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 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).

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 from an employee or employees of one of our Stonehage Fleming Group companies or from a family member.
• 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, client on-boarding, application or other forms.
• 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 with which you are otherwise connected.
• From your agents, advisers, intermediaries, insurance companies, fund managers, investment managers and custodians of your assets.
• 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, your passport number or national identity card details, country of domicile and your nationality.
• Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details.
• Information relating to your tax affairs including your tax status and tax identification number.
• Information about your knowledge and experience in the investment field.
• An understanding of your goals and objectives in connection with your wealth.
• Information about your employment, education, family or personal circumstances, and interests.
• Information relating to your industry, marketing segment and the services we offer which may be of interest to you.
• 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.
• Information concerning your health, where you have consented and this is relevant to the services we provide to you.

Where We Process Your Data Other Than With Your Consent

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 regarding the services we offer;
• To provide you with the services as set out in our Client Agreement with you 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, intermediaries, insurance companies, banks, fund managers, investment managers and custodians;
• Third party administrators who we may engage to assist in delivering the services to you;
• Our advisers where it is necessary for us to obtain their advice or assistance;
• Other third parties such as intermediaries, insurance companies, fund managers or investment managers, custodians & brokers who we introduce to you.
• 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:

• 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, including raising client invoices and recovering money owed 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 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 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 Switzerland, Israel, Jersey, Liechtenstein, Luxembourg, Guernsey, Malta, Isle of Man 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, South Africa, Monaco and Mauritius, which do not provide the same level of protection to your personal data as provided within the United Kingdom. Where applicable, 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 may be located in jurisdictions that currently do not have laws which 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 a contractual data sharing arrangement, another available safeguard or with your explicit consent.

If you wish to receive details regarding all of the companies within the Group or other service providers which we have engaged to assist in delivering services to you and with whom we have shared your information please contact us at ukdataprotectionofficer@stonehagefleming.com

We may 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 personal data as required by anti-money laundering legislation, we may retain your personal data for five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court or other legal proceedings.

• where we have provided advice relating to a pension transfer, pension conversion, pension opt-out or free-standing additional voluntary contribution, we will keep your personal data relevant to this indefinitely as we are required to do so by the Financial Conduct Authority.

Version: 7 March 2024