Privacy Policy

Certain parts of the website may ask for some personal details. However, any information gathered will be used solely by us for marketing purposes, to keep you informed of the services we provide, and/or to evaluate the use of the web site.

Your details will not be passed to any other company. We may process and hold your data in both manual and electronic form. You are free to unsubscribe from our services at any time. Should you wish to ask about the information we hold concerning you, you are invited to contact us at our registered address.

Please be aware our telephone lines may be recorded and monitored.

GDPR Statement.

The personal data we collect and our legal basis for processing 

When you sign up for our services we will obtain personal data from you, including:

  • Basic information including your name, address, age, sex, occupation and marital status. • Information on your investment experience, income level and portfolio size, and attitude to risk. • Contact details including email address and telephone number. • Copies of identity, (such as a scan of your passport or driver’s license) plus any supporting documents to provide proof or clarification of any information relating to you or your account.

We use this data in order to enter into a services contract with you, to assess your suitability and risk appetite (if you are signing up for an advisory or asset management service), and to comply with our legal and regulatory obligations, such as the FCA’s Handbook rules and the Money Laundering Regulations 2017. 

All the personal data we obtain will be collected and processed in accordance with one of the below lawful bases for processing:

  • The performance of a contract (your basic information, contact details, and information on investment experience, portfolio size, and objectives) • Compliance with our legal obligations (identity and address proofs as well as any other information obtained for Anti Money Laundering Know Your Customer (AML/KYC) purposes or other legal obligations we are subject to) • Our legitimate interests (see below) • Your consent (in certain circumstances, please see below)

 Our legitimate interests 

In some circumstances we may rely on our legitimate interests for processing your personal data and sharing this with third parties (for more on who we share data with on this basis, see below). 

Our “legitimate interests” in this context can be defined as a general commercial interest in providing a broad range of services to our clients and growing our core client base by way of marketing activity. 

Who will use the personal data we collect 

All electronic copies of the personal data we collect will be held securely, in encrypted format, on secure servers. All physical copies will be kept in locked filing cabinets within our principle place of business. 

We may share your data with our legal advisors in circumstances where there is contemplation of any relevant litigation or legal action. 

If necessary we will also pass your data on to the execution platforms and custodians we use in order to set up your account and provide the necessary services to you.

Transfers to third-party countries and safeguards 

The personal data we hold will never be transferred outside the EU for any reason. If this changes, we will reflect this in an updated Privacy Notice. 

Consent 

We will never assume that you have given us consent unless you explicitly do so, and you may withdraw your consent at any time by contacting us. 

Your rights 

You have various rights in relation to the personal data we collect, including the “right to portability” and the “right to erasure” (otherwise known as the right to be forgotten). We will comply with these requests if we are legally obliged to do so, and your rights change depending on the legal basis upon which we are processing your information (see this ICO guidance for more information). Should you wish to assert any of these rights, please get in touch with us using the contact details provided above. 

Please note that you cannot request the erasure of the AML/KYC information we hold as we must retain this information under UK law. 

How long we will keep your data for 

We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary to comply with the FCA’s record keeping rules and retention periods mandated by the Money Laundering Regulations 2017, as well as any other relevant legislation. 

What happens if you don’t provide us with the personal data we need 

As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations. 

Should you refuse to provide us with this data or make a request for erasure, it is likely that we will be unable to continue with our client onboarding process, or would have to terminate our existing contractual relationship. 

Should you refuse to provide or update us with the data we need to comply with our legal obligations, such as AML/KYC information, we will be unable to open an account or continue an existing business relationship with you.

Complaints 

If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided above. 

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage:

www.ico.org.uk

TJM complies with the General Data Protection Regulation (GDPR) and before 25 May 2018 with the Data Protection Act 1998 (reference no. Z3406362).

 

 

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Issued by The TJM Partnership PLC which is authorised and regulated by the Financial Conduct Authority. FCA No. 498199.