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Privacy Policy

Balmoral Asset Management Limited Data Protection Privacy Notice

We need to collect detailed information about your personal and financial circumstances as well as your needs, concerns, objectives, and aspirations so that we can deliver the services described in our Terms of Business booklet.

We take data protection very seriously and treat your confidential personal information with great care. This privacy notice explains how we use the personal information that we collect about you and the rights that you have.

General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is the law on data protection and privacy for all individuals within the European Union. It was brought in to create a consistent set of rules throughout Europe and to update the law to protect your personal data in our modern technology driven world.

The GDPR only allows businesses to process personal data if there is a valid lawful basis. Data processing means collecting, using, disclosing, retaining, or disposing of personal data. Personal data is any data that can be used to identify a person. Sensitive personal data includes information on things like health; racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; certain biometric data; and a person's sex life and/or sexual orientation. Lawful reasons include collecting information that is needed to perform a contract for services or to meet a legal requirement or when an individual gives consent.

What information do we collect about you?

We collect information about you when you engage us to provide financial advice services. This information will relate to your personal and financial circumstances. It may include special categories of sensitive personal data such as information about your health when this is necessary for the provision of our services.

How do we collect information about you?

We collect information from you during our discussions and from letters and e-mails that you send us, as well as any application forms that you complete when we arrange a financial product or service for you. We may also obtain information directly from third parties but only if you have authorised them provide this to us. This might include your accountant, solicitor, employer, or other companies where you have existing financial arrangements.

We may occasionally collect information if you voluntarily complete a client survey or provide other feedback to us. We do not collect personal data through our website and we do not use cookies.

Why do we need to collect and use your personal data?

It is essential for us to collect your personal data so that we are able to perform the contract for services that you have requested and this is the primary lawful basis that we rely on to process your personal data. If we did not collect your personal data we would also be unable to fulfil our legal and regulatory obligations. Where special category data is required we will obtain your explicit consent to collect and process this information.

How will we use the information about you?

We use the information about you to provide you with the services for which you engage us and to ensure that the advice we provide is tailored to your personal circumstances and objectives.

Who might we share your information with?

We may sometimes need to pass your personal information to other organisations so that we can deliver our services to you effectively. This may include third parties that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

We are obliged to put in place controls to prevent our business being used for money laundering and other forms of financial crime and may send your details to third party agencies for identity verification purposes.

When we need to send personal data to a third party we will use appropriate security measures to protect your personal data in transit. We will not share your information for marketing purposes with other companies.

How long do we keep hold of your information?

We will keep your personal information for as long as you are a client of Balmoral Asset Management. We may also keep your personal information for up to 10 years after you cease to be a client to: respond to any questions or complaints; show that we treated you fairly; meet our regulatory requirements; or meet any legal obligations that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. If we do, then we will make sure that your privacy is protected and we will only use it for those purposes.

You have the right to ask us to delete your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above. Where we no longer need your personal information we will dispose if it in a secure manner and without further notice to you.

How can I access the information you hold about me?

You have the right to ask for a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.


We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain to keep personal information protected from unauthorised access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties and similar security protocols. However, due to the nature of the Internet and related technology, we cannot guarantee the security of personal information and Balmoral expressly disclaims any such obligation.


We do not generally contact clients for marketing purposes but there may be occasions where we would like to send you information about our products and services if we think they may genuinely be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email or write to us using the contact details noted below.

Other websites

Our website contains links to other websites. This privacy policy only applies to our website so when you link to other websites you should read their own privacy policies, over which we have no control.

What can you do if you are unhappy with how your personal data is processed? 

You have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113 (local rate).

Changes to our privacy policy

We may need to make changes to our privacy policy and you can check for updates on our website at We will inform you if there are any important changes. This privacy policy was last updated on 1 February 2018.

How to contact us 

Please contact us if you have any questions about our privacy policy or information we hold about you by email at or you can write to us at: Balmoral Asset Management Limited, 18 Rutland Square, Edinburgh, EH1 2BB. Our main telephone number is 0131 220 6950.