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Privacy

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This Privacy Notice describes how your personal data will be collected and used as a customer of 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 & Advice Limited, abrdn Capital Ltd, 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) and are separate controllers of your personal information (as defined by data protection laws).

We 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.

This Privacy Notice 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 Notice. When you browse our websites we use cookies to make our site secure and to ensure it works properly. We also use cookies to store information about how you use our websites to improve the quality of services provided; however, you can choose which of these types of cookies we use in our cookie preference centre. Cookies and similar tracking technologies will also be used in some of our emails; you can choose to block these via your device settings but they are useful to help us understand if you have opened an email and how you responded to it. To understand more about the type of cookies we may use and how to set your preferences, read our Cookie Policy.

We keep our Privacy Notice under regular review. This version was last updated on 10 October 2022. We may need to make changes to this Privacy Notice 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, we will contact you to let you know.

Contact us:

If you have any questions about this Privacy Notice or the personal information we collect and use about you in connection with the products or services we provide, please contact;

FAO Data Protection Officer
abrdn plc
1 George Street
Edinburgh
EH2 2LL
DPOffice@abrdn.com

This Privacy Notice includes the following sections

Information about you that we collect and use includes:

  • Information about who you are in order to verify your identity and comply with Anti-Money Laundering Regulations e.g. your name, date of birth, national insurance number (or equivalent), passport, contact details, occupation, source of wealth
  • Information connected to your product or service with us e.g. your bank account details, email address
  • Information about your contact with us e.g. meetings, phone calls, emails / letters
  • Information about your priorities and goals e.g. savings goals / retirement planning
  • Information that is automatically collected via cookies when you visit one of our websites or access our online tools e.g. username, your activity on our website. Some information will only be collected where you have turned on the relevant cookies in our preference centre.
  • Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
  • Information connected to other people associated with you e.g. where you have a joint product or service with a partner or a product available only to children / minors such as the Junior ISA, we will require some personal information about them including their name, date of birth and relationship with you
  • Information classified as special category data ['sensitive' personal information] e.g. relating to your health, gender. Where we collect and use such sensitive personal information, as defined by data protection laws, this information will only be collected and used where it's needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process this information.

We will collect your personal information directly from you, from a variety of sources, including: 

  • An application form for a product or service with us e.g. Stocks and Shares ISA or for a platform account
  • Phone conversations with us
  • Emails or letters you send to us
  • Registering for one of our events e.g. retirement or financial planning and advice roadshows
  • Participating in research surveys to help us understand you better and improve our products and services
  • Participating in research surveys to help us understand you better and improve our products and services
  • Our online services such as websites, and through our social media (if you engage with our marketing campaigns)
  • If you have a financial adviser or a discretionary investment manager, the information we collect and use may be provided by them on your behalf.
  • 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 obtain updated contact information if we have been 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:

    • It’s necessary to provide the product or service you have requested e.g. if you wish to invest in our products, we will need to collect and use personal information from you including your name, address, date of birth, national insurance number and bank account details; or, if you require us to provide you with financial planning and advice we may also need some special category information relating to your health and lifestyle to provide a plan tailored to your specific goals and needs
    • It’s necessary for us to meet our legal or regulatory obligations e.g. to send you important information including any changes to a product’s or app’s legal Terms and Conditions, to check source of wealth and do appropriate money laundering checks, or for the detection and prevention of fraud
    • You have given us your permission [consent] to use your information e.g. to send you email communications with information about similar products and services offered by other subsidiaries of abrdn plc. You can withdraw your consent at any time via the unsubscribe link on these emails or by contacting DPOffice@abrdn.com
    • It’s in our legitimate interests to process your information to better understand you and your needs so we can:
      • Send you postal communications to make you aware of other relevant products and services available from us
      • Show you targeted ads for our products and services through social media channels
      • Deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment
      • Further improve our products and services by using information we hold on our records about existing customers to better understand their preferences and needs
      • Conduct research and collate management information to understand how customers have interacted with us, which products and services customers have already purchased, and to help us send more relevant communications based on our analysis of customers’ preferences and needs

    Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be. If you wish to object to this processing, please contact us (see Contact Us section).

    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.

    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 their 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:

    • Other subsidiaries of abrdn plc who support us in the provision of the products and services agreed with you
    • Various technology companies; software suppliers; or companies who can help us in our contact with you, for example an internet service provider
    • FNZ – our partner for the wrap platform
    • Credit and identity check agencies for ID verification and credit reference checks e.g. Experian and Call Validate
    • Your adviser or discretionary investment manager where this is required as part of the product or service you have agreed with us
    • Our regulators; including the Financial Conduct Authority (FCA and the Information Commissioner's Office for the UK (the ICO)
    • Law enforcement and other appointed agencies who support us (or where they request the information in line with their own obligations) in the prevention and detection of crime
    • HM Revenue & Customs (HMRC) for the processing of tax relief (where relevant) or the prevention of detection of tax avoidance
    • Social media companies such as Facebook and LinkedIn, so they can display messages to you and others about our products and services, or make sure you are not sent information which is not relevant to you personally (for example, if you already have the abrdn product we want to advertise).

    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.

    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, platform account or other services 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; typically, we will be required to retain your personal information for a minimum of 7 years after our relationship has ended.

    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 on our websites and within, for example, product and investment fund application forms, terms & conditions.

    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 for abrdn plc (see 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 us 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 investments to another company.

    Right to object to processing of your personal information
    You can object to us 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:

    • Give you information about its processing of your personal information
    • Request human intervention or challenge a decision where processing is done solely by automated processes
    • Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

    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 contact the Data Protection Office by email (DPOffice@abrdn.com) or by post (see Contact Us section above).

    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.