Privacy notice

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 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 at 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 an employee or employees of one of our Stonehage Fleming Group (“Group”) companies;
• When you communicate with us or when 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;
• Information contained within a subscription application form or client on-boarding document relating to the service you wish to receive;
• From other companies in our Group;
• From your agents or advisers;
• 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, date of birth, passport or national identity card details;
• Country of birth, domicile and citizenship;
• Gender and marital status;
• Contact information such as residential or business address, email address and telephone number;
• Information relating to your tax affairs, including your tax status and tax identification number;
• Information about your employment, education, family, personal circumstances, and interests;
• Information about your knowledge and experience in the investment field;
• An understanding of your goals and objectives in connection with your wealth;
• 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, 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 because it is necessary for the performance of a contract to deliver the services you have engaged us for 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 preliminary information or a proposal for you regarding the services we offer;
• To provide you with dealing, treasury and other related services as 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:

• Brokers, custodians of your assets, banks and third party administrators who we may engage to assist in delivering the services to you;
• Your agents, trustees, advisers, intermediaries, fund and investment managers or employees of firms with which you are associated;
• Our advisers where it is necessary for us to obtain their advice or assistance;
• Companies within our Group;
• Payment processors where we are making payments on your behalf;
• 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:

• 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;
• External service providers we are using to provide you with the service you require;
• Regulatory authorities outside of the United Kingdom, where we are required to do so to meet our compliance obligations.

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;
• Any regulatory authority or service provider.

If we rely on our legitimate interest for using your personal information, we will undertake a balancing test to ensure that our legitimate interest is not outweighed by your personal interest 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 and countering terrorist financing regulations, tax reporting and beneficial ownership reporting requirements.

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 service providers who we may engage to assist in delivering the services to you, where they conduct reviews in accordance with their statutory obligations, including, but not limited to, anti-money laundering and countering terrorist financing;
• With third parties who assist us in conducting background checks about you, such as whether you are on sanctions lists;
• With relevant regulators, tax authorities and 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 Switzerland, Jersey, Israel, Liechtenstein, Luxembourg, Guernsey, Malta, Isle of Man or Canada which are countries which provide 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, South Africa, Monaco and Mauritius which currently do not provide the same level of protection to your personal data as provided within the United Kingdom. We will use Standard Contractual Clauses, as a safeguard, when making transfers to these countries or will do so with your explicit consent.

We may also share your personal data with other companies or service providers that we have engaged to assist us in providing services to you. These companies or service providers may be located in jurisdictions, such as the United States of America, which do not provide the same level of protection to your personal data as provided within the United Kingdom. Where we share your personal data with a company or service provider in a non-adequate jurisdiction we will do this using either Standard Contractual Clauses, another available safeguard or with your explicit consent.

If you wish to receive details regarding all of the companies or service providers which we have engaged to assist in delivering services to you or 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 will retain your personal data for a period of 7 years after the termination of our relationship with you in order to meet our regulatory and legal obligations. Please note that we may retain your personal data for a longer period where necessary to protect against legal claims. Where we have collected client due diligence data as required by anti-money laundering (AML) regulations, we will retain that AML related personal data for five years after the termination of our relationship.

Version: 20 December 2023