Privacy Notice

Last updated and effective August 2021

  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 consider privacy to be fundamental to our relationship with our current and prospective clients. We are committed to maintaining the confidentiality, integrity and security of their personal data. 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 information 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, you have different rights which are explained here.
  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. The California Consumer Privacy Act of 2018 (CCPA) requires that a business disclose certain information about its collection, use, disclosure and sale (if any) of the personal data of a California resident. This California Privacy Notice is part of our Privacy Notice. This section only applies to California residents.
    2. The personal data that we collect, use and disclose relating to you as a California resident will depend on our interaction or relationship with you. The CCPA does not apply to certain types of personal data that is collected by investment advisors such as Partners Capital in the course of providing our services. This California Privacy Notice applies more generally to the personal data that we may collect from you during your interactions with us on our website or in our California offices.
      1. Notice at Collection This Notice at Collection is part of our Notice and includes information about the personal data that we collect from California residents and how that data may be used.
      2. Personal data that we collect about you We collect and process different categories of personal data about you as described below:
        1. Identifiers such as first name, family name, dependents names, and state issued identification numbers including driver’s license number and Social Security number;
        2. Customer Records Information including personal data defined by the California customer records law, such as your contact information including email address, phone number, address, city, postcode and/ or country;
        3. Characteristics of Protected Classes such as your marital status or gender;
        4. Purchase Information such as your business relationship with us including the products and services that you request from us;
        5. Biometrics such as a recording of your voice or a photograph of you;
        6. Employment information including your employment history and education;
        7. Internet and other electronic network activity such as your IP address, device information, time zone setting and location, operating system and platform and other technologies you use to access our website. We also collect information about how you use our website, such as the pages you visit;
        8. Inferences including your preferences and characteristics, which we may use for marketing purposes.
      3. How we use your personal data We will only use your personal data in compliance with applicable laws. We typically use your personal data for the following business 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.
      4. Your Consumer Rights California residents have the following consumer rights to their personal data. These rights apply to personal data that we have collected from or about you in the previous 12 months.
      5. Access Right: You may request that we provide the following information:
        1. The categories of personal data we have collected about you and the categories of sources from which we collected the personal data;
        2. The business or commercial purpose for which we collected the personal data;
        3. The categories of third parties to whom we disclosed your personal data;
          and
        4. The specific pieces of personal data that we have collected about you.

        You may exercise this right twice during a 12 month period.

      6. Deletion Right: You may request that we delete the personal data that we have collected about you.
      7. Right to Opt-Out: We do not sell your personal data. If we did, you would have the right to opt-out of that sale.
      8. 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.
    3. Exercising your Consumer Rights
      You may exercise your access or deletion rights by submitting a verifiable consumer request in the following ways:

      1. Calling us at 617-292-2570
      2. Emailing US-Compliance@partners-cap.com

      In order to protect you, we will not disclose information in response to a request for access or complete a deletion request unless we can verify your identity or verify that that you are an authorized representative of the person making the request.

      We will not respond to requests to know/requests for access or requests for deletion unless we can verify your identity to a reasonable degree of certainty. To verify your identity, we will use information about you that we already have when feasible; however, we may need to request additional information, which we will use only for the purposes of 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.

    4. Do Not Track Signals
      We do not respond to Do Not Track signals.
    5. Shine the Light
      California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Please contact us directly to make this request.
    6. Contact Information
      If you have any questions about the personal data that we collect, use or disclose relating to California residents, please contact refer to the “How to contact us” section of the Privacy Notice.