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Privacy notice

This Privacy Notice explains how Stonehage Fleming Charitable Foundation (“the Charity”) collects, uses, and

discloses your personal data, and your rights in relation to the personal data it holds.

In this Privacy Notice, “us”, “we” and “our” refers to the Charity.

The Charity is the data controller of your personal data and is subject to the Data Protection Act 2018 and to

the United Kingdom General Data Protection Regulation. Our Data Protection Officer is Mr. Cesare Milani.

His contact details are: email - ukdataprotectionofficer@stonehagefleming.com - tel. +44 20 7087 0136.

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your

personal data. This Privacy Notice supersedes any previous version of this notice with which you may have

been provided, or had sight of, before the date stated below.

You have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us not to send you marketing communications;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights under data protection legislation at www.ico.org.uk

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the following:

By post - 15 Suffolk Street, London, SW1Y 4HG

By email - ukdataprotectionofficer@stonehagefleming.com

By telephone - +44 20 7087 0136

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner (www.ico.org.uk).

We may collect your personal data in a number of ways, for example:

  • From the information you provide to us when you meet with us or with an employee of one of our Stonehage Fleming Group companies;
  • When you communicate with us or we communicate with you by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • From other companies in our Group;
  • From the trustee(s) of any trust in respect of which you are a settlor or a beneficiary or are otherwise connected;
  • From your agents, advisers or representatives.

We may collect the following categories of personal data about you:

  • Your name and contact information such as address, email address and telephone number;
  • Information relating to your financial situation such as your bank account details;
  • Information relating to your tax status and tax identification number;
  • Information about you and your donation;
  • Information relating to your marketing segment and the services which our Group companies offer, which may be of interest to you.

The legal basis for our processing of your personal data is based on you making a donation to the Charity.

In this respect, we use your personal data for the following:

  • To process and administer your donation and update our records;
  • To deal with any feedback or complaints you may have;
  • For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with the following:

  • Companies or Trusts within our Group;
  • Your advisers, agents or representatives;
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our data storage providers.

We may also process your personal data because it is necessary for our legitimate interests.

In this respect, we may use your personal data for the following:

  • For the administration and management of the Charity;
  • To train our staff or monitor their performance;
  • To seek advice and guidance on our rights and obligations, such as where we require our own legal advice;
  • To mitigate the risks we face.

In this respect, we may share your personal data with the following:

  • Our advisers, agents, settlors or protectors of trusts where it is necessary for us to obtain their advice or assistance.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection.

We may also process your data for our compliance with a legal obligation which we are under.

In this respect, we may use your personal data for the following:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering, tax and beneficial ownership laws.

In this respect, we may share your personal data with the following:

  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With relevant regulators or law enforcement agencies, where we are required to do so.

In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies located in the European Economic Area as well as Switzerland, Israel, or Jersey, which are countries which provide the same or a similarly adequate level of protection for your personal data as provided within the United Kingdom. We may also share your personal data with Group companies located in South Africa which do not have laws which provide the same level of protection to your personal data as provided within the United Kingdom. However, these companies are subject to our contractual data sharing arrangements which offer a common level of protection across the Group.

If you wish to receive details regarding the Group companies with which we have shared your information, please contact us at: ukdataprotectionofficer@stonehagefleming.com

We retain your personal data for a period of seven years after your last donation, unless we are required to retain this information for a longer period by another law or for the purposes of court proceedings.

Date: 28 January 2021