Pacific Capital Partners Limited, trading as Pacific Asset Management (PAM), values your right to privacy and security and therefore treats Personal Data, as defined in the General Data Protection Regulation (GDPR) as private. We are committed to protecting the privacy of any information we hold about you and we have summarised our policies regarding the collection, use and transfer of your personal data, the security measures we employ to protect such data and your rights and choices with regard to access or use of such data.
In adopting this Notice, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take appropriate and reasonable technical and organisational steps to prevent unauthorised access to, or disclosure of your personal data.
In keeping in line with our commitment to providing you with secure access, this Notice may be varied from time to time and we would advise that you check it regularly.
Pacific Capital Partners Limited (“we”, “us” or “our” in this Privacy Notice) is the data controller and is responsible for your personal data. We are registered on the Information Commissioners – Data Protection Public Register and our registration number is: ZA565204
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Types of data we have, how we collect it and why we have it
We may collect and process the following personal data about you:
- Information that you provide to us directly. This includes (by way of a non-exhaustive list) basic personal data such as first name; family name; job title; company name; company email address; business phone number; business address; city; postcode; and country; identity/address documents.
- Information that we collect or generate about you. This includes (by way of a non-exhaustive list):
- a file with your client records and contact history to be used for enquiry purposes;
- details of site and marketing/communication preferences.
- Information that we collect or generate about you. This includes (by way of a non-exhaustive list):
- Information we obtain from other sources indirectly. This includes:
- Anonymised data. In addition to the categories of personal data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual.
Special Categories of Personal Data. We do not collect any Special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Under the GDPR, the lawful basis we rely on for processing your personal data are:
- We have your consent. You can withdraw your consent at any time using the contact details below;
- We need to use the information to perform a contract with you where we maintain a business relationship with you;
- We need to use the information to comply with our legal and regulatory obligations and /or in connection with any legal claims;
- We have a legitimate interest where we are providing you with information about our products or services.
How we use and process the data we collect
Personal data is used as is appropriate in the normal course of business to provide the products and services you have requested, for the purpose/s for which we tell you that such information has been collected and for other legitimate purposes permitted by applicable law.
While we will retain certain personal information we have collected only for as long as necessary given the purpose for which it was collected, we may store information for the purposes of investment transaction processing and administration, to monitor our site and to communicate with you directly, and you expressly consent to this. We will also be able to tailor our content and give you information that is relevant to you. If you advise us that you do not want us to use this information as a basis for further contact, we will respect your wishes.
PAM will disclose information when required to do so: (1) by a court order; (2) by any regulatory authority and the regulators they appoint for the various financial sectors; (3) in order to comply with PAM’s legal and regulatory obligations in terms of any legislation or regulation applicable to PAM and its business dealings (including fraud prevention and anti-money laundering); (4) in order to exercise, protect and defend PAM’s rights and property (including PAM’s intellectual property); (5) in order to conduct required credit or background checks; (6) on the reasonable request of a fund in which you have invested; and (7) in the public interest.
You acknowledge that we may disclose your personal data within the Pacific Investments Group and you expressly consent to this.
We will not disclose or transfer personal data to third parties for the purposes of marketing.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the relevant rules, where this is required or permitted by law.
PAM is a global business, with customers and our operations spread around the world. As a result, we collect and transfer certain personal data on a global basis. That means that we may transfer your data outside the European Economic Area (EEA).
Where we transfer your personal data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:
- the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on ‘model contractual clauses’ approved by the European Commission, obliging them to protect your personal data;
- in other circumstances the law may permit us to otherwise transfer your personal data outside Europe.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe by contacting us.
Data security and integrity
PAM is committed to keeping your information secure and confidential.
PAM is dedicated to being at the forefront of information security to protect the privacy and confidentiality of your personal information. We take every reasonable step to protect your personal information, including the use of encryption technology. We can, however, not guarantee the security of any information you transmit to us electronically and you do so at your own risk.
We implement strict security standards and procedures in order to help prevent unauthorised access to your personal information. Only authorised PAM employees or agents will have access to your information, and all of our employees, service providers and marketing partners are held to stringent standards of privacy and security and are bound by confidentiality agreements.
We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process.
To the extent that we disclose personal data to approved third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.
How long we keep your data
We will only keep the data collected about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.
PAM reviews the data it holds on a regular basis and your information will be securely destroyed if it is no longer required for the purpose(s) for which it was obtained.
Your data protection rights
You have the right to:
- access your personal data; you can ask us for copies of your personal information;
- have it updated or corrected if it is inaccurate or incomplete;
- request that we restrict its processing or remove your data entirely from our systems. When asked to remove a record from our database, PAM will retain minimal information to ensure we do not contact you or collect such information again in the future.
- object to the processing of your personal data in certain circumstances;
- have the personal data we hold about you erased in certain circumstances. If you would like us to delete all your related data, or if you prefer that we unsubscribe you from our marketing mailing list, please specify your preference by contacting us at [email protected]
- ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us using the details below if you wish to exercise any of your rights relating to your personal information.
Changes to the Privacy Notice
PAM reserves the right to modify or amend the Privacy Notice at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Notice, those changes will be posted here.
By using the site, you are accepting the terms of this Privacy Notice and you consent to the collection, processing, further processing and storage of your personal information as contemplated in this Privacy Notice.
Date of last review: January 2023
Cookies are small text files consisting of encrypted information assigned to a computer’s browser, which is given to your browser by our web server when you visit our website. This data is stored on your browser. The cookie is sent back to our web server each time you visit our website. Cookies are not computer programs and do not run on a computer like programs do. They cannot gather information or function on their own. They cannot collect any personal information about you or your machine and cannot gather data or information about what you do on the Internet. Cookies merely enable us to provide a more valuable online experience to you. While you can set up your Internet browser to disable cookie technology, we do not recommend that you do this since some parts of this website may not function properly, or at all.
Monitoring the site
We gather and analyse information on our visitors’ routine visits to this site. We use this information to monitor which areas of the site are most frequently visited in order to assist us to continue developing a value-added service. This information is pooled so that individual personal information, behaviour or patterns cannot be identified.
Use of IP address
An IP address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses or the location of computers on the Internet.
We collect IP addresses for the purposes of system administration and to audit the use of the website. We do not ordinarily link IP addresses to personal data, which means that your session may remain anonymous. However, we cannot guarantee that this will always be the case, as it may be necessary to identify a particular user when it is necessary to enforce compliance with the Privacy Notice or to protect our website, its users or other interests.
Links to other sites
When you are using the website, you could be directed to other websites that are beyond our control. These other web sites may send their own cookies to you to collect data or solicit personal information. We do not control the privacy policies of those third party web sites.
Information contained on the website is updated on a regular basis. Due to the nature of the information posted, it becomes outdated rapidly. Users are therefore cautioned to independently verify the correctness of information contained on the website that may have become outdated.
Pacific Capital Partners Limited accepts no liability of any sort resulting from reliance being placed upon outdated information contained on the website by any user or other person.
Whilst every effort is made to represent accurate financial and technical information on an ongoing basis, inadvertent errors and typographical inaccuracies may occur. Information, laws, rules and regulations may also change from time to time. Information contained on the website is therefore made available without any express or implied representation or warranty whatsoever, and PAM disclaims liability for any expenses incurred, or any damage, claims or costs sustained by users arising from the reliance being placed on the use of links, services or any information or representations contained on the website.
Our contact details
If you have any questions about this Privacy Notice, please contact us at:
Tel : +44 (0)20 3970 3100
Email : [email protected]
Pacific Asset Management
1 Portland Place
How to complain
You can contact us at the above details if you wish to raise a complaint.
You can also complain to the Information Commissioners Office if you are unhappy with how we have used your personal information.
Their contact details are:
Information Commissioner’s Office
Helpline number: 0303 123 1113
Pacific Asset Management is a trading name of Pacific Capital Partners Limited,
authorised and regulated by the Financial Conduct Authority.
© 2018 Pacific Asset Management LLP All rights reserve