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 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
How long do we keep your personal information for?
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 12.
What is our approach to sending information overseas?
There may be some 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 has 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-outside-eu/model-contracts-transfer-personal-data-third-countries_en;
- transferring personal information only to companies in the United States who are certified under the “Privacy Shield”. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome or
- 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-outside-eu/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:
- Country of transfer: China, Hong Kong and Singapore
- Reason for the transfer: Provision of data to international offices to support clients living overseas.
- Method we use to protect your information: We have standard contractual clauses in place
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.
How do we protect your personal information?
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.
- We have a dedicated group, the “Information Security Oversight Committee”, that provides oversight and guidance to our information security and privacy programme.
- We educate and train our employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.
- 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).
- We will always interact with you in a safe, secure and consistent manner.
- We continually review our physical and logical security controls in place across the business.
- We conduct security testing of our applications and services in a controlled testing environment before they are made available for our Clients to use.
- We have a business resiliency plan with a disaster recovery and business continuity testing.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
Cookies
The St. James’s Place website and content provided by Asset.tv 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 aboutcookies.org.
Google Analytics
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 on line ‘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.
Monitoring
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).
Hyperlinks
We may provide hyperlinks from this website (‘the Site’) to websites 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 be liable for the contents of linked websites or any transactions carried out with organisations operating those websites.
Your rights
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 of course inform you if any of the above situations arise and if we are unable to comply with your request.
- The right to access your personal information:
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 you 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.
- The right to rectification
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.
- The right to restriction of processing
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.
- The right to withdraw your consent
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.
- The right to object to direct marketing
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 12.
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.
- The right to data portability
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
- Rights relating to automated decision-making
St. James’s Place do not rely on automated decision making to provide products and services to you.
- The right to make a complaint with the ICO
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.
Contacting us
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 the St. James’s Place Data Protection Officer at St. James’s Place Wealth Management Group plc, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, [email protected] and 0800 0138 137.
Updates to this notice
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.
This notice was last updated in 2021.