Privacy notice

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 product or 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.

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

• An application form for a platform account
• When you interact with us e.g. phone conversations, email, letters and meetings
• Registering for one of our events
• Third party product providers, where you have initiated a transfer to Aberdeen from that provider
• 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 (and if you engage with our marketing campaigns)

If you have a financial adviser or a discretionary investment manager, the information we collect and use will most likely have been provided by them on your behalf.

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.

If you have investments in a model portfolio managed by aPSL, some platforms may provide us with limited personal data relating to you i.e. names, portfolio numbers, wrapper type and value of your investments. aPSL may further process this data for internal reporting purposes.

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 we are able to satisfy one of the lawful processing conditions set out in 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 one of our pension or savings products, we will require some personal information including your name, address, date of birth, bank account details
• It's necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions, to check source of wealth and do appropriate money laundering checks for identify verification and for the prevention and detection of fraud
• 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 Aberdeen group. You can withdraw your consent at any time via the unsubscribe link in our emails or by contacting  DPOffice@aberdeenplc.com.
• It's in our legitimate interests to process your information to:
  • 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
  • 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
  • Conduct research and collate management information to improve the products and services we offer.
  • Develop new products and services

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 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 customers to make decisions about the products and services we may offer you to help meet your needs
• When designing and enhancing our online services and tools for use by your adviser and / or discretionary investment managers to provide you ongoing guidance and advice

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 provide you with our products and services.

We may share your information with third parties for the reasons outlined in 'Why we collect and use your information' and where there is an appropriate lawful basis to do so.

We may share your information with:

• Other parts of the Aberdeen group who support us in the provision of the product or service you have with us
• Third party product providers where you have instructed a transfer out to that provider
• Credit and identity check agencies for ID verification and credit checks, to verify information that we hold about you or to undertake regulatory and legal checks.
• Your adviser or discretionary investment manager where this is required as part of the product or service you have agreed with us
• Our partner for the Wrap platform - FNZ
• Subsidiaries/affiliates within Aberdeen Group plc and/or our selected partners for their marketing purposes only where you have provided prior appropriate consent
• Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies (e.g. Okta and origo); or companies who can help us in our contact with you, for example companies who help us validate mailing addresses or obtain up to date postal addresses
• 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, financial institutions and other third parties who require or request your personal information in the prevention and detection of crime or suspicious activity relating to your investments.
• HM Revenue & Customs (HMRC) for the processing of tax relief on pension payments or the prevention 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 Aberdeen product we want to advertise).
• Third parties in the negotiations of a sale, restructure or re-organisation of all or part of Aberdeen Group plc e.g. professional advisers, prospective purchasers
• Third parties, where relevant, for the purposes of responding to complaints, including the payment of any compensation

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

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 Aberdeen affiliates with ongoing oversight to ensure they meet these obligations.

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.

Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Internal and external audits are carried out on a regular basis 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.

To provide you with the agreed services and meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you (and your adviser) have a relationship with us.

Even when you (or your adviser) 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 or other privacy notices contained within our website and platforms, application forms, terms and conditions and other documents.

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 Platform-DSAR@aberdeenplc.com or in writing/email to 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 Aberdeen 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 Aberdeen 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 us to:

• give you information about our 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@aberdeenplc.com) or by post (see Contact Us section).

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 our Privacy Notice, please let us know immediately and we will do our utmost to make things right.

Please contact us at:

FAO: Data Protection Officer
Aberdeen
1 George Street
Edinburgh
EH2 2LL

Email: DPOffice@aberdeenplc.com

While we hope that we can resolve any complaints for you, you do have the option to 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