Open Account

Privacy Policy

Last revised: 18 January 2025

Introduction

Silverstone Capital Management (“Silverstone,” “we,” “us,” or “our”) is committed to safeguarding and processing personal information (“PI”), including sensitive personal information (“SPI”), in compliance with all applicable privacy and data protection laws within the United Kingdom. This Privacy Notice sets out how we collect, use, and protect your PI, and the rights you have regarding our processing of such data.

References to “you” or “your” refer to individuals whose PI is processed by Silverstone, including individual investors, client employees, officers, or agents (together “Representatives”) with direct or indirect relationships, and beneficial owners of an organisation or entity in connection with:

  • The provision of services to potential and actual clients;
  • Transactions to which we are a party (including those which we effect on behalf of clients);
  • Services provided to us by third-party vendors.

If your contract is with Silverstone Capital Management, the entity you contract with will be the controller of your PI. If you are an investor in a Silverstone-managed product, the associated management company and the managed product, if a separate legal entity, will be separate controllers.

This Privacy Notice outlines the purposes for which we collect, use, and disclose (collectively “Processing”) PI and how it is protected. It also sets out individuals’ rights regarding their PI.

There may be additional terms and conditions that also govern how we collect, use, and disclose your PI, which should be read in conjunction with this Privacy Notice.

Personal Information We Collect

PI refers to information relating to an individual that can be used alone or in combination with other information to identify that individual. PI does not include non-attributable data where the identity of the individual has been removed. SPI includes PI related to race or ethnicity, religious beliefs, political opinions, health data, or biometric data.

The nature of the PI we collect depends on the services provided, applicable laws, and our relationship with you. We categorise the PI we may process as follows:

  • Identification Data: Full name, title, gender, marital status, date of birth, national identification number, passport number, driving licence number, and signature.
  • Contact Data: Personal and business addresses, telephone numbers, and email addresses.
  • Electronic Monitoring Data: To the extent permitted by law, we may record and monitor your electronic communications with us, including telephone conversations, email, and instant messaging.
  • Financial Data: Bank account details, account statements, investment history, and transaction records.
  • Marketing, Behavioural, and Communication Data: Marketing preferences, information about your use of our websites and platforms.
  • Professional Information Data: Job title, business address, and business contact details.
  • Profile Data: Username and password for online services, services requested, marketing communications responded to, and survey responses.
  • Services Data: Payment details and details of services you have provided to us or we have provided to you.
  • Building and Security Data: Records of visits to our premises, CCTV recordings.
  • Technical Data: Your interactions with our online services, IP address, browser type and version, operating system, and browsing activity.
  • Sensitive Personal Information (SPI): In limited circumstances, we may collect SPI such as information about criminal convictions (where legally required), dietary requirements (for event catering), disability status (to provide reasonable accommodations), and political affiliations (for anti-money laundering compliance).

How We Collect Personal Information

We collect PI in several ways, including:

  • Directly from you when you provide it to us in connection with a Silverstone product or service.
  • If you are a Representative of an organisation or entity that is a client or vendor of Silverstone, and that organisation provides us with your PI.
  • Throughout the course of our relationship with you, including when you update your details or request additional services.
  • From publicly available sources, such as social media, professional profiles, and regulatory filings.
  • From third parties such as credit reference agencies and business partners.
  • From interactions with our websites, portals, or online services.

We may also create or derive PI based on your interactions with us, subject to applicable law.

Legal Basis for Processing Personal Information

We process your PI in accordance with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR). The legal bases for processing PI include:

  • Contractual necessity: When processing is required to fulfil our contractual obligations with you.
  • Legal compliance: To meet regulatory and legal obligations, such as anti-money laundering checks.
  • Legitimate interests: When processing is necessary for our legitimate business interests, such as fraud prevention, business analytics, or security purposes.
  • Consent: When we rely on your explicit consent for specific processing activities, such as marketing communications.

How We Use Personal Information

We use PI for the following purposes:

  • To provide investment, financial, and advisory services.
  • To manage accounts and transactions.
  • To comply with legal and regulatory requirements.
  • To protect against fraud and unauthorised access.
  • To analyse and improve our services and digital platforms.
  • To communicate with you regarding updates, marketing, and client support.

Sharing and Disclosure of Personal Information

We may share your PI with:

  • Affiliates and subsidiaries within the Silverstone Group.
  • Regulatory authorities to comply with legal obligations.
  • Third-party service providers for operational purposes, such as IT support and payment processing.
  • Professional advisors, including legal, tax, and audit consultants.

We do not sell your personal information to third parties.

Data Security and Retention

We implement appropriate technical and organisational measures to protect your PI from unauthorised access, disclosure, alteration, and destruction. We retain your data only for as long as necessary to fulfil legal, contractual, and business obligations.

Your Rights

Under UK data protection laws, you have the following rights:

  • Access: Request access to your PI.
  • Correction: Request corrections to inaccurate or incomplete data.
  • Erasure: Request deletion of your data where applicable.
  • Objection: Object to processing based on legitimate interests.
  • Data portability: Request your data in a structured format.
  • Withdraw consent: Withdraw consent for specific processing activities.

To exercise your rights, contact us at privacy@silverstonecapital.com.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Any changes will be posted on this page with an updated revision date.

Contact Us

For any questions regarding this Privacy Notice, please contact us.