This privacy policy explains how GPIM Limited may use any personal information we collect about you or from you.

GPIM Limited will collect and use personal data on the basis that it is in its legitimate interests to do so, as an example to keep records of transactions and to continue providing service to its clients.

GPIM Limited will collect information via our account application process and throughout our relationship with you, in order to comply with regulations. Additionally, for the purposes of ensuring our contract with you is maintained. The provision of your personal data is required to enter into a contract with us, however the provision of information for marketing purposes is voluntary.

Examples of personal data we may hold include:

• Name and contact details
• General Financial Information including risk tolerance and objectives (to enable us to ensure suitability and complete due diligence)
• ID Verification documents

GPIM Limited may record and monitor phone calls made to or by us and store email data to comply with our regulatory obligations. Third party electronic verification may be used by GPIM Limited to comply with our Know Your Client (KYC)/Anti Money Laundering (AML) requirements.

The timeframe personal data is held for may vary subject to legal and regulatory obligations.

If you are not currently a client of GPIM Limited:
Information gathered shall be retained for one year from the date of our last correspondence with you.

If you are currently or have been a client of GPIM Limited:
GPIM Limited shall retain much of your information for 7 years further to the closure of your account, unless regulatory requirements dictate otherwise.

Recordings of telephone conversations shall be retained for 5 years from the date they took place.

If GPIM Limited are asked to remove you from marketing lists, we may retain personal details on an “opt-out” list to ensure that no further marketing action is taken.

To fulfil our contract with you as a client of GPIM Limited, we may share information with third parties, examples of which are detailed below:

• IT providers and services providers in order maintain the provision of our services.
• Appointed auditors, accountants, lawyers and other professional advisers. (Only to the extent that they require access to the information to provide advice)
• ID Verification and fraud prevention agencies and other organisations that allow us to complete the relevant regulatory checks.
• Providers of investments or services we recommend, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, custodians, insurance products or other such products or services. (We may also at times be required to share information with the auditors appointed by the providers of such products or services)
• The Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure.
• If required to do so to meet applicable law, a Court Order or market rules and codes of practice applicable to the circumstances at the time.
• Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law.
• If tax regulations require us to collect information about tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax authority, who may in turn pass this on to tax authorities based in other jurisdictions.

Transfer of data outside of the European Economic Area (EEA):

GPIM Limited will not lend or sell your information to third parties. Your personal information may need to be shared with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA). Where this is required, GPIM Limited will ensure that this in accordance with current data protection legislation by only transferring your data to jurisdictions where there is a European Commission adequacy decision in place. Where this is not the case, GPIM Limited will use model clauses, approved by the European Commission, obliging them to protect personal data in accordance with GDPR.

Marketing:

GPIM Limited may send you information about our products or services by email or by post, which may be of interest to you. If you consent to receive marketing, you may still opt out at any future date.
GPIM Limited may also use your name and address to send invitations to events, or to introduce you to other GPIM Limited products or services which we may consider are of interest to you.

You have a right at any time to stop us contacting you for marketing purposes. If you no longer wish to be contacted, please email us at enquiries@gpimlimited.com or write to us using the address at the end of this notice.

Your rights:

You have several legal rights in relation to personal data that GPIM Limited hold about you, these may include:

• The right to obtain information regarding how we process your personal data and access to the personal data we retain about you.
• The right to request we rectify personal data if inaccurate or incomplete.
• The right to request we erase or restrict the processing of personal data in certain circumstances. (Unless we are legally obliged to retain information)
• The right to complain to the Information Commissioners Office (ICO) if you feel any of your rights have been infringed by GPIM Limited.

More details in relation to your rights in respect of the data we hold relating to you can be found on the Information Commissioner’s website.

Application of these rights may vary according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you due to other regulations. In this instance we will not be able to erase or modify the data.

If you have any concerns about our use of your personal information, please contact the Data Protection Officer for GPIM Limited using the contact details at the end of this notice. You can also contact the ICO in its capacity as GPIM Limited’s supervisory body.

GPIM Limited will endeavour to keep your information accurate, however if at any time after providing information it becomes out of date, then please notify us directly and we shall remove, amend or update the information within a reasonable time frame, in accordance with legislative requirements.

Internet communication, which includes email, is not secure. The protection of data by encryption is possible provided that the encryption method used remains current and the correct procedure for encryption and decryption is followed at all times.

GPIM Limited cannot accept any responsibility for unauthorised access by a third party or for loss, theft or modification of data while it is being sent to us by email. For security purposes we may monitor emails received or issued by us.

GPIM Limited will regularly review our privacy policy. We reserve the right to update this privacy notice at any time and may provide details to you if there are any substantial changes made.

Should you have any questions about our privacy policy or the information we hold about you please contact us at enquiries@gpimlimited.com or by post at the address below:

Data Protection Officer
GPIM Limited
80 Coleman Street
London EC2R 5BJ