processing of this information will be necessary for the progression of your matter and to enable us to act in your best interests.

 

In commercial matters, we will hold and use personal data about you, your officers and/or your employees in the course of providing our services to you.  When you provide personal data to us relating to your officers or employees, you confirm that you are allowed to do so. You should ensure that those individuals understand how their data will be used by us. In personal matters you may be providing other third party data to us, for example details about your family members, in which case we will use such data as a data controller in our own right and will comply with data protection legislation in relation to use of that data.  You must have, and by using our services you represent to us that you do have, the authority to disclose personal data if it relates to someone else and all data disclosed should be complete, accurate and up to date.

 

5.      ON WHAT BASIS DO WE COLLECT AND PROCESS YOUR DATA?

 

The legal grounds for processing personal data you provide to us are as follows:

 

(a)     it is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you. The engagement letter between you and Strathmore sets out the terms of the contract and the services we will provide;

 

(b)     it is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you;

 

(c)     it is necessary in order to comply with mandatory legal obligations to which we are subject under EU or UK law;

 

(d)     we will send information, updates and invitations to events on the basis of the consent that you have provided to us to receive certain communications.

 

6.      WHO HAS ACCESS TO IT

 

Generally, we will only use your information within Strathmore.

 

However there may be circumstances, based upon the services you need, where we may pass your details to selected people or organisations (data processors) to carry out certain activities on our behalf.

 

For example, personal data you provide may be disclosed to our agents, who may keep a record of that information. We may pass your information to any third parties where required to do so in the course of providing our services, or where we are obliged by law.  This will include, but is not limited to:

 

(a)     solicitors, accountants, or other experts acting for you in connection with any matter in which we are retained by you;

 

(b)     organisations involved in any business reorganisation with which we are dealing;

 

(c)     any disclosures to law enforcement agencies where required by law (in particular the prevention of financial crime and terrorism);

 

(d)     our professional indemnity insurer in the event a claim is made against us in order to defend ourselves;

 

(e)     the bank or building society or other lender providing finance in a transaction in which we are retained to provide services.

 

At the outset of your matter we may not be aware of all the other parties involved as this will depend on the specific nature of the work. We will not share your information with third parties for marketing purposes.

 

7.      HOW DO WE PROTECT YOUR DATA

 

We take the security of your data seriously. We use reputable IT service providers and cloud computing services to keep your information secure from loss, misuse or alteration. Where your information is disclosed to third parties, for the purposes of carrying out your instructions and handling your matter, we will ensure that personal data is processed in line with our stringent confidentiality and protection policies. If we have given you a username and password which enables you to access certain parts of your matter on our systems, you are responsible for keeping it confidential. Please do not share it with anyone.

 

There may be occasions where we need to send your data outside the EEA. This would cover situations where we need to deal with international aspects of your matter and instruct overseas organisations to assist. Some organisations may be located in countries outside of Europe where data protection laws are not as strict as they are in the UK. Where your personal data is being transferred outside the EU, we will undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information.

 

8.      HOW LONG WE KEEP YOUR DATA

 

We will only retain your information for as long as is necessary:

 

(a)     to carry out the services we have been retained for.

 

(b)     in the establishment or defence of legal claims (for example negligence claims) that could be made against us.

 

(c)     to comply with legal obligations under EU/UK law.

 

After the required time period your file (paper and electronic) will be destroyed confidentially without further reference to you unless you contact us to request the file at an earlier date.

 

9.      WHAT ARE YOUR RIGHTS

 

Under GDPR you have a number of important rights over your personal data. Further information about these rights can be found on the Information Commissioners website www.ico.org.uk. If you would like to exercise any of these rights please contact us or contact the person dealing with your matter.

 

10.  HOW TO COMPLAIN

 

In the first instance please contact us and we hope to resolve any query or concern you have about our use of your information. If you have not been satisfied with our response then you can lodge a complaint with the supervisory authority, the Information Commissioner Office who can be contacted at www.ico.org.uk/concerns/ or telephone 0303 1231113 10.

 

11.  HOW TO CONTACT US

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Strathmore Wealth Partners Limited

Tel: (+44) 77 3436 3023

Email: familyoffice@strathmorewealthpartners.com