The privacy of your personal information is very important to us. This Privacy Notice explains how we (the data controllers identified below) use your personal information. It also describes your data protection rights, including a right to object to some of the processing which we carry out.
For the purpose of this Privacy Notice, “you” or “your” means you a user of our website.
In relation to any information we collect about you and any information we process in relation to you, the data controller is Evelyn Partners Group Limited.
How do we receive your information?
We may receive information about you from one or more of the following sources:
- Directly from you through your use of our website:
- When you register with us, use our services, book to attend an event or submit a subscription request (e.g. to receive a newsletter or for marketing information or download one of our guides), make an enquiry (e.g. by submitting an online enquiry form)
- If you apply to work for Evelyn Partners
- Through your interactions with our website and mobile applications
- Other Evelyn Partners group companies
- Your postings on any other social media applications if your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram give us permission to access information from those accounts
- By completing a survey relating either to your use of our website and/or information posted on the website
What information do we collect from you?
Information we process about you includes (but is not limited to):
- Contact information such as your name, address, email address, phone number and other contact information
- At times we may request some specific information related to a particular area. This could be in the form of an industry survey or as part of a marketing campaign
- Interactions with our website and mobile applications such as your Internet Protocol (IP) address which indicates the location of your computer, your browser type and language
- Information about your visit to our website and mobile applications. This can include the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page
We do not collect sensitive information about you on our website. Sensitive information includes information about your health, ethnicity, political or philosophical beliefs, or criminal offences.
How will we use the information we collect about you?
Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience and to provide the services you have requested. We may also use the information that you have provided to ensure that the content on our website and mobile applications is presented in the most effective manner for you and your computer and/'or other device.
We use the personal information about you for a number of reasons:
Where necessary to perform a contract with you
- To communicate with you
- To perform pre-contractual activities such as considering applications or enquiries
- To carry out our obligations arising from any contracts between you and us and to provide you with the information, products and services that you request from us
- To notify you about changes to our service or to deliver service messages
Where necessary to comply with a legal obligation
- To comply with any legal obligations to which we are subject
- In connection with legal claims, (including disclosure of personal information in connection with legal process or litigation). The latter may include special category information contained in documents, telephone or video recordings
Where it is in our or a third party’s legitimate interests, as listed below, and where these interests are not overridden by your fundamental rights and freedoms
- To ensure that content from our website is presented in the most effective manner for you and for your computer and/or device
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- As part of our efforts to keep our website safe and secure
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
- To send you our newsletter or updates, or to make suggestions and recommendations to you as a use of our website and mobile applications about services that may interest you or them
- To provide you with targeted marketing in relation to our services (unless you indicate at any time that you do not wish us to do so)
- To improve how we interact with you through our website and mobile applications to improve the user experience (e.g. by enabling user feedback on our website)
- To prepare research and anonymised or pseudonymised statistical reports
- To follow up with you after you request information to see if we can provide any further assistance
- To ensure that complaints are investigated
- To prevent or detect abuse of our services or any of our rights, and to protect our (or others') property or rights
- To share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject always to confidentiality obligations
- Auditing, assurance and compliance monitoring
You have the right to object to processing where it is in our or a third party’s legitimate interests by contacting us at: The Data Protection Officer, Evelyn Partners, 45 Gresham Street, London, EC2V 7BG or by email: email@example.com.
With your consent
- With your consent, where such consent is required under the applicable regulations and data protection laws, to send you information about products and services of ours and other companies in our group which may be of interest to you. You may withdraw your consent or otherwise opt out of receiving this information at any point. You can contact us using the details below; or opt to unsubscribe from marketing communications by using the method contained in any marketing message.
You have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing that we carried out before your withdrawal. If you choose to withdraw your consent, we may not be able to provide you with certain products and services.
Providing third party information to us
Sometimes we receive personal information relating to third parties, for example family members, joint account holders, underlying clients or beneficiaries. When this information is provided to us, we expect that you have obtained any necessary permissions from such persons to the reasonable use of their personal information for the purposes referred to in this Privacy Notice.
Who do we share your information with?
Information is normally only provided to a third party if it is required in order to deal with your enquiry, but there may be other circumstances where it is necessary for Evelyn Partners to provide information, including as a result of legal or regulatory process.
The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Notice:
- Other companies in the Evelyn Partners group (for example, to satisfy our anti-money laundering requirements and account opening purposes)
- Third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our products and services, respond to your enquiries or for any other related purposes
- Our service providers who act only on our instructions (e.g. service and software providers, IT and hosted services, compliance monitoring services) including their sub-contractors
- Our professional advisors (e.g. suppliers, professional advisors, solicitors, auditors, insurers)
- Analytics and search engine providers that may assist us in the improvement and optimisation of our website and mobile applications
- Website optimisation technologies (e.g. GetSiteControl, HotJar)
- Statistics and research providers (e.g. Nisus)
- Websites that help us to identify new prospective clients such as Meta Pixel by Facebook, Google Tag Manager and LinkedIn Insight Tag
- Third parties who support our information technology or handle mailings or events on our behalf
- Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect our website, our technology assets or the rights, property or personal safety of any person)
- Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity
- Any successor in interest, in the event of a liquidation or administration of Evelyn Partners
Evelyn Partners do not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.
Transfers of personal information outside the United Kingdom (UK)
Personal information in our possession may be transferred to countries and jurisdictions which are outside the UK. These may be where your investments are held, where transactions are effected, from where you receive or transmit information about your investments and where underlying managers conduct their activities.
These countries and jurisdictions may have differing (and potentially less stringent) laws relating to the protection of personal information. They may also have less stringent laws relating to the degree of confidentiality afforded to your information.
Information can become subject to the laws and disclosure requirements of such territories, including disclosure to governmental bodies, regulatory agencies and private persons as a result of applicable governmental or regulatory inquiries, court orders or other similar processes.
If we transfer your information outside the UK, we will make sure that it is done lawfully and will only occur where:
- we have your consent to share, or the transfer is otherwise legally allowed;
- the transfer is to a country that the UK has determined offers adequate data protection; or
- appropriate legal safeguards have been put in place in accordance with Data Protection Legislation. For further information about the relevant safeguards, please contact the Privacy Office using the details provided below.
Security of your information
We will take appropriate steps to store, process and send your personal information securely and employees are trained on and are aware of their responsibility to maintain your privacy.
We will take appropriate technical and organisational security measures against the accidental loss, destruction, damage and/or the unauthorised or unlawful use of your personal information. These will include ensuring that any service provider provides sufficient security guarantees in relation to any data processing it undertakes on our behalf.
Our website contains links to other websites. Evelyn Partners are not responsible for the privacy policies of third-party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered, via our website.
How long do we keep hold of your information?
We will only keep the information we collect about you, through your use of our website or otherwise, for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
Once we no longer need your personal information, we securely destroy it.
What are your rights in relation to the personal information we hold about you?
This section explains what rights you have under data protection law. If you want to exercise any of these rights, or if you would like further information about them, you can contact us using the details set out in the ‘Contact Us’ section below.
We will grant your rights request only to the extent that, following an assessment of your request, we are allowed and required to do so under data protection law. Your rights may be limited; for example, if fulfilling your request would unfairly reveal personal information about another person, or if you ask us to delete information which we are required by law or have a compelling legitimate interest to keep.
You have the right to:
1. ask for a copy of the personal information we hold about you in a written format, free of charge.
2. require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information.
3. in certain cases, ask us to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.
4. object to the processing of your personal information in certain circumstances.
5. have the personal information we hold about you erased in certain circumstances, unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations.
6. obtain and reuse your personal information for your own purposes across different organisations; for example, if you wish to move to a new financial services provider. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely (where technically feasible), without affecting its usability.
7. lodge a complaint about how we collect, process and store your personal information with our Data Protection Officer (details below), or with the supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
You can contact the Evelyn Partners Privacy Office to exercise any of the rights relating to your personal information as set out above, or if you have any questions or comments about privacy issues, or wish to raise a complaint about how we are using your personal information, by emailing firstname.lastname@example.org or using the unsubscribe links at the bottom of our communications.
You may also contact our Data Protection Officer by post: The Data Protection Officer, Evelyn Partners, 45 Gresham Street, London, EC2V 7BG.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will update this document from time to time as required. This Privacy Notice was last updated in July 2022.
Privacy Notices for specific services
If you are a client or prospective client, or a job applicant for Evelyn Partners and want to know more about how we process your personal information, copies of our Privacy Notices for our various service lines can be found here: