Privacy Policy

In order for us to deliver such financial services and deal with any correspondence that may
arise, we need to collect and process personal information. This makes us a “data controller”.
Apollo Private Wealth on this website will be acting as data controller of your personal
information, jointly with St. James’s Place Wealth Management.

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

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

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

Where you provide personal information to us about other individuals (for example,
members of your family or other dependents) we 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.

This section will apply if you are a prospective client and we 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.

• 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 we 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 dependents.
• Information such as IP address and browsing history obtained through our use of cookies.
  You can find more information about this in our cookies policy in section 7 below.
• Information obtained during telephone recordings.
• Information we may have gather from publicly available sources such as the electoral roll,
  internet search engines and social media sites such as LinkedIn where you have been
  flagged as a PEP and we need to carry out enhanced due diligence.

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

We will collect information directly from you when:

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

We will also collect your personal information from:

• Publically 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

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

We will rely on the following “Lawful Basis” when we process your “personal information”:

• We need to use your personal information to enter into the client agreement, for example,
  we need to use your personal information to assess whether we can provide services to
  you and to set you up as a client on the St. James’s Place client relationship management
  system.
• We have a legal or regulatory obligation to use such personal information. For example,
  our regulators require us to hold certain records of our dealings with you and we are
  required to report to St. James’s Place on our relationship with you.
• We have a valid business reason to use your personal information and which is necessary
  for our 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 our business models and undertake strategic and
  operational business analysis. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

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

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

When we use your “special categories of personal information”, we must have an additional
“lawful basis” and we will rely on the following lawful basis in these circumstances:

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

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

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

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

• 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 we 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 us 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 our use of cookies.
  You can find more information about this in our cookies policy in section 7.
• Your marketing preferences and details of your customer experience with us.
• Information which we 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 we need to carry out enhanced due diligence.

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

We will collect information directly from you when:

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

We 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 us 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 we have appointed to carry out electronic ID checks, sanctions and
  politically exposed persons checking services.

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

We will rely on the following “Lawful Basis” when we process your “personal information”:

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

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

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

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

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

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

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

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

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

• Directly from our client.
• From documents directly provided to us by our client, such as wills or trust documents where you are listed as a dependent or employment related documents and you are listed as a business partner of our 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 us when that IFA was acquired by St. James’s Place group companies.
• St. James’s Place group companies.

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

We will rely on the following “Lawful Basis” when we process your “personal information”:

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

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

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

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

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

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

If you are a business partner such as a products provider, portfolio or fund manager or contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.

• 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 we 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.

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

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

We will rely on the following “Lawful Basis” when we process your “personal information”:

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

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

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

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

• 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 our use of cookies.
  You can find more information about this in our cookies policy in section 7.

We will collect your information directly from our website.

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

We will rely on the following “lawful basis” when we process your “personal information”:

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

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

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

This section will apply if you are a job applicant within the St. James’s Place Partnership.

• We have set out below the main categories of candidate personal information which we
  process in connection with our recruiting activities on a day to day basis:
• personal contact information (including your name, home address, personal telephone
  number(s) and personal e-mail address)
• work history and other relevant experience including information contained in CV, cover
  letter or job application form
• education information including degrees awarded, transcripts and other information
  provided in support of the job application
• remuneration history
• information collected during phone screenings and interviews
• details regarding the type of employment sought, desired salary, willingness to relocate,
  job preferences, and other information related to compensation and benefits
• reference information and information received from background checks (where applicable) including information provided by third parties
• information related to previous applications to us or previous employment history with us
• documents evidencing your right to work (including information about your immigration
  status where relevant)
• date of birth
• gender
• information gathered through our monitoring of our IT systems, building access records
  and CCTV recording in relation to your communications with us and attendance at our
  premises
• personal information which you otherwise voluntarily provide during the course of the
  recruitment process

The majority of the personal information to be provided by you is mandatory in connection
with our recruiting activities. Failure to provide mandatory personal information may affect
our ability to accomplish the purposes stated in this Notice, including considering your
suitability for employment and/or entering into an employment contract with you.

The list set out above is not exhaustive, and there may be other personal information
which St. James’s Place collects, stores and uses in the context of the application and
recruitment process. St. James’s Place will update this Notice from time to time to reflect
any notable changes in the categories of personal information which it processes.

The majority of the personal information which we process will be collected directly from
you. However, your personal information may also be provided to us by third parties, such
as recruitment agencies, former employers, official bodies (such as regulators or the
Disclosure and Barring Service) and/or medical professionals.

As part of our referencing and vetting procedures, we will contact certain third parties in
order to verify your personal information (including personal information that you provide
as part of the application and recruitment process). These third parties will include:

• former employers, in order to verify your previous employment history
• universities and/or other establishments for higher education that you attended, in order
  to verify your education history
• for specific roles we will undertake electronic ID checks, sanctions and politically exposed
  persons checks via a third-party agency

We will also gather data from publicly available sources such as the electoral roll, court
judgments, insolvency registers, internet search engines and social media sites.

We will only conduct background checking in relation to successful candidates that have
accepted a conditional offer of employment with us, and we will specifically inform such
candidates that we will be contacting these third parties in advance of doing so.

St. James’s Place uses your personal information for a variety of purposes to take steps
necessary to enter into an employment contract with you, to comply with legal obligations or
otherwise in pursuit of its legitimate business interests. We have set out below the main
purposes for which candidate personal information is processed:

• To identify and evaluate job applicants, including assessing skills, qualifications and
  experience
• Verifying candidate information and carrying out employment, background
  (including criminal records) and reference checks, where applicable, and in order to
  prevent fraud
• Communicating with you about the recruitment process and your application
• To comply with our legal, regulatory, or other corporate governance requirements

In addition to using your personal information to consider you for the role you applied for, we
will retain and process your personal information for six months to inform you about, and to
consider you for other roles that may be appropriate for you. If you do not want us to
consider you for other roles which we consider may be appropriate for you, please inform
your recruitment contact.

Again, this list is not exhaustive and St. James’s Place may undertake additional processing
of personal information in line with the purposes set out above. St. James’s Place will update
this Notice from time to time to reflect any notable changes in the purposes for which its
processes your personal information.

St. James’s Place will share candidate personal information with other parties only in limited
circumstances where this is necessary for the purposes of entering into an employment
contract, to comply with a legal obligation, or otherwise in pursuit of its legitimate business
interests as follows:

• recruitment agencies
• background vetting specialists
• occupational health providers and other medical professionals
• HMRC and/or any other applicable government body
• accountants, lawyers and other professional advisers
• The Financial Conduct Authority and/or the Prudential Regulatory Authority and/or
  any other applicable regulatory body
• specialists undertaking psychometric & personality tests

Personal information is shared under the terms of a written agreement between St. James’s
Place and the third party which includes appropriate security measures to protect the
personal information in line with this Notice and our obligations. The third parties are
permitted to use the personal information only for the purposes which we have identified,
and not for their own purposes, and they are not permitted to further share the data without
our express permission.

Certain categories of data are considered “special categories of personal information” and
are subject to additional safeguards. St. James’s Place limits the special categories of
personal information which it processes as follows:

Health Information

We may process information about a candidate’s physical or mental health in the course of
the recruitment process. In particular:

• We will process information about an individual candidate’s physical or mental health
  to comply with our obligations to make reasonable adjustments for disabled
  employees as part of the recruitment process;
• as part of our pre-employment screening, successful candidates are asked to
  complete a medical questionnaire administered by Health Assured Ltd in order that
  we can take account of any medical issues relating to a new employee, including our
  obligation to make reasonable adjustments in the workplace. Health Assured Ltd will
  only share information from this questionnaire with us with your express consent.

We will always treat information about health as confidential and it will only be shared
internally where there is a specific and valid purpose to do so. We have implemented
appropriate physical, technical, and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration,
or disclosure.

If a candidate is successful, any health information processed as part of the recruitment
process that is relevant to St. James’s Place’s compliance with its obligations in connection
with employment will be retained and processed in accordance with the Employee Privacy
Notice. If a candidate is unsuccessful, any health information obtained as part of recruitment
process will be deleted with the rest of the candidate’s personal information six within
months of their rejection.

St. James’s Place’s policy is to retain personal information only for as long as needed to fulfil
the purpose(s) for which it was collected, or otherwise as required under applicable laws
and regulations. Under some circumstances we may anonymise your personal information
so that it can no longer be associated with you. We reserve the right to retain and use such
anonymous data for any legitimate business purpose without further notice to you.

For unsuccessful candidates:

• We will retain personal information collected during the recruitment process for a
  maximum period of 6 months from the end of the process subject to any
  exceptional circumstances and/or to comply with particular laws or regulations.

If you are offered and accept employment with us, some of the personal information we
collected during the application and recruitment process will become part of your
employment record and we may use it in connection with your employment in accordance
with the Employee Privacy Notice. The remaining data will be stored for a period of 6 months
then deleted.

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

1. Where you are a prospective client
   Where we have obtained your personal information from LinkedIn searches, we will connect
   with you as per the terms and conditions of the LinkedIn social network. Approaching you
   through LinkedIn, we will provide information about our wealth management services that we
   offer which you might be interested in. We may inform you that we wish to contact you via telephone to discuss our service offerings further, at which point you will be able to notify us that you do not wish to receive such a call. Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you. We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so. We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this.
2. Where you are an existing client
   We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so. We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have consented to receive this.
3. 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 us when we call you. Otherwise you can always contact us using the details set out in section 12 to update your contact preferences. Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.

We 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 our 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, we are regulated by the Financial Conduct Authority (the FCA) who
imposes certain record-keeping rules which we 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 11.

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

• entering into data transfer contracts and using specific contractual provisions that have
  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-outsideeu/model-contracts-transfer-personal-data-third-countries_en;
• we 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-outsideeu/adequacy-protection-personal-data-non-eu-countries_en

We 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 we have with you.

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

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

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

If we become aware that a personal data breach has occurred and is likely to result in a
high risk to the rights and freedoms of our clients, Partners or employees, we will inform them
without undue delay.

We have a dedicated group, the ‘Information Security Oversight Committee’, that provides
oversight and guidance to our information security and privacy programme.

The executive body responsible for privacy and data security is the Information Security
Oversight Committee (ISOC) – chaired by the Data Protection Officer. ISOC has a reporting
line that enables effective escalation of issues up to the Board where appropriate.

We educate and train our employees, Partners and contractors on their information security,
fraud prevention and privacy obligations annually.

Our 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 our 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 our new
employee induction program.

We also educate our employees in identifying potential financial crime and internal fraud;
any suspicious activity is reported to our Financial Crime Prevention team.

When you login, or send us information on the internet we 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 us, all electronic
information exchanged is encrypted using 2048bit SSL (Secure Sockets Layer) certificate. You
can identify this by looking for the HTTPS:// and the padlock in the address bar at the top of
your browser.

We will always interact with you in a safe, secure and consistent manner.

To keep your information secure and to protect our 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 email the St. James’s Place Data Protection Office at dpo@sjp.co.uk.

When interacting with you, we will:

• Only send funds that you have requested to be withdrawn to a verified bank account
  in your name.
• Verify who you are when speaking to you on the phone, by asking you security
  questions.

We will not:

• Ask you for your password over the phone.
• Send you an unsolicited email with a link to our 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 us back immediately to
  discuss the problem further.

We continually review our 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 our
systems where we store and use personal 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.

We conduct security testing of our applications and services in a controlled testing
environment before they are made available for our clients to use on an ongoing basis.
We perform security risk assessments for each of our sites to identify and control risks.
External technical assessments are conducted by an independent external 3rd party.
Security audits and vendor due diligence are conducted on a continual basis.

We have a business resiliency plan with 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 our products and
  services to our clients.
• To provide a recovery plan that supports a timely and full restoration of our products
  and services for our clients.

However, whilst we take appropriate technical and organisational measures to safeguard
your Personal Information, please note that we cannot guarantee the security of any data
that you transfer over the internet to us.

The St. James’s Place website uses cookies – small text files that are stored on your computer
or in your browser – to help us to monitor how visitors use our site and allow us 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 our visitors collectively, for example the number of visits the website
receives. In order to respect our 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 our site. You can find out more about deleting or
controlling cookies by visiting About Cookies.

Facebook advertising
We use the “Custom Audience pixel” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025,
USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal
Harbour, Dublin 2, Ireland (“Facebook”)) on our website. This allows us to track what users do
after they see or click on our Facebook advertisements. This enables us to monitor the
effectiveness of Facebook ads for purposes of statistics and market research. Data collected
in this way is anonymous to us, which means we cannot see the personal data of individual
users. However, this data is saved and processed by Facebook. Facebook can connect this
data with your Facebook account and use it for its own advertising purposes, in accordance
with Facebook’s Data Policy which can be found here
https://www.facebook.com/about/privacy/. We also utilise Facebook Custom Audiences.
Facebook Custom Audience is a remarketing and behavioural targeting service provided by
Facebook, Inc. that connects the activity of this Website with the Facebook advertising
network. You can allow Facebook and its partners to place ads on and outside of Facebook. A
cookie can also be saved on your device for these purposes.
Please click here if you would like to withdraw your consent
https://www.facebook.com/settings/?tab=ads#=
Facebook adhere to the Self-Regulatory Principles for Online Behavioural Advertising and
participate in the opt-out programmes established by the Digital Advertising Alliance,
the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising
Alliance. You can opt out of all participating companies through these sites.

Google Ads
We use the Google Ads remarketing service to advertise on third party websites (including
Google) to previous visitors to our site. It could mean that we advertise to previous visitors
who haven’t completed a task on our site, for example using the contact form to make an
enquiry. This could be in the form of an advertisement on the Google search results page, or
a site in the Google Display Network. Third-party vendors, including Google, use cookies to
serve ads based on someone’s past visits to the sjp.co.uk website. Of course, any data
collected will be used in accordance with our own privacy policy and Google’s privacy
policy. To opt out of Google’s use of cookies or device identifiers visit Google’s Ads Settings.
To opt out of third-party vendor’s use of cookies visit the Network Advertising Initiative optout page or control the use of device identifiers by using your device’s settings.

We use Hotjar in order to better understand our users’ needs and to optimize this service and
experience. Hotjar is a technology service that helps us better understand our users
experience (e.g. how much time they spend on which pages, which links they choose to click,
what users do and don’t like, etc.) and this enables us to build and maintain our service with
user feedback. Hotjar uses cookies and other technologies to collect data on our users’
behaviour and their devices (in particular device’s IP address (captured and stored only in
anonymized form), device screen size, device type (unique device identifiers), browser
information, geographic location (country only), preferred language used to display our
website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we
will ever use this information to identify individual users or to match it with further data on an
individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of
our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

View St. James’s Place full Cookie policy: https://www.sjp.co.uk/site-services/cookies

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, we 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 our 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.

We will only collect personal information about you if you send us an e-mail enquiry via the
‘contact us’ 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 online ‘contact us’ form or complete the
registration details. The type of information being collected for an enquiry will be apparent
from the layout of the ‘contact us’ 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.

We take all reasonable precautions to protect our visitors’ information, both on and off line. If
your personal information changes, please let us know and we will correct, update or
remove any information that we hold about you on our active databases. We 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 us 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

Please note that if you communicate with us electronically, including by e-mail, telephone or
fax, this communication may be randomly monitored and/or recorded to protect the
interests of our business and our 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 our customer relations practices).

We may provide hyperlinks from this web site (‘the Site’) to web sites 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 liable for the contents of linked web sites or any
transactions carried out with organisations operating those websites.

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

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

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

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

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

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

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

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

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

Where we rely on your consent to process your personal information, you have the right to
withdraw such consent to further use of your personal information.

You are entitled to request your personal information to be deleted in certain circumstances
such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own
regulatory obligation, to assess whether we can comply with your request.

You have a choice about whether or not you wish to receive marketing information from us
and you have the right to request that we stop sending you marketing messages at any
time. You can do this either by clicking on the “unsubscribe” button in any email that we
send to you or by contacting us using the details set out in section 8.

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

In certain circumstances, where we only process your personal data because we have a
legitimate business need to do so, you have the right to object to our processing of your
personal data.

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

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

We do not carry out any automated decision making to provide products and services to
you.

If you believe that we 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.

If you would like any further information about any of the matters in this notice or if you have
any other questions about how we collect, store or use your personal information, you may
contact our St. James’s Place Data Protection Officer at St. James’s Place plc, St. James’s
Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom,
dpo@sjp.co.uk and 01285718453.

From time to time we may need to make changes to this notice, for example, as the result of
changes to law, technologies, or other developments. We will provide you with the most up
to date notice.

This notice was last updated on (13/02/23)