Parmenion Capital Partners LLP (“Parmenion”) value your privacy and the security of your data is extremely important to us. This policy sets out where and how Parmenion collects your personal information and how it will be used, as well as your rights over any personal information we hold about you.
In this Policy, we use the terms “we”, “us”, and “our” (and other similar terms) to refer to Parmenion, and “you” and “your” (and other similar terms) to refer to our advisers, clients, service providers, job applicants and website visitors.
We recommend that you read the document carefully and print and keep a copy for your future reference. In providing us with any instruction or other form of contact in relation to your account, we will assume you agree to the uses of your Personal and Confidential Information described in this Policy unless you inform us otherwise in writing.
Parmenion Capital Partners LLP is a registered Data Controller under the terms of the Data Protection Act 1998. Details of Parmenion’s notification to the Regulator for data protection, may be found in the Information Commissioner’s Office Public Register of Data Controllers at www.ico.org.uk under registration number Z9657178.
How to contact us
You can contact us with any queries on the manner in which we collect, store and use Personal and Confidential Information using the details provided below:
By post: 2 College Square, Anchor Road, Bristol BS1 5UE; or
By E-mail: firstname.lastname@example.org
Type of Information we will collect
From our initial contact with you we may collect various Personal and Confidential Information about you. The types of Personal and Confidential Information that we may collect, store and use include:
Advisers using the service: We will collect, store and use the information provided in your initial registration for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. Any further information provided following your initial registration will also be stored as will information relating to any matters of a confidential nature on which you choose to instruct us. The details you provide in relation to your bank account and/or other payment details will be held for the purpose of paying fees or remitting any payments to or from our client accounts.
Clients using the service: We will collect, store and use the information provided in your initial application for the purpose of contacting and corresponding with you. Any further information provided following your initial registration will also be stored as will information relating to any matters of a confidential nature on which you choose to instruct us. The details you provide in relation to your bank account and/or other payment details will be held to allow us to make payments to you as required or request payments as instructed.
Sensitive Information: Parmenion will not request sensitive client information without explaining why we wish to use this information and without your expressed consent. Replies to requests for sensitive information will be voluntary and the data will be processed anonymously and securely. There will be no adverse consequences to you for not providing this information when requested.
Service Providers to Parmenion: We will collect, store and use your contact information and any other details you provide to us by way of post, email or telephone conversation. We may also hold confidential details about any services that you may supply to us, as well as your bank account and/or other payment details for the purpose of paying fees in relation to the services provided.
Website Visitors: We will collect, store and use two specific types of information:-
- Personal information such as your name, address, telephone number and email address as provided by you when you register or make an application.
Job Applicants: We will collect, store and use your contact details, any information you provide in relation to your application and any references provided or obtained, for the purposes of processing your application.
How is your Personal and Confidential Information used?
Depending on the nature of your relationship with Parmenion your information will be used in various ways. Examples of the ways in which we use the Personal and Confidential Information that we collect may include:
Contact and communication: Contact information collected will be used to contact you in relation to service updates that affect you, regulatory updates that affect our services and any additional information in relation to our service that we feel may be of interest to you. We will only contact you in accordance with the contact preferences that you have specified and will not send you marketing communications where you have indicated to us that you do not wish to receive these. Should you wish to amend your contact preferences at any time you can instruct us either by email, post or telephone.
Operation of your account: The information provided during the registration process and any subsequent information you choose to provide will be used to let you have information on the operation of your account including confirmation and investment details and information about important changes to our services.
Advisers: Unless otherwise instructed in writing, we will assume we may use and disclose any personal and confidential information collected during the registration process and any subsequent information collected, in such manner as we believe is reasonably necessary to provide our services.
Clients: Unless otherwise instructed in writing, we will assume we may use and disclose any personal and confidential information collected in such manner as we believe is reasonably necessary to provide our services.
Service Providers to Parmenion: Unless otherwise instructed in writing, we will use personal and confidential information provided to us in such manner as we believe is reasonably necessary to receive their services. The information will also be used for the purpose of arranging and making payments in relation to the services provided to us.
Anti-Money Laundering Regulation Compliance: Depending on the nature of your relationship with Parmenion we may use your personal and confidential information to conduct identity checks as part of our Anti-Money Laundering obligations. Where this is the case you will be notified prior to any check being carried out.
Promotion of Services: Parmenion will not process personal information for the purpose of promoting our services without your expressed consent.
Overseas Transfer of Information: Parmenion will not transfer client information overseas without explaining why we wish to do so and without your expressed consent.
Third Party access to your Personal and Confidential Information
Unless otherwise instructed in writing, where you supply us with personal and confidential information, we will assume that we can disclose this information in such manner as we believe is reasonably necessary to provide our services (as described in our Discretionary Management Agreement and Intermediary Service Agreement), or as is required under applicable law. Examples of the ways in which we use the Personal and Confidential Information that we collect may include:
Anti-Money Laundering agencies: Where we are required to carry out a background identity check as part of our Anti-Money Laundering obligations we may enlist the services of a third party identity verification agency to carry out the checks.
Service Providers: In the course of providing our service we may need to share your personal and confidential information with our third party service providers.
Disclosures required by law or regulation: Under applicable law or regulation we may be required to disclose personal and confidential information, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
Quality assurance and training
In order to ensure we deliver the highest possible levels of service, we may monitor telephone and email communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law. We will at all times continue to protect the confidentiality of your communications in accordance with this policy.
If you or others on your behalf give us any Personal and Confidential Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Policy.
Protecting your Personal and Confidential Information.
We have a number of technical and organisational security measures in place to protect your Personal and Confidential Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.
Parmenion treats all the information it holds with the utmost care and security. Financial details are stored on our system in a secure format and can only be accessed when you sign in using your user name or email address and password. If we contact you we will never ask for your password. We advise you never to enter your account details or password into an email or after following a link from an email.
In order to provide a safe, secure investment environment for all our users and to ensure we only serve genuine clients, Parmenion reserves the right to use reputable security devices and systems as necessary.
In addition to the company’s safeguards your personal data is protected in the UK by the Data Protection Act 1998. This means, amongst other things, that the data we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should, where necessary, be kept up to date and not retained for longer than is necessary. It should be kept securely to prevent unauthorised access by other people. You have the right to see what is held about you and correct any inaccuracies.