Privacy Policy

This Privacy Notice sets out how Partners Capital collects and uses personal data about you. It applies to visitors to our website partners-cap.com (the “Site”), as well as to our clients, prospective clients and other individuals with whom we interact. Please take the time to read and understand this Privacy Notice. A translation of this Privacy Notice can be provided upon request.

We use the following definitions in this Privacy Notice:

Partners Capital / “we” / “us” / “our” means Partners Capital LLP, Partners Capital Investment Group LLP, Partners Capital Europe SAS, Partners Capital Investment Group (Asia) Pte Limited, Partners Capital Asia Limited, Partners Capital LLP (DIFC Branch), Partners Capital (ME) Limited and Partners Capital Switzerland Sàrl.

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).

We are committed to maintaining the confidentiality, integrity and security of the personal data we collect. Accordingly, we have developed internal policies and implemented appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration, while allowing our clients’ needs to be met.

For the purposes of data protection law, the data controller or data user, as the case may be, of your personal data will generally be the relevant Partners Capital entity that collects your personal data, corresponds with you, provides services to you or your organisation, or otherwise determines the purposes and means of processing your personal data. We will identify the relevant controller to you at the time your personal data is collected or otherwise in the course of providing services to you. In relation to personal data collected through the Site, the controller is Partners Capital LLP.

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. In some jurisdictions personal data may also be required, to comply with anti-money laundering or counter-terrorist financing obligations.

If you are a resident of California, please click here for our California Privacy Notice, which also serves as our Notice at Collection.

This Privacy Notice applies to personal data relating to individuals. It does not apply to information about companies or other legal entities.

We may update this Privacy Notice from time to time. The date at the top of this notice shows when it was last updated. Where we make significant changes, we will take reasonable steps to inform you.

We collect and process different types of personal data about you as described below:

Personal data you provide to us

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:

• Basic personal data (such as first name, family name, email address, phone number, address, city, postcode and/ or country);
• 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;
• Information about your date of birth, nationality, gender, marital status, 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.
• Information about your preferences in relation to receiving direct marketing from us.
• If you choose to use or enable relevant scheduling functionality when arranging a meeting with Partners Capital staff, we may collect information about your calendar availability (such as free/busy status) to facilitate meeting scheduling through virtual scheduling assistants, time-blocking applications and similar tools.
• Where permitted or required by applicable law or regulation, we may monitor and record communications (such as emails, telephone calls and other electronic communications) to ensure compliance with legal and regulatory obligations, and for the prevention or detection of misuse or unlawful activity. This may involve processing personal data contained in those communications, including contact details and message content. Communications with us may therefore be monitored or recorded for these purposes.

Personal data we collect or generate

We may collect or generate personal data about you, including:

• Information about our business relationship with you and our interactions with you;
• information you provide when you submit identifiable comments or other content to us, which we may use to respond to you or otherwise fulfil the purpose of your submission; and
• Records of our communications with you (including call recordings where applicable), data relating to IT usage and risk profile information.

Personal data collected automatically

When you use our Site, we may automatically collect personal data including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Site, including where collected through cookies and similar technologies.

Personal Data from other sources

• We may collect and store information that is publicly available from sources such as Companies House and from information sources we subscribe to such as LSEG World Check-One; and
• We may collect additional information from third parties, including credit reference agencies or other background check and sanctions screening agencies.

What we use your personal data for

We may collect, use, process or store your personal data for business or commercial purposes, and the lawful bases for our processing include the following:

• Managing and administering our business, where this is necessary for our legitimate interests and, where applicable, to perform a contract with you;
• Creating, improving and developing our products and services, and the operation of our Site, where this is necessary for our legitimate interests and, where applicable, to perform a contract with you;
• Assessing risk profiles, and tailoring our product and service offerings to different client needs, where this is necessary for our legitimate interests and, where applicable, to perform a contract with you;
• Contacting you about programs, products or services that we believe may be of interest to you, including new product or service announcements and event invitations, where this is necessary for our legitimate interests or, where required by applicable law (including electronic marketing rules), with your consent. You can object to direct marketing at any time;
• Responding to your requests or inquiries and providing user support;
• Conducting market research, surveys, and similar inquiries to help us understand trends and user needs across product categories or user groups, where this is necessary for our legitimate interests;
• Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal data, our Site or data systems;
• Complying with, and assessing compliance with applicable laws, rules and regulations, and internal policies and procedures;
• Investigating and resolving disputes and security issues and enforcing our legal rights; and/or
• Administering and maintaining databases storing personal data, where this is necessary for our legitimate interests.

Why we are allowed to use your personal data

We will only use your personal data where permitted by applicable law. Depending on the processing activity and the law that applies, we may use your personal data because:

• it is necessary to enter into a contract with you or to perform our contractual obligations to you;
• we have obtained your consent, where required or appropriate;
• we have legal and regulatory obligations that we need to comply with;
• we need to do so to establish, exercise or defend our legal rights or in connection with legal proceedings;
• it is necessary for our legitimate interests or those of a third party, where permitted by applicable law and where those interests are not overridden by your rights and interests.

Our legitimate interests may include managing and administering our business, developing and improving our services, maintaining the security of our systems, conducting business analysis and promoting our business.

We will also notify you of the purposes for which your personal data is collected, used or disclosed where required by applicable law.

Sharing within Partners Capital

We may share your personal data with our affiliates where necessary to provide our services and to manage and administer our business. This may include personal data used for Know Your Customer (KYC) and anti-money laundering (AML) checks.

Other third parties

We may share your personal data with the following third parties:

• Service providers: We share your personal data with third party agents, vendors and contractors that we use or test and that may process your personal data in connection with the services they provide or are being considered to provide. These may include accountants, professional advisors, IT and communications providers (including website hosting and security providers such as Google reCAPTCHA) and virtual scheduling assistants. Where appropriate, these third parties will be subject to appropriate confidentiality, security and data protection obligations;
• Business partners: This may include asset managers or other business intermediaries. They may act as independent data controllers in which case they will process your personal data in accordance with their own legal obligations and provide any notices required by applicable law;
• Legal process, safety and enforcement: We may disclose your personal data where required or permitted by law, including to legal, governmental or regulatory authorities in response to lawful requests or to assist with investigations. We may also disclose your personal data to third parties in connection with claims, disputes or litigation, or where necessary to protect you or us, or to establish, exercise or defend our legal rights or contractual commitments; and
• Business transfers: Your personal data may be disclosed as part of a business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and may 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.

International transfers of your personal data

(including transfers of personal data outside of the UK and the EEA)

Your personal data may be transferred to, stored in or accessed from countries outside the jurisdiction in which it was originally collected, including where other Partners Capital entities or our service providers are located. Where we transfer personal data internationally, we will do so in accordance with applicable data protection law and will use appropriate safeguards where required.

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, for example the USA, 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:

• 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;
• the recipient might have entered into 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
• in other circumstances, the law may permit us to otherwise transfer your personal data outside of the UK or EEA.

Depending on where you are located and the services involved, countries to which your personal data may be transferred include the United Kingdom, EU/EEA, Switzerland, Singapore, Hong Kong, the United States and the United Arab Emirates. This list may change from time to time, and where required by applicable law, we will update this Privacy Notice.

In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.

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 using the details in the “How to contact us” section below.

We use cookies and similar technologies (such as pixels and local storage) on our Site. Cookies are small text files placed on your device when you visit a website. Further details, including a list of the cookies we use, their purposes and duration, and how we manage your preferences, are available in our Cookie Policy.

We take the protection of your personal data seriously, and maintain appropriate security measures, controls and policies. We keep your personal data only for as long as necessary for the purposes for which it was collected and used. The precise retention period will vary depending on the type of personal data and the circumstances.

In determining the appropriate retention period, we consider the duration of the relevant activity and any period specified in an agreement with you, the time reasonably required to demonstrate compliance with our professional, regulatory and legal obligations, any applicable statutory or regulatory requirements, the period during which litigation, claims or investigations may arise from your interactions with us, and whether continued retention remains necessary and proportionate in light of the purposes and lawful bases described above.

Further information about the retention period applicable to particular personal data is available on request.

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, although a reasonable fee may apply where permitted by applicable law. These rights may include:

• The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• 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. Withdrawing your consent does not affect the lawfulness of processing carried out before you withdrew it;
• 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 that 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;
• The right to request that we rectify your personal data if it is inaccurate or incomplete;
• 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;
• The right to object to, or request that we restrict, our processing of your personal data in certain circumstances. 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
• The right to lodge a complaint with the relevant data protection regulator or other competent authority if you think that any of your rights have been infringed by us.

We may charge a reasonable fee where permitted under applicable data protection law including where your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure that you are entitled to access the information or exercise any of your other rights. This is an appropriate security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it.

You can exercise your rights by contacting us using the details set out in the “How to contact us” section below.

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:

• California Privacy Protection Agency in California, United States (https://cppa.ca.gov/); and
• the Massachusetts, New York or Texas Attorney General, where applicable;
• Information Commissioner’s Office in the UK (www.ico.org.uk);
• Commission Nationale de l’informatique et des Libertés in France (the CNIL) (www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles);
• Office of the Privacy Commissioner for Personal Data in Hong Kong (https://www.pcpd.org.hk/);
• Personal Data Protection Commission in Singapore (https://www.pdpc.gov.sg);
• Federal Data Protection and Information Commissioner in Switzerland (https://www.edoeb.admin.ch/en/data-protection);
• Dubai International Financial Centre Commissioner of Data Protection (https://www.difc.com/business/registrars-and-commissioners/commissioner-of-data-protection);
• Abu Dhabi Global Market Office of Data Protection (https://www.adgm.com/operating-in-adgm/office-of-data-protection);

If you are a resident of California, you have specific rights which are explained here.

If you would like further information about how we collection, use, disclose, transfer or otherwise process your personal data, or about exercising any of the rights listed above, please contact our Data Protection Officer at DPO@partners-cap.com.

This section is provided pursuant to the California Consumer Privacy Act (CCPA) and describes how we collect, use, and disclose personal information 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.

Personal information that we collect about you

We collect and process the following categories of personal information about California residents:

• 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 may constitute Sensitive Personal Information under the CCPA;
• Characteristics of Protected Class such as your date of birth, marital status, citizenship or immigration status, and gender. Certain information in this category, including citizenship or immigration status, may constitute Sensitive Personal Information under the CCPA;
• Commercial Information such as your business relationship with us and the products and services that you request from us;
• Sensory Information such as photographs, audio, and video information collected when you communicate with us by phone or videoconferencing;
• Professional or Employment-Related Information including your employment history and education;
• Internet and other Electronic Network Activity Information including browsing history, search history, and information regarding interactions with our Site or applications; login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Site, including where collected through cookies and similar technologies;
• Geolocation Data including your approximate location inferred from your IP address or other device information; and
• Inferences drawn from other Personal Information and reflecting the preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Sources from which we collect Personal Information

In general, we collect personal information from the following categories of sources:

• Directly from you;
• Automatically, for example through cookies, pixels, and other similar technologies used on our Site;
• Generated by us, for example, when we provide you with a username or other credentials or when we draw inferences from other personal information we collect;
• From service providers that help us operate our business; and
• From third-party sources, including data providers, internet service providers, data analytics vendors, advertising networks, social networks, other financial institutions or advisors, and your employer or colleagues.

How we use and disclose Personal Information

We typically use and disclose the personal information we collect for the following purposes:

• For the management and administration of our business;
• Creating, improving and developing our products and services, and the operation of our Site;
• Assessing risk profiles and tailoring our product and service offerings to different client needs;
• 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;
• Contacting you to respond to your requests or inquiries and provide user support;
• Conducting market research, surveys, and similar inquiries to help us understand trends and user needs across product categories or user groups;
• Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorised access to or use of personal information, our Site or data systems;
• In order to comply with and assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• Investigating and resolving disputes and security issues and enforcing our legal rights; and/or
• For the administration and maintenance of databases storing personal information.

We may disclose each of the categories of personal information we collect to our service providers, business partners (for example, asset managers or other business intermediaries) and contractors, vendors for the business purposes described above.

We use and disclose sensitive personal information only for more limited purposes permitted under the CCPA, 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.

In addition to the purposes described above, we may use and disclose any category of personal information we collect to respond to governmental and/or law enforcement requests, or as otherwise required or permitted 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

How long we keep Personal Information

We take the protection of your personal information seriously, and maintain appropriate security measures, controls and policies. We keep your personal information only for as long as necessary for the purposes for which it was collected and used. The precise retention period will vary depending on the type of personal information and the circumstances.

In determining the appropriate retention period, we consider the duration of the relevant activity and any period specified in an agreement with you, the time reasonably required to demonstrate compliance with our professional, regulatory and legal obligations, any applicable statutory or regulatory requirements, the period during which litigation, claims or investigations may arise from your interactions with us, and whether continued retention remains necessary and proportionate in light of the purposes and lawful bases described above.

Further information about the retention period applicable to personal information is available on request.

California Privacy Rights

California residents have the following rights relating to their personal information:

• Right to Know: You may request that we provide you with the following information:
  • The categories of personal information we have collected about you;
  • The categories of sources from which we collected the personal information;
  • The business or commercial purpose for which we collected or disclosed the personal information;
  • The categories of recipients to which we disclosed personal information;
  • The categories of personal information 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 information; and
  • The specific pieces of personal information that we have collected about you.
• Deletion Right: You may request that we delete the personal information 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.
• Correction Right: You may request that we correct inaccurate personal information that we have collected about you.
• Right to Opt-Out: We do not sell personal information or share personal data for cross-context behavioural advertising.
• Right to Limit Use and Disclosure of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
• 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.

Exercising your Rights

You may exercise your access, deletion, or correction rights by submitting a verifiable request in the following ways:

• Calling us at +1 (617) 292-2570;
• Submitting a request through the form at the bottom of the page; or
• 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. We may require an authorized agent to provide proof that you have authorized them to act on your behalf. We may also require you either to verify your identity directly with us or to confirm directly with us that you have given the authorized agent permission to submit the request, except where applicable law provides otherwise.

Do Not Track Signals

We do not respond to Do Not Track signals.

Contact Information

If you have any questions about how we process personal information or if you need access to this Notice in an alternative format or language, please contact us at DPO@partners-cap.com.

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.