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This Privacy Policy applies to the various financial planning and advice, digital direct-to-consumer, and discretionary fund management products and services offered by abrdn Client Management, abrdn Financial Planning and Advice Limited [including subsidiaries], Standard Life Savings Limited and Elevate Portfolio Services Limited [collectively referred to within this Privacy Policy as ‘we’, ‘us’, ‘our’]. All are subsidiaries of abrdn plc; a global asset management company offering active wealth management, financial planning and advice services.
abrdn plc and its subsidiaries are committed to safeguarding any personal information shared with us. We take privacy seriously and as a consumer of one or more of our digital, financial planning and advice or discretionary fund management services you can be assured that we will only ever collect and use your personal information where it is necessary, fair and lawful to do so in line with the privacy & data protection laws applicable to our business operations.
Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.
Our Cookie Policy forms part of our Privacy Policy. When you browse our websites and use our open banking app, we use cookies and other similar tracking technologies to store information about how you use these websites in order to improve the quality of service provided to you. Find out more about these cookies and tracking technologies and how to set your preferences.
We keep our Privacy Policy under regular review. This version was last updated August 2021. We may need to make changes to this Privacy Policy so please check our website for updates from time to time. If there are important changes such as changes to where your personal information will be processed or the terms of the open banking app; we will contact you to let you know.
If you have any questions about this Privacy Policy or the personal information we collect and use about you in connection with the products or services we have agreed with you, please contact;
FAO Data Protection Officer
abrdn plc
1 George Street
Edinburgh
EH2 2LL
Email: DPOffice@abrdn.com
Information about you that we collect and use includes:
We will collect your personal information directly from you, from a variety of sources, including:
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:
Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be.
We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the services or features we offer you now or in the future. We use automated decisions to tailor the functionality and products within the open banking app, for example, to support your financial priorities and needs by placing you in groups with similar individuals to make decisions about the services we may offer to help meet your and other customers’ needs.
We will also collect and use statistical and aggregated data to understand, for example, the total number of customers for a particular product or service or how customers are using our open banking app features and functionality to support further development of the app and continually improve user experience.
Note - If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with some of our services
The majority of your information is processed in the UK or European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with in countries outside of the UK or the EEA, including countries such as the United States.
Where your information is being processed outside of the UK or the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties and abrdn affiliates with ongoing oversight to ensure they meet these obligations.
We will be required to share your information with selected 3rd parties and other subsidiaries of abrdn plc for the reasons outlined in ‘Why we collect and use your information’.
We will share your information with:
Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations. An example of this is that Internal and external audit and specialist third party consultants conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. . Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information whether it is being processed by us or a third party acting on our behalf.
Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
We also use internal and external audit and specialist third party consultants to conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.
To provide you with the product or service agreed and to fulfil our legal and regulatory obligations, we will keep your personal information and copies of records we create (e.g. calls with us) while you are a [prospective] customer or client of ours.
Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.
You have a number of rights under Data protection laws which may be exercised in certain circumstances.
These are:
Right to be informed about how and why we are processing your personal information
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with - we do this in our Privacy Notice and privacy notices.
Right of access to personal information relating to you
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR) by contacting the Data Protection Officer (see How to Contact Us section).
Right to request rectification of inaccurate or incomplete personal information
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure of your personal information
You can ask for your information to be deleted or removed if there is not a compelling reason for abrdn to continue to have it.
Right to restrict processing of your personal information
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information - but only to ensure we don't use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.
Right to object to processing of your personal information
You can object to abrdn processing your personal information where: it's based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
Right to not be subject to automated decision making including profiling
You have the right to ask abrdn to:
More information can be found on your rights here https://ico.org.uk/for-the-public/
If you require any more information on your rights and how to exercise them, you can email: DPOffice@abrdn.com or contact us at www.abrdn.com/en-gb/individual/help
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in this Privacy Policy, please let us know immediately and we will do our utmost to make things right.
Please contact us at:
FAO Data Protection Officer
abrdn,
1 George Street,
Edinburgh,
EH2 2LL
Email: DPOffice@abrdn.com
While we hope that we can resolve any complaints for you, you do have the option complain to the ICO (whether or not you have exhausted our complaints procedure). Their contact details are as follows:
Website: https://ico.org.uk/
Postal address:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Our Stocks and Shares ISA and Personal Portfolio are provided by Standard Life Savings Limited, which is registered in Scotland (SC180203) at 1 George Street, Edinburgh, United Kingdom, EH2 2LL. It is authorised and regulated by the Financial Conduct Authority under registration number 188796. Standard Life Savings Limited is a wholly owned subsidiary of abrdn plc.
abrdn Financial Planning and Advice Ltd is registered in England (01447544) at Bow Bells House, 1 Bread Street. London, EC4M 9HH and is authorised and regulated by the Financial Conduct Authority.
‘abrdn’ is a trading name used by Cumberland Place Financial Management Limited, which is part of abrdn group (abrdn plc and its subsidiaries). Cumberland Place Financial Management Limited is registered in England (8948895) at Bow Bells House, 1 Bread Street. London, EC4M 9HH and is authorised and regulated by the Financial Conduct Authority.
‘abrdn’ is a trading name used by Fraser Heath Financial Management Limited, which is part of abrdn group (abrdn plc and its subsidiaries). Fraser Heath Financial Management Limited is registered in England (04357058) at Bow Bells House, 1 Bread Street. London, EC4M 9HH and is authorised and regulated by the Financial Conduct Authority. © 2021-22 abrdn, All rights reserved.
Copyright © abrdn plc 2021-22. All rights reserved.
abrdn plc is registered in Scotland (SC286832) at 1 George Street, Edinburgh, EH2 2LL