Privacy Policy

Last updated and effective June 2024

1. About this Privacy Notice

   1. This Privacy Notice sets out how Partners Capital collects and uses personal data about you. Please take the time to read and understand this Privacy Notice.
   2. We use the following definitions in this Privacy Notice:
      1. “we,” “us” or “our” or Partners Capital” means Partners Capital LLP, Partners Capital Investment Group LLP, Partners Capital Europe SAS, Partners Capital Investment Group (Asia) Pte Limited, and Partners Capital Asia Limited;
         and
      2. “personal data” means any data that relates to a living individual who can be identified from that data (either by itself or when it is combined with other data).
   3. We are committed to maintaining the confidentiality, integrity and security of the personal data we collect. Accordingly, we have developed internal policies to protect personal data while allowing our clients’ needs to be met.
   4. For the purposes of data protection law, we are a data controller of your personal data. This means that we are responsible for deciding how we use your personal data and for ensuring that any such use is in compliance with data protection law.
   5. We will let you know if the collection of your personal data is mandatory (for example, if we are required by law to collect it for “Know Your Customer” purposes). If you do not supply your personal data where it is mandatory for us to collect it, we may not be able to provide you with some or all of our services.
   6. If you are a resident of California, please click here for our Notice at Collection.

2. Personal data that we collect about you

   1. We collect and process different types of personal data about you as described below:
      1. Personal data that you provide to us or one of our affiliates. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail, through our website partners-cap.com (the “Site”) or otherwise. Such information may include:
         1. Basic personal data (such as first name, family name, email address, phone number, address, city, postcode and/ or country);
         2. Any information that you choose to share with us (whether through our Site, through populating a Discretionary Management Agreement or otherwise) which may be considered personal data;
            and
         3. Information about your dependants, banking relationships and bank account details, tax information, national insurance number, passport or ID card details, employment details, information about your PEP (Politically Exposed Person) status and source of wealth information.
      2. Personal data that we collect or generate about you. Such information may include:
         1. Information about our business relationship with you and our interactions with you;
         2. When you submit identifiable comments or other content to us, we collect whatever information you supply and use this information to communicate with you if requested, and otherwise fulfil the purpose of the content submission;
            and
         3. Call recordings, data relating to IT usage and risk profile information.
      3. Information we obtain from other sources.
         1. We may collect and store information that is publicly available on websites such as Companies House and from information sources we subscribe to such as Thomson Reuters World Check-One;
            and
         2. We may sometimes collect additional information from third parties including credit reference agencies or other background check agencies.

3. How we use your personal data

   1. Your personal data may be stored and processed by us in the following ways and for the following purposes:
      1. For the management and administration of our business;
      2. Creating, improving and developing our products and services, and the operation of our Site;
      3. Assessing risk profiles, tailoring our product and service offerings to different client needs;
      4. Contacting you about programs, products or services that we believe may be of interest to you, and new product or service announcements or event invitations;
      5. Contacting you to respond to your requests or inquiries and provide user support;
      6. Conducting market research, surveys, and similar inquiries to help us understand trends and user needs across product categories or user groups;
      7. Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorised access to or use of personal data, our Site or data systems;
      8. In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
      9. Investigating and resolving disputes and security issues and enforcing our legal rights;
         and/or
      10. For the administration and maintenance of databases storing personal data.
   2. We are entitled to use your personal data in these ways because:
      1. We need to do so in order to perform our contractual obligations with you;
      2. We have obtained your consent; We have duly notified you of the purposes for which your data is to be used;
      3. We have legal and regulatory obligations that we have to discharge;
      4. We need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
         and/or
      5. The use of your personal data as described is necessary for our legitimate business interests, such as:
         1. allowing us to effectively and efficiently manage and administer the operation of our business;
         2. conducting market research or business analysis;
         3. maintaining compliance with internal policies and procedures;
            and/or
         4. promoting our business.

4. Disclosure of your personal data to third parties

   1. We may disclose your personal data to our affiliates in the circumstances described below:
      1. In the provision of services and for the management and administration of our business. This may include data relating to Know Your Customer (KYC) checks and to perform Anti-money laundering (AML) checks.
   2. We may share your personal data with the following third parties:
      1. Service providers: We share your personal data with third party agents and contractors (for example, accountants, professional advisors, IT and communications providers). These third parties will be subject to appropriate data protection obligations;
      2. Business partners: For example, this could include asset managers or other business intermediaries, and which may include them acting as independent data controllers of your data in which case they will notify you of the purposes for which they will use your information in accordance with applicable law;
      3. Legal process, safety and terms enforcement: We may disclose your personal data to the extent required by law, for example if we are under a duty to disclose your personal data to any legal or government regulatory authorities in response to their requests for such information or to assist in investigations. We may also disclose your personal data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect you or us, or to enforce our legal rights or contractual commitments that you have made;
         and
      4. Business transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.

5. Transfers of personal data (including transfers of personal data outside of the UK and the European Economic Area)

   1. The personal data that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which it was originally collected. It may be processed by us or our suppliers operating in other jurisdictions. Where we transfer your personal data outside of the jurisdiction of original collection, we will ensure that it is protected in a manner that is consistent with how your personal data would be protected by us in the jurisdiction of original collection and in all cases, we will ensure that any transfer of your personal data is compliant with applicable data protection law.
   2. Where we transfer your personal data from the United Kingdom (“UK”) or a country within the European Economic Area (“EEA”) to another country outside the UK or the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK or the EEA (as applicable). In relation to personal data being transferred outside of the UK or the EEA, this may be done in one of the following ways:
      1. the country that we send the data to might be approved by the UK Government or European Commission as offering an adequate level of protection for personal data;
      2. the recipient might have signed up to a contract based on “model contractual clauses” approved by the UK Government or the European Commission, obliging them to protect your personal data;
         or
      3. in other circumstances the law may permit us to otherwise transfer your personal data outside of the UK or EEA.
   3. In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.
   4. You can obtain more details of the protection given to your personal data when it is transferred (including, where relevant, a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “How to contact us” section below.

6. How long we keep your personal data

   1. How long we will hold your personal data for will vary and will be determined by the following criteria:
      1. the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose;
         and
      2. legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

7. Your Rights

   1. In all the above cases in which we collect, use or store your personal data, you may (depending on applicable data protection law) have one or more of the following rights and, in most cases, you can exercise them free of charge or for a nominal fee. These rights may include:
      1. The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
      2. The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
      3. In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to us;
      4. The right to request that we rectify your personal data if it is inaccurate or incomplete;
      5. The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
      6. The right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
         and
      7. The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
   2. We may charge a reasonable fee if permitted under applicable data protection law or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
   3. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
   4. You can exercise your rights by contacting us using the details set out in the “How to contact us” section below.
   5. You can find out more information about your rights by contacting the relevant data protection regulator in your jurisdiction or by searching their website, including the:
      1. Information Commissioner’s Office in the UK (www.ico.org.uk);
         and
      2. Commission Nationale Informatique et Libertés in France (www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles).
   6. If you are a resident of California, you have different rights which are explained here.

8. How to contact us

   1. If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to our Data Protection Officer at DPO@partners-cap.com.

9. California Privacy Notice

   1. This section is provided pursuant to the California Consumer Privacy Act (CCPA) and describes how we collect, use, and disclose personal data about California residents whose relationship with us is not covered by our US Client Privacy Policy, Privacy Notice for California Personnel or Privacy Notice for California Job Applicants.
      1. Personal data that we collect about you We collect and process the following categories of personal data about California residents:
         1. Identifiers and Personal Records such as first name, family name, alias, signature, postal address, telephone number, unique personal identifiers, online identifiers, IP address, email address, account name or log-in, password or credentials allowing access to an account, state issued identification numbers including driver’s license number and Social Security number, passport number or other similar identifiers, insurance policy number, education, employment, employment history, bank account number, financial account or other financial information. This category includes information described in Cal. Civ. Code § 1798.80(e). Some of this information is considered sensitive under the CCPA;
         2. Characteristics of Protected Classes such as your date of birth, marital status, citizenship or immigration status, and gender;
         3. Commercial Information such as your business relationship with us and the products and services that you request from us;
         4. Sensory Information such as photographs, audio, and video information collected when you communicate with us by phone or videoconferencing;
         5. Professional or Employment-Related Information including your employment history and education;
         6. Internet and Other Electronic Network Activity including browsing history, search history, and information regarding interactions with our Site or applications;
         7. Geolocation Data including your physical location inferred from your device IP address; and
         8. Inferences reflecting the preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
      2. Sources from which we collect personal data In general, we collect personal data from the following categories of sources:
         1. Directly from you;
         2. Automatically, for example through cookies, pixels, and other similar technologies in use on our Site;
         3. Created by us, for example, if we provide you with a username or other credentials or inferences we draw from other personal data we collect;
         4.  From service providers that help us to operate our business; and
         5. From third-party sources, including data providers, internet service providers, data analytics vendors, advertising networks, social networks, other financial institutions or advisors, your employer or colleagues.
   2. How we use and disclose personal data  
      1. We typically use and disclose the personal data we collect for the following purposes:
         1. For the management and administration of our business;
         2. Creating, improving and developing our products and services, and the operation of our Site;
         3. Assessing risk profiles, tailoring our product and service offerings to different client needs;
         4. Marketing our products and services, including contacting you about programs, products or services that we believe may be of interest to you, and new product or service announcements or event invitations;
         5. Contacting you to respond to your requests or inquiries and provide user support;
         6. Conducting market research, surveys, and similar inquiries to help us understand trends and user needs across product categories or user groups;
         7. Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorised access to or use of personal data, our Site or data systems;
         8. In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
         9. Investigating and resolving disputes and security issues and enforcing our legal rights; and/or
         10. For the administration and maintenance of databases storing personal data.
      2. We may disclose each of the categories of personal data we collect to our service providers, business partners (for example, asset managers or other business intermediaries) and contractors for the business purposes described above.
      3. We use and disclose sensitive personal data for more limited purposes, including: when necessary to provide our services; services performed on our behalf related to the operation of our business and/or the services; to verify your identity; ensuring security and integrity of personal data; short-term, transient use; undertaking activities to verify or maintain the quality or safety of our services; to comply with applicable laws and regulations; for safety and security; and detecting, protecting against, or addressing malicious, deceptive, fraudulent, or illegal activity.
      4. In addition to the purposes described above, we may use and disclose any category of personal data we collect to respond to governmental and/or law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others; to resolve any disputes; to enforce our policies; and to evaluate or conduct a corporate business transaction such as a merger, sale, acquisition, joint venture, financing or sale of some or all of our assets, including bankruptcy proceedings
         
   3. How long we keep personal data
      How long we will hold your personal data for will vary and will be determined by the following criteria:
      1. the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
      2. legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
   4. California Privacy Rights California residents have the following rights relating to their personal data:
      1. Right to Know: You may request that we provide you with the following information:
         1. The categories of personal data we have collected about you;
         2. The categories of sources from which we collected the personal data;
         3. The business or commercial purpose for which we collected or disclosed the personal data;
         4. The categories of recipients to which we disclosed personal data;
         5. The categories of personal data that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal data; and
         6. The specific pieces of personal data that we have collected about you.
      2. Deletion Right: You may request that we delete the personal data that we have collected from you. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
      3. Correction Right: You may request that we correct inaccurate personal data that we have collected about you.
      4. Right to Opt-Out: We do not sell personal data or share personal data for cross-context behavioral advertising. 
      5. Right to Limit Use and Disclosure of Sensitive Personal Data: We do not use or disclose sensitive personal data for purposes to which the right to limit use and disclosure applies under the CCPA.
      6. Right to Non-Discrimination: You have the right to not be discriminated against when you exercise your CCPA rights. We will not treat you differently because you exercise your CCPA rights.
   5. Exercising your Rights
      
      1. You may exercise your access, deletion, or correction rights by submitting a verifiable request in the following ways:
         1. Calling us at 617-292-2570
         2. Submitting a request through the form at the bottom of the page.
         3. Emailing US-Compliance@partners-cap.com

      In order to protect you, we will not fulfil your request until we verify your identity.

      To verify your identity, we will use information about you that we already have when feasible; however, we may need to request additional information for verification. We may also use a third-party identity verification service. The information we need to verify your request will depend on the nature and scope of your request. Upon receipt of your request, we will notify you if we need additional information from you to verify your request. You may designate an authorized agent to make a CCPA request on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.

   6. Do Not Track Signals
      We do not respond to Do Not Track signals.
   7. Contact Information
      If you have any questions about how we process personal data or if you need access to this Notice in an alternative format or language, please contact at DPO@partners-cap.com.

   8. If you are a California resident, you may use this form to submit a request under the CCPA about your personal information collected by Partners Capital.