Privacy Policy

Introduction

This Privacy Policy explains how Royal Exchange Investment Management Ltd (“we”, “us” or “our”) collects, uses, stores and protects your personal data. We are committed to safeguarding your privacy and handling your personal information in a transparent and lawful manner.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details set out at the end of this notice.

Legal Basis for Processing

We collect, control and process personal data in accordance with UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The primary lawful basis for processing your personal data is contractual necessity. This means we process your personal data where it is necessary to provide information to you, respond to your enquiries, and deliver our regulated services.

We may also process personal data where necessary to comply with our legal or regulatory obligations, including those imposed by the Financial Conduct Authority (FCA).

Special Category Personal Data

We do not normally collect or process special category (sensitive) personal data. Where it becomes necessary to do so in order to provide our services or comply with regulatory requirements, we will discuss this with you in advance and obtain your explicit consent before processing such information. The provision of this information following that discussion will be treated as your consent.

Provision of Personal Data

You are not obliged to provide us with personal data. However, if you choose not to provide information that is necessary for us to deliver our services, we may be unable to act for you or provide advice.

Marketing

We do not use your personal data for marketing purposes and do not share your personal data with third parties for marketing. Where we do collect data for marketing purposes, we will clearly inform you and obtain your explicit consent.

Personal Data We Collect and How We Use It

We collect and use personal data to provide advice, arrange products and services, and communicate with you. This may include:

• Your name and contact details (including email address)

• Information relevant to the services we provide to you

• Records of advice, communications and transactions

This information is processed and stored securely and used only for legitimate business and regulatory purposes.

Sharing Your Personal Data

To fulfil our contractual and regulatory obligations, we may share your personal data with third parties acting as either Data Controllers or Data Processors.

Data Controllers
These may include:

• Product and service providers (including investment, pension and platform providers)

• Compliance and regulatory monitoring providers

• The Financial Conduct Authority

• The Financial Ombudsman Service

• Other regulators or authorities where required by law

Data Processors
We also use external Data Processors who process personal data on our behalf for purposes such as:

• Secure file sharing

• Data storage and backup

• Communications

• Accounting and forecasting

• Record keeping

• Regulatory compliance

All Data Processors are contractually required to process personal data only in accordance with our instructions and applicable data protection laws.

Data Processor Systems Used

We seek to minimise the personal data shared with third parties and anonymise data where possible. However, in some cases identifiable data is required to provide services effectively.

The systems we use include:

• Raymond James Investment Management Platform – client administration, record keeping and product arrangements

• Microsoft SharePoint – secure document storage and internal and external file sharing

Each provider maintains its own privacy and security policies, which may be updated from time to time.

We will not share your personal data in any circumstances other than where necessary to provide our services or where we are legally required to do so.

Where Your Data Is Stored

Your personal data is stored securely on encrypted servers, encrypted backup drives, or with contracted third-party processors who meet appropriate security standards.

Your Rights

Under data protection law, you have the right to:

• Request access to the personal data we hold about you

• Request correction of inaccurate or incomplete data

• Request deletion of your personal data or restriction of processing

• Object to certain types of processing

• Be informed about how your data is used, where it is stored, and with whom it is shared

• Question any automated decision-making processes

• We may not always be able to comply with a request for deletion where we are required to retain data for legal or regulatory reasons, but you may request that processing be restricted.

Requests can be made by contacting us using the details below.

Complaints

We are registered with the Information Commissioner’s Office (ICO) as a Data Controller. If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the ICO.

Contact Details

For any queries regarding data protection, please contact:

John Cairnduff
Royal Exchange Investment Management Ltd
1 King William Street
London EC4N 7AF

IP Addresses and Cookies

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Types of Cookies Used

Essential Cookies
Required for the operation of the website, such as remembering session information or login status.

Performance Cookies
Used to collect anonymous information about website usage to improve performance (for example, website analytics). These do not identify individual users.

Functionality Cookies
Used to remember user preferences (such as language or region) to provide a more personalised experience.

Advertising Cookies
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