Privacy Notice

How to contact us

If you have any questions about our Privacy Notice or the personal information we collect or use, please contact;

FAO Data Protection Officer
abrdn plc
1 George Street
Edinburgh
EH2 2LL

Email: DPOffice@abrdn.com

Information we collect and use

Information 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, contact details
• Information connected to your service with us e.g. your bank account details
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected via cookies when you visit one of our websites e.g. activity on our website linked to IP address or device ID (some information will only be collected where you have turned on the relevant cookies in our preference centre).
• Information to allow you to access our online services e.g., username and email address.
• Information if you visit one of our offices e.g., visual images collected via closed circuit television (CCTV).
• Information classified as special categories of data (‘sensitive’ personal information) e.g., relating to your health. Where we collect and use sensitive personal information, as defined by data protection laws, this information will only be collected and used where it’s needed to provide the service you have requested or to comply with our legal obligations. We may need to obtain your explicit consent to process such information.

Where we collect your information

We may collect your personal information directly from you, or from a variety of sources, including but not limited to:

• When you agree (or your firm agrees) to our Platform Adviser Terms of Business, Elevate Adviser Terms of Business, Investment Hub Terms of Business; or the Model Manager Terms of Business (as applicable).
• When you interact with us e.g. phone conversations, email, letters and meetings.
• Registering for one of our events e.g., adviser roadshows
• Participating in research surveys to help us understand your needs as an adviser better and how we can improve our products and services for you and your clients
• Our online services such as websites, and through our social media (if you engage with our marketing campaigns) 
• We may also collect your personal information 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.
• Individuals who work in businesses you are associated with or own (in part or whole).

If you give us personal information about other people (such as Beneficial Owners or Shareholders of the company you work for), you confirm that you have their authorisation to do so and have advised them how to view this notice about how we will use their personal information.

Why we collect and use your information

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 manage our relationship with you and to provide the product or service you have requested e.g. to give you access to our platforms so that you are able to provide a service to your clients.
• It's necessary for us to meet our legal or regulatory obligations e.g. to check source of wealth and do appropriate money laundering checks, for the detection and prevention of fraud, and identity verification.
• We require your permission (consent) to use your information, e.g.  to send you email communications promoting other products and services offered by members of the abrdn group, You can withdraw your consent at any time via the unsubscribe link in our emails or by contacting DPOffice@abrdn.com.
• It's in our legitimate interests to process your information to better understand your needs as an adviser 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 support your clients with their financial needs and to get the best outcome for your clients from their products and investments with abrdn 
  • To conduct research and collate management information to improve the products and services we offer.

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. 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 products, services or features we offer you now or in the future. We use automated decisions in the following ways:

Tailoring products and services e.g. placing you in groups with similar advisers to make decisions about the products and services we may offer you to help meet your needs as an adviser.

When designing and enhancing our online services and tools for use by you in the provision of services to your clients

If you do not wish us to collect and use your personal information in these ways, it may mean that we will not be able to offer our services to you.

Who we may share your information with

We may share your information with third parties for the reasons outlined in 'Why we collect and use your information'.

We may share your information with:

• Other members of the abrdn group who support us in the provision of the services agreed with you l
• Credit and identity check agencies for ID verification, to verify information that we hold about you or to undertake regulatory and legal checks.
• Various technology companies; software suppliers; or companies who can help us in our contact with you, for example an internet service provider
• The nominee company of our abrdn wrap and Elevate platforms 
• Providers of products and investments we make available on our platforms, for example product providers and fund managers;
• Our regulators and government bodies; 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 the prevention and detection of crime
• Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime.
• Social media companies to display messages to you and others about our products and services. This involves securely sharing your information (e.g. your email address) to match it against information they may already hold about you; if you do not want us to share your information with social media companies for this purpose, you can tell us not to.

Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.