Click here for information on how Stonehage Fleming is responding to the COVID-19 epidemic

Privacy notice

This Privacy Notice explains how Stonehage Fleming Advisory Limited (“the Company”) 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 Company.

The Company is the data controller of your personal data and is subject to the Data Protection Act 2018 and the United Kingdom General Data Protection Regulation. Our Data Protection Officer (DPO) is Mr. Cesare Milani. His contact details are: email - ukdataprotectionofficer@stonehagefleming.com tel. +44 207 087 0136.

Our appointed representative in the European Union is Sturdon Holdings Luxembourg SARL. Our Data Privacy Officer in Luxembourg is Mr. Peter Egan. His contact details are: email - luxprivacyofficer@stonehagefleming.com tel. +352 2744 7303.

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 you may have received, or had sight of, before the date stated above, as well as anything to the contrary contained in any agreement with us.

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.

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).

Depending on the nature of the relationship we have with you, we may collect your personal data in a number of ways, for example:

  • From the information you provide to us when you meet with one of our employees;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you complete, or we complete on your behalf, a client classification self-certification form;
  • From other companies in the Stonehage Fleming Group;
  • From intermediaries, your agents, advisers and from individuals in the organisations with which you are associated;
  • From publicly available sources, or from third parties, where we need to conduct background checks about you.

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

  • Your name and contact information such as address, email address and telephone number, as well as your date of birth, tax identification number and your passport number or national identity card details, country of domicile and your nationality;
  • Information about your knowledge and experience in the corporate field, and the investment field (where relevant for direct investments);
  • Information relating to you and your financial situation such as your industry and marketing segment, the services we offer which may be of interest, your net worth, income, expenditure, assets and liabilities, sources of wealth and your bank account details;
  • Information about your employment, education, family or personal circumstances, and interests;
  • Information, some of which is collected daily, to assess whether you may represent a money laundering, terrorist financing or reputational risk to the Group. This includes whether you are a Politically Exposed Person, are involved in a high risk business, have been arrested, charged or convicted of a crime, are on a sanctions list or expose us to tax, litigation, bribery or corruption risk.

We may process your personal data without your specific consent because it is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract.

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

  • To prepare a proposal for you or for a company with which you are associated regarding the services we offer;
  • To provide you with corporate finance and/or direct investment opportunities or as otherwise agreed with you from time to time;
  • To deal with any complaints or feedback 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:

  • Your advisers, agents and intermediaries;
  • Potential counterparties and their advisers in relation to our corporate finance or direct investment opportunity services;
  • Companies or Trusts within our Group;
  • 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:

  • Determine if you may be interested in investment opportunities and to inform you of these opportunities;
  • To run, grow and develop our business;
  • To ensure a safe environment for our employees and visitors, including website visitors;
  • To provide client services;
  • To conduct market research and carry out business development activities;
  • To train our staff or monitor their performance;
  • For the administration and management of our business including carrying out internal group administrative functions and recovering money you owe to us;
  • 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;
  • With third parties and their advisers where those third parties are acquiring, or considering acquiring all or part of our business.

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 laws, and where we are required to monitor, record or store telephone conversations.

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

  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks;
  • 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, Jersey or Canada, which are countries which are viewed as providing the same or a similarly adequate level of protection for your personal data as is provided within the United Kingdom. We may also share your personal data with Group companies located in the United States of America and South Africa which do not provide the same level of protection to your personal data as provided within the United Kingdom. However, these companies are subject to our Group-wide data sharing arrangements that offer a common level of protection across the Group.

If you wish to receive details regarding all of the companies within the Group which we have engaged to assist in delivering services to entities in respect of which you are connected or have an interest and with whom we have shared your information please contact us at: ukdataprotectionofficer@stonehagefleming.com

We retain your personal data for a period of seven years after the termination of our relationship with you in case any claims arise out of the provision of our services to you. However, where we have collected client due diligence information and documentation as required by anti-money laundering legislation, we retain your personal data for five years after the termination of our relationship, unless we are required to retain this information for a longer period by another law or for the purposes of court or other legal proceedings.

Version: January 2021