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Privacy Notice
This Privacy Notice provides an overview of what to expect when IPS Capital LLP (‘IPS’, ‘we’, ‘our’, ‘us’, the Firm) collects, uses & shares your personal information. This notice applies to the processing of past and present data of prospective, present and past clients (‘you’, ‘your’).
For the purposes of data protection laws and regulation, we are a data controller in respect of your personal data and are responsible for ensuring that we use your personal data in compliance with data protection laws and regulations.
How We Collect Your Data
It is necessary for us to collect your data in order for us to begin discussing our services with you, for legal and regulatory purposes and for marketing. We only ever collect data that is necessary and this will be collected in a number of ways:
• Initial interactions you have with IPS before becoming a client which are necessary for us to record basic personal and contact information. This may be via phone, letter, email or our website, ipscap.com,
• Information provided when you interact with IPS with the intention of using one or more of our services,
• Information provided to IPS as part of the onboarding process when you have decided to use our services,
• Information provided about you by your agents, advisers, consultants, lawyers or other professional experts or other person,
• Information that you provide to IPS relating to other, such as family members, which is necessary for the provision of our services. We accept such information from you on the understanding that you have their consent or are entitled to provide this information to us for our use,
• Information about you that IPS has sourced from a public forum or third party, and
• Any other way that you may interact with IPS for the prospective or actual provision of our services or for marketing purposes.
What Information We Collect
IPS will only ever collect information that is necessary for it to deliver the services that you have selected us to provide. The information necessary for us to deliver our services may include:
• Your name, address and other contact information such as email address and phone number,
• Your date of birth, nationality, tax identification number and other due diligence information,
• Financial information, and
• Personal information and data required for IPS to carry out know your client due diligence and satisfy anti-money laundering laws and regulations that IPS are obliged to comply with. These may include your photo, passport and passport number, driving license and driving license number, and personal billing information.
It may also be necessary for IPS to collect Sensitive Personal Data (a special category of data) about you such as health and medical data. We will obtain your express consent to collect and process this information and it will be clearly explained to you why it is necessary for us to collect this type of data for the delivery of our services.
Prospective Employees – where you contact us about a vacancy or potential vacancy at IPS, we will store certain personal data for the purposes of contacting you in respect of roles available at IPS. A separate Prospective Employee Privacy Notice is available on the Careers page of our website.
Why & How We Use Your Information
The data that we gather is used for the purposes of delivering our services to you. It is necessary for us to obtain the data set out above to ensure that the service delivered is effective, suitable and of the highest quality. Below is a list of the types of activities (including the legal basis for the processing of that information in brackets alongside) we undertake that require us to hold and process your data:
• Interact and enter into discussions with you as a prospective client where you have expressed an interest to do so (Performing a contract),
• Onboard you as a new client and undertake initial client due diligence (Performing a contract),
• Enter into a contract for the delivery of our Investment and/or Wealth Planning Services (Performing a contract),
• Provide continued management of our relationship with you under the contract for our services including handling any concerns or complaints (Performing a contract),
• Liaising with your Custodian to facilitate the link between your investment services and your chosen custodian (Performing a contract),
• Monitor the performance of services and communications (Legitimate interests),
• Outsourcing back office functions to third parties or using third party software to enable the provision of certain aspects of our service such as cloud storage and IT management (Legitimate Interests),
• For legal advice purposes including as par of the reorganisation or sale of part or all of the firm and its business (Legitimate Interests),
• Marketing and assistance purposes where initiated by you, including providing investment market commentary and inviting you to events (Legitimate Interests),
• Undertake necessary checks and monitoring required of us by laws and regulations (Compliance with our legal obligations), and
• Deliver website, newsletters and marketing content that you have agreed to receive (Consent).
Third party vendors may be used to verify client due diligence for identity verification under the Compliance with our legal obligations legal basis. IPS undertake regular due diligence to ensure these vendors have in place rigorous data protection policies and procedures.
Disclosure of Your Information & Transfer Outside the UK
The information that is provided to us is stored electronically on our Servers maintained by Connect Systems, our outsourced IT providers. We also utilise data storage systems including but not limited to; Intelliflo Office, IMIX and Virtual Cabinet, all of whom store our client data for use in the software systems they provide to us. Intelliflo Office, IMIX and Virtual Cabinet are all UK based software providers and we conduct regular due diligence on these providers.
We will only share your personal data where it is necessary for the provision of our services or where we are required to by laws or regulations. We will also share data where you have consented us to do so with third parties related to you such as advisers, lawyers or other professional contacts.
Where we utilise third party vendors for data processing or storage, they may utilise group companies who operate in overseas jurisdictions that do not provide the same level of data protection as the UK. Where this is identified as part of our regular due diligence, we test that there are appropriate measures in place to ensure adequate protection of your personal data and ensure that our contractual arrangements comply with the standards required as set out by the UK Information Commissioner.
Use of Cookies
When interacting with our website, we will collect certain information and data. By using our website, online portal or any other online facility we may provide from time to time, you acknowledge that we may:
• Collect and store information about your device, such as browser type or IP address, for security purposes and to deliver and monitor any online service(s) we provide to you; and/or
• Use and store cookies and similar technologies for security purposes and, where applicable, to monitor and personalise our online services.
Please read our Cookies Policy, available on our website, for further information.
Monitoring of Communications
As required by financial rules and regulations in the UK, IPS records and monitors all forms of communication used by its staff. This will include correspondence between IPS and you. Any communication that you make with IPS will be recorded, stored and used for the following purposes:
• In order to comply with legal and regulatory requirements,
• For training purposes,
• To evidence transactions and client orders, and
• Preventing or detecting crime.
Information and data obtained through the monitoring of communication channels is treated equally with all other personal data collected and stored by IPS.
How long is personal information retained for
All personal data is retained for as long as necessary for its purpose and in compliance with the requirements of both data protection legislation and financial services regulation. Retention periods are set out in the firm’s Terms of Business which you entered into at the point of agreeing to use our services. The firm will retain relevant personal data after our provision of services ceases and for as long as is required and permitted for legal, regulatory, fraud prevention and our legitimate business purposes.
Your Rights
Under UK data protection laws, you have rights as an individual which you can exercise in relation to the information we hold about you. These rights are as follows:
• Right to obtain access to, and copies of, your personal data,
• Right to cease processing of your personal data,
• Right to ask us to cease sending marketing communications,
• Right to require us to correct errors in your personal data,
• Right to erase your personal data,
• Right to restrict our data processing activities,
• Right to withdraw consent for data processing activities,
• Right to receive copies of the personal data we hold about you, and
• Right to require us to comply with your objection to any particular data processing activity.
These rights are not absolute and IPS may be entitled to refuse the request where it is reasonable and allowable for us to do so. If you are not satisfied with our refusal to comply with any of your rights listed above, you have the right to approach the Information Commission. Their contact information is available on their website; www.ico.org.uk.
Changes to this Privacy Notice
IPS may, from time to time, make changes to this Privacy Notice. Any changes will be published on this link and are effective from the date of publication. This privacy notice was last updated in October 2024.
Contact
This privacy notice has been drafted in simple language to provide a general overview and understanding of how IPS collects, stores and uses your personal data. A more detailed overview is available in our Privacy Policy which is available on request. Should you have any question about this Privacy Notice or how IPS collects, stores or uses your personal data please contact our Data Protection Officer, Richard Page, using one of the options below:
Email: rpage@ipscap.com
Post: Richard Page
IPS Capital LLP
4 Eastcheap
London
EC3M 1AE