Privacy Policy

Under data protection laws and regulations in the territories where we operate, we have a legal duty to protect any personal data we collect from you.  We are committed to protecting your information and strictly adhere to the requirements of such data protection legislation.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This Privacy Policy is issued on behalf of Turner Smith Partners and references to “Turner Smith Partners”, “we”, “us” or “our” in this Privacy Policy are references to the relevant company in the Turner Smith Partners Group, responsible for processing your data.

What is personal data?​

Personal data means any information relating to an individual person who can be identified, directly or indirectly, by reference to a particular identifier, for example, name, email address, date of birth.

What personal data do we collect?

On our contact page, when you make a general enquiry, we ask you for your full name, telephone, email address, a message, your company.  

We may also collect personal data regarding your preferences where it is relevant to services that we provide.

How is your personal data collected?

We use different methods to collect data from and about you, including the following:

  • When you or your organisation seek investment from us;
  • When you or your organisation subscribe to our services or publications or sign up to receive our marketing communications or to attend a Turner Smith Partners event;
  • When you provide us with feedback or use the ‘contact us’ section of our website;
  • When you or your organisation interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns, which we may collect using cookies or similar technologies; or
  • When you or your organisation offer to provide services to us.

What is the basis for using your data?

We will only use your personal data when we are allowed to do so by law.

The lawful grounds on which we will use your data, most commonly, will be in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
  • Where we need to comply with a legal or regulatory obligation (e.g. anti-money laundering regulations;
  • Where we provide you with services and need to perform our contract with you; or
  • Where you have expressly given us your consent.

For which purposes will we use your personal data?

Where you have provided us with consent (or we have other lawful grounds), we may keep you up to date with any announcements, market commentary, relevant sector briefings or details of events.

How long will we keep your personal data?

We will retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

When it is no longer necessary for us to retain your personal data we will delete or destroy it.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

Will we share your personal data?​

We may share your personal data within Turner Smith Partners on a confidential basis where necessary for the purpose of us providing our services to you.

We may need to share your personal data with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also share your personal data with our financial auditors, our insurers and insurance brokers and other professional advisers in the course of the advice we provide to you. 

We do not sell, rent or exchange your personal data with any third party for commercial reasons.

How do keep your personal data secure?

We will take appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.  These measures include information security processes as well as organisational policies and procedures.

What are your rights?

Subject to certain legal conditions, you are entitled at any time to ask us for a copy of the personal data which we hold about you.  You are also entitled to ask that any information we hold about you is updated or rectified and to object to or restrict our using your personal data.  You can make any of these requests free of charge by contacting us at; however, we reserve the right to charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive.

If you feel that we have not been able to resolve your query or concern you may raise a formal complaint.  If you remain unsatisfied with our response, you may take your complaint to the relevant privacy regulator, which is the Information Commissioners Office (ICO) in the United Kingdom.  Further information is available on the ICO website or by telephone on 0303 123 1113.