Privacy Notice

Bellecapital UK Limited (“Bellecapital”) is committed to protecting your personal data and recognises that it is important for you to know how we deal with your personal data.

Our Privacy Notice contains important information about what personal data we collect; what we do with that data; who we may share it with and why; and your choices and rights when it comes to the personal data you have given us.

Data Controller
Bellecapital UK Limited is registered as a data controller with the Information Commissioner's Office (registration number: ZA143502). You can access Bellecapital UK Limited's register entry at:

https://ico.org.uk/about-the-ico/what-we-do/register-of-fee-payers/

Contact details for Bellecapital's Data Protection Officer are:

The Data Protection Officer
Bellecapital UK Limited
19 Berkeley Street
London W1J 8ED

Email: info@bellecapital.com

Personal data we collect
To provide the highest quality service and advice, Bellecapital UK Limited is required to obtain certain personal data about you and our ability to provide you with comprehensive financial advice is dependent on us obtaining certain personal data about you.

Bellecapital UK Limited may request personal data from you which will generally comprise, but not be limited to the following:

- Personal details e.g. name, address, contact details (phone, email), marital status, date of birth;
- Employment details and employment history;
- Details of your financial needs and objectives;
- Financial details including your assets and liabilities (both actual and potential), income and expenditure;
- Details of your current investments, insurance cover and superannuation including amounts, investor numbers and bank account details;
- Details of your personal goals and objectives; Details of your investment preferences and aversion or tolerance to risk;
- Taxation information including your tax file number;
- Information you may provide us about other people e.g. joint applicants or beneficiaries including status of wills, and powers of attorney;
- Information about your contact with us e.g. meetings, phone calls, emails / letters; and
- Information on children e.g. where a child is named as a beneficiary, we will collect and use only the information required to identify the child (such as their name, age, gender).

We DO NOT collect Sensitive Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health or sexual preferences.

How we collect your data
In most circumstances, the data that we hold about you has been provided to us by you or under your authority. Where you provide us with personal data relating to others (for example, your nominated beneficiaries and dependents), we understand that you are authorised to provide that information to us, and that you have provided this Privacy Notice to them as appropriate.

We may collect your personal data directly from you from a variety of sources, including:
- an application form for a Bellecapital service
- phone conversations with us
- emails or letters you send to us
- meetings with one of our Investment Managers
- our online services such as our website and through the Bellecapital App

What we do with the data we hold
We will process your data for limited purposes that will include: responding to your requests; providing our services in accordance with our terms and conditions; developing and improving our services to you and to other customers; and informing you by letter, telephone or electronic means (including email) about our services that may be of interest to you. You may tell us if you do not wish to receive marketing material by emailing us at info@bellecapital.com.

Lawful basis for processing data
We take your privacy seriously and we will only ever collect and use data which is personal to you where it is necessary, fair and lawful to do so.

Under the General Data Protection Regulation (“GDPR”) the lawful bases we rely on for processing data are below. At least one of these must apply when we process personal data:

- Consent: We have been given clear consent for us to process data for a specific purpose
- Contract: To perform any contractual obligations we have with you or to exercise our rights under the terms and conditions in place between you and us
- Legal Obligation: Processing data is necessary for us to comply with the law (this includes a regulatory obligation or any agencies for the prevention and detection of crime)
- Vital Interests: Data processing is necessary to protect someone’s life
- Public Task: Data processing is necessary for us to perform a task in the public interest
- Legitimate Interest: Data processing is necessary for our legitimate business interests (including our interests in operating our services in an efficient, effective and high quality manner, and our interests in marketing and promoting our services (unless you have opted out of this, as above).

Data sharing
To ensure that Bellecapital UK Limited provides you with efficient and effective financial services we will sometimes need to share your data with our partner organisations that support the delivery of the service you may receive, for example:

- Across the Bellecapital Group
- Any financial institution (including fund managers, share brokers, clearing and settlement providers) with whom you will be investing, are invested in or have previously invested in.
- Government departments e.g. HMRC Tax office,
- Your Professional Advisors such as solicitor, or accountant;
- Your Executor or Power of Attorney if required;
- Any other external party as authorised by you at the time.

We will only ever share your data if we are satisfied that our partner organisations have sufficient data protection measures. The organisations receiving this data are not permitted to use your data for any purpose other than for the specific purpose that it was provided. We will never share your data for marketing purposes.

Details of transfers to third country and safeguards
Your personal and sensitive data will be stored and processed on servers based within the European Economic Area (EEA). This data may be shared for the purpose of registering as a foreign entity/setting up offices in other jurisdictions, including governmental authorities in such countries. We maintain the highest regulation to ensure the data being sent remains secure. Where third party custodians are used, we ensure that they have equivalent measures in place to protect your data in the same way that we do.

Data storage
Bellecapital UK Limited recognises how important the privacy of your personal data is to you and has arranged to store such data in a secure environment. Your personal data may be stored both in hard copy and/or electronically. At all times your personal data is treated as confidential and sensitive. We restrict access to your data by maintaining login and password control on all computer systems and have in place secure, lockable filing cabinets to store hard copies of personal data.

Data retention
We will keep your personal data only where it is necessary to provide you with our products or services while you are a client. We may also keep your data after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your data for these purposes will vary depending on the obligations we need to meet. Once your data is no longer needed it will be securely and confidentially destroyed.

Your data protection rights
You have certain rights under the GDPR, which are:

- The right to be informed about the collection and use of personal data;
- The right of access to any personal data Bellecapital UK Limited holds about you;
- The right of rectification which requires us to correct inaccurate or incomplete data about you if it is incorrect;
- The right to erasure which requires us to delete your personal data in certain circumstances;
- The right to restrict processing which requires us to restrict our data processing activities in certain circumstances;
- The right to data portability which requires us to provide you with your personal data in a structured, commonly used, machine readable form;
- The right to object, on grounds relating to your particular situation, to your personal data being used in particular ways (e.g. profiling, direct marketing or research purposes).

Where our processing is based on your consent (which will be rarely be the case as per the above), you may withdraw that consent without affecting the lawfulness of our processing of your data based on consent before its withdrawal.

If you would like to exercise any of these rights, please contact the Data Protection Officer in writing using the contact details above. Please note that these data protection rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

Access to your personal data
You can request details of the data we hold about you at any time. This is called a Subject Access Request.

You can make a Subject Access Request by contacting our Data Protection Officer. You are generally entitled to access the data we hold about you unless there are certain legal reasons that prevent you from doing so. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. We endeavour to respond to your request as soon as practical (usually within one calendar month) and we may also ask you to identify yourself to our satisfaction.

There are certain conditions under which we may refuse you access to your personal data, such as when your request may unreasonably impact upon another person’s right to privacy. If we entitled or obliged to refuse to give you access to your data, we will tell you and provide reasons for our decision.

Changes to our privacy notice
We may need to make changes to our Privacy Notice, so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed, we will contact you to let you know. This Privacy Notice was last updated in January 2024.

Complaints
If you are not satisfied with how we are processing your personal data, you may have the right to complain to the Information Commissioners Office (‘ICO’). You can find out more about your rights under data protection legislation from the Information Commissioner's Office website at: www.ico.org.uk