Terms and Conditions
1. We do our best to ensure that the website operates properly at all times, but we make no warranties as to the availability or accessibility of the website, and (save as otherwise set out in these terms and conditions) we will not be liable for any damages, loss, costs or expenses incurred by you as a result of any lack of availability or accessibility of the website.
2. Nothing within these conditions operates so as to exclude, limit or restrict our liability for death or personal injury.
3. Where you deal as a consumer, nothing in the above exclusions affects your statutory rights.
4. All Intellectual Property Rights and goodwill in or relating to the contents of the website belong to either ourselves, to a member of the St. James’s Place group or to our suppliers.
©2018 St. James’s Place plc. All rights reserved. “St. James’s Place” and the St. James’s Place Logo are trademarks of St. James’s Place plc.
Nothing contained in these conditions or the website should be construed as granting by implication, estoppel, personal bar, or otherwise, any licence or right to use any of the trade marks without our permission. However, copying and printing of those web pages which contain the trademarks is permitted within the scope of the licence below.
You may download to a local hard disk and print extracts from the website solely for personal, non-commercial use. You may also recopy downloaded extracts to others for their personal, non commercial use.
You may not reproduce part or all of the contents of the website in any form unless it is for personal, non commercial use.
You may not copy or otherwise incorporate into or store in any other website, electronic retrieval system, publication or other work any of the content of the website in any form (whether hard copy, electronic or other).
You may not frame or link to the website or any part of it without our express permission.
The information published on this website is provided as a convenience to visitors and should be used for information purposes only and is subject to change without notice. None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact one of our personnel.
While we use reasonable efforts to ensure that the information contained on this website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. We accept no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. These documents should not be copied, reproduced or redistributed, in whole or in part.
No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros. Links from this website exist for information only and we accept no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by us or St. James’s Place. Links to this website are not permitted without our prior written consent. Please note that clicking on links to external websites will cause you to leave this website.
In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”.
Wellesley Wealth Advisory in the United Kingdom will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.
Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.
Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.
We also use details of any unspent criminal convictions for fraud prevention purposes.
Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections.
We carry out the following marketing activities depending on the relationship that we have with you:
1. Where you are a prospective client
We will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about our wealth management services that we offer which you might be interested in.
In these letters, we inform you that we will contact you via telephone to discuss our service offerings unless you notify us that you do not wish to receive such a call.
As part of our follow-up telephone call we will discuss the wealth management services we offer which you might be interested in and we will answer any questions that you may have.
Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you.
We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so.
We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this.
2. Where you are an existing client
We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so.
We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have consented to receive this.
General marketing practices
If you wish to opt out of marketing, you may do so by clicking on any “unsubscribe” link or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us to update your contact preferences.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.
We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in the section above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to.
If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in the ‘Contacting St James’s Palce’ section below.
There may be some instances where your personal information is transferred to countries outside of the European Economic Area (“EEA“) such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:
- entering into data transfer contracts and using specific contractual provisions that has been approved by European data protection authorities otherwise known as the “standard contractual clauses”. You can find out more about standard contractual clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en;
- transferring personal information only to companies in the United States who are certified under the “Privacy Shield”. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome or
- we will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.
Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:
|Country of transfer||Reason for the transfer||Method we use to protect your information|
|China, Hong Kong and Singapore||Provision of data to international offices to support clients living overseas.||We have standard contractual clauses in place|
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in the contact section below.
At St. James’s Place, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.
- We have a dedicated group, the “Information Security Oversight Committee”, that provides oversight and guidance to our information security and privacy programme.
- We educate and train our employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.
- When you login, or send us information on the internet we protect the security of this information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
- We will always interact with you in a safe, secure and consistent manner.
- We continually review our physical and logical security controls in place across the business.
- We conduct security testing of our applications and services in a controlled testing environment before they are made available for our Clients to use.
- We have a business resiliency plan with a disaster recovery and business continuity testing.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.
In addition, we use Google’s remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.
We will only collect personal information about you if you send us an e-mail enquiry via the ‘contact us’ facility or you register to receive your Unit Trust Manager’s Reports by email. In order for this to happen, you will need to fill out the on line ‘contact us’ form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the ‘contact us’ form, which also tells you how this information will be used. The type of information collected to register to receive the Unit Trust Manager’s Reports by email will be apparent from the details requested when you register. The information collected when you register will only be used to email your Unit Trust Manager’s Reports and for no other reason.
We take all reasonable precautions to protect our visitors’ information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which Wellesley Wealth Advisory or St. James’s Place handles data collected from you on this website, please contact us for more information.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James’s Place employees comply with legal obligations and St. James’s Place policies and procedures (including our customer relations practices).
You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time if you wish to exercise these rights; we will not usually charge you.
We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:
- in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
- in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
Please click here for Wellesley Wealth Advisory contact details.
If you would like any further information about any of the matters in this notice or if you have any other questions about how St. James’s Place collect, store or use your personal information, you may contact the St. James’s Place Data Protection Officer at St. James’s Place Wealth Management Group plc, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, firstname.lastname@example.org and 0800 0138 137.
From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments.
This notice was last updated on 18-06-2018.