Bestinvest Data Privacy Notice
We are now a member of the NatWest Group Plc. More information about the NatWest Group can be found at www.NatWestGroup.com. We respect individuals’ rights to privacy and to the protection of personal information.
The purpose of this Privacy Notice is to explain how we (the data controllers identified below) and other NatWest group companies collect and use personal information in connection with our business. ‘Personal information’ means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).
This Privacy Notice also describes your Data Privacy rights, including a right to object to some of the processing which we carry out.
This Privacy Notice applies to information held about you, or your directors, partners, members, officers, employees, family members, trustees, beneficiaries, powers of attorney, representatives, agents or any other related individual as appropriate. For the purpose of this Privacy Notice, “you” or “your” means you as a user of our website and/or portal, a client, a prospective client and/or any of the above listed individuals as appropriate.
In relation to any personal information we collect about you and any information we process in relation to you, whether you are a client, a prospective client or a contact of a client or a prospective client, the data controller is Evelyn Partners Investment Management Services Limited. Bestinvest by Evelyn Partners is a trading name of Evelyn Partners Investment Management Services Limited.
How do we receive your information?
We may receive information about you from one or more of the following sources:
- Directly from for example:
- When you fill in forms or applications and when you request any products or services
- Through your interactions with us by post, email, telephone, in person, via our websites, secure portals, social media or by any other means
- By the way you use the financial products you hold or take out with us and from your use of our portal
- Through your use of our website:
- When you register with us, share your information with us, use our services, book to attend an event or submit a subscription request (e.g. to receive a newsletter or for marketing information or download one of our guides)
- When you input information in the registration form, or make an enquiry (e.g. by submitting an online enquiry form)
- Through your interactions with our website and mobile applications
- Other Evelyn Partners group companies
- Third parties – including other NatWest Group companies
- Your postings on any other social media applications if your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram give us permission to access information from those accounts
- By completing a survey relating either to your use of our website and/or information posted on the website
- From individuals or third parties acting on your or our behalf (e.g. powers of attorney, solicitors, accountants, financial advisers, platform providers or custodians)
- Marketing and analytics agencies which may receive personal information from other parties and sources including publicly available sources
- Credit reference agencies, identification, verification and screening tools and service providers which receive information from other parties, including publicly available sources
- Our existing clients, connections, affiliates or introducers who refer us to you or you to us
- When carrying out due diligence on an organisation that we intend to acquire, books of business or teams that we intend to acquire where it is not possible to anonymise the information
- From individuals or third parties setting up a trust of which you may be a related party (e.g. settlor, protector, trustee or beneficiary)
What information do we collect from you?
Information we process about you includes (but is not limited to):
- Contact information such as your name, address, email address, and phone number
- Personal identifiers such as personal identification numbers, identity and verification documents
- Financial information, information about your wealth, assets, credit position, the products you have invested in, tax residency, details of any payments you make or receive, household income, employment status and details of your business interests. This includes information about the source of your wealth and source of funds
- Credit worthiness, open-source media including adverse media and potential criminal or regulatory investigations or conviction information resulting from any due diligence checks we will undertake about you
- Information about your family, next of kin or other relationships where necessary
- Information that we need to be able to provide you with help and support if you require it
- Details of third parties connected to you such as your professional advisers (e.g. accountants or solicitors) or connections who you may introduce to us
- Information we obtain from you about the way you do business with us, such as when you:
- use our telephone services,
- visit our website (including IP address(es), device types used and country of access),
- use our client portal and application,
- write to us,
- apply for our products or services,
- enter into competitions or promotions, or
- any other time you contact us, including through social media
- Any other information about you that you disclose to us when completing your Account Application or during the course of our relationship in providing services to you including information about the way you use and manage your account(s)
- At times we may request some specific information related to a particular area. This could be in the form of an industry survey or as part of a marketing campaign
- Information about your visit to our website and mobile applications. This can include the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page
The personal information that we collect about you may also include more sensitive types of information such as your racial or ethnic origin, criminal or alleged criminal offences or your health and wellbeing. Where necessary, we will seek permission from you to collect this type of information. We may process it without your permission when it is lawful for us to do so.
How will we use the information we collect about you?
We will use and share your information with other NatWest group companies to lawfully carry out our business activities as a group of companies (for example, to manage our risk, to meet our regulatory or legal requirements, to support our decision-making processes, to provide you with products or services, to support your welfare needs, for marketing, for internal reporting, or where those companies provide services to us or where we provide services to other NatWest group companies).
We use your personal information for a number of reasons. Under applicable Data Privacy laws, we must have a lawful basis for each use of your information. These are summarised below.
Where necessary to perform a contract with you
- To interact with you before you become a client, for example when you express your interest in our services
- To better understand your personal finances and investment objectives before you become a client so that we can determine the services most appropriate for you
- To provide you with products and services and administer your account as set out in the contract between us
- To manage our client relationship with you
- To communicate with you
Where necessary to comply with a legal obligation
We also process your personal information where this is necessary to comply with our legal obligations, such as:
- To comply with requirements of any applicable legislation and regulation (e.g. Anti-Money Laundering, Anti-Bribery and the Markets and Financial Instruments Directive, Economic Sanctions regimes and any other applicable legislation and regulations that require data retention and/or use). This could result in processing of information about actual or alleged criminal convictions
- For verification purposes (e.g. as required by applicable Money Laundering Regulations and other applicable financial crime legislation). In order to satisfy our obligations under anti-money laundering laws and legislation we are required to verify the identity of all clients and, where relevant, beneficial owners of such clients as well as relevant related parties (for example, if you are a trustee, executor or person of interest under a trust or a partnership, or if you are a company then your directors, officers, shareholders, members and/or trustees and trust beneficiaries as relevant) and other information (including but not limited to details of any nationality, citizenship or rights of residence you hold). We may do this using an electronic verification system that we consider suitable or by asking you for documentary evidence
- We are required under financial crime laws and regulations including the Money Laundering Regulations to verify certain other information about your source of wealth and source of funds in certain circumstances and may ask for documentary evidence or use third party service providers to do so
- The detection and prevention of financial crime
- To prevent fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us
- To take measures to comply with applicable laws and regulations so we can counter the risk of being used for financial crime purposes
- In connection with legal claims, (including disclosure of personal information in connection with legal process or litigation). The latter may include special category information contained in documents, telephone or video recordings
- To fulfil our obligations under any reporting agreement entered into with any tax authority or requirement from the regulator(s) from time to time
- We are required to maintain backups of our systems in the event that live data is lost, unrecoverable or compromised
- To match data and personal information with external sources to ensure the accuracy of data held on our systems
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or to employ you, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
If you fail to provide us with this information that we need to know about you for the above purposes, the consequences are that we may not be able to provide any services to you.
Where it is in our or a third party’s legitimate interests
We may process your information where it is in our legitimate interests to do so as an organisation or where it is in the legitimate interest of another NatWest group company or a third party. We (and other NatWest group companies) may process your information in the day-to-day running of our business as a group of companies, to manage our business and financial affairs and to protect our customers, employees and property. It is in our and their interests to ensure that our processes and systems operate effectively and that we can continue operating as a business.
When we process personal information where it is necessary for our legitimate interests or those of a third party, we ensure your interests and fundamental rights are not overridden by our legitimate interests. These include:
- For security and training purposes
- To monitor or record telephone and video conversations or other communications between you and us. Recordings of telephone and video conversations may take place without the use of a warning tone. We use these recordings (or transcripts of them):
- To check your instructions to us
- To analyse, assess and improve our services to clients
- For training and quality purposes
- To help us investigate any complaint you may make
- As evidence in any dispute or anticipated dispute between you and us
- Where required by applicable regulation and internal policies
- As required in internal investigations
- To ensure that content from our website is presented in the most effective manner for you and for your computer and/or device
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- As part of our efforts to keep our website safe and secure
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
- To send you our newsletter or updates, or to make suggestions and recommendations to you as a use of our website and mobile applications about services that may interest you or them
- To provide you with targeted marketing in relation to our services (unless you indicate at any time that you do not wish us to do so)
- To improve how we interact with you through our website, services, communications and products, and to improve our website user experience (e.g. by enabling user feedback on our website)
- To better understand how clients interact with our secure portal and to further improve it
- To prepare research and anonymised or pseudonymised statistical reports
- To follow up with you after you request information to see if we can provide any further assistance
- To understand our clients’ actions, behaviour, preferences, transactions, savings, expectations, feedback and financial history in order to improve our products and services, develop new products and services, and to improve the relevance of offers of products and services by NatWest group companies
- To develop new products and services, including:
- To analyse our client base in order to establish whether it (as a collective) may be interested in new products and services highlighted by market trends
- To develop new products and services which would be suitable for you based on wider information, including trade frequency, client log ins and account values
- To test software and system improvements by using pseudonymised/anonymised information where possible
- To use artificial intelligence to create efficiencies in our processes, products and/or services, with appropriate safeguards in place to protect your personal information
- To offer you new investment products or financial services that we think may be of interest, based on what we know about you
- To invite you to and manage events and inform you of our and our group of companies’ relevant products and services by email, telephone, letter and other digital methods unless you ask us not to. You can determine the extent of our communication to you through our online portal, the links or instructions in any email we send you, or by contacting us using the details below
- To prepare research and anonymised or pseudonymised statistical reports, including reports on what our typical clients are like, or to build attrition and other effectiveness models
- As part of profiling in order to better understand you, our clients and prospective clients (including the products and services you may be interested in). We may work with third party organisations who provide additional insight, such as information about your wealth, profession and attributes and information about you that is publicly available
- In relation to clients, we may use information we already hold about you in combination with information we obtain with third party organisations and public sources to better understand you and your network
- In relation to prospective clients, we may use information that we obtain or learn from our existing clients and connections (e.g. our clients’ professional advisers) in combination with information we obtain with third party organisations and public sources to identify you, better understand you and to market to you using the methods described above
- To identify potential prospective clients based on what we know about you and your network (where you are a client)
- To gain an understanding of the typical Evelyn Partners client and typical prospective clients in order to identify those who may be interested in our and our group of companies’ services and to tailor our marketing to prospective clients accordingly
- If you are a client, to obtain referrals from you based on your networks and connections and if you are a prospective client, to obtain introductions to you from our clients and other connections
- To ensure that complaints are investigated, and/or to conduct internal investigations
- To prevent or detect abuse of our services or any of our rights, and to protect our (or others') property or rights
- To share information with relevant third parties in the context of a sale, potential sale of a relevant part of our business of our business or restructuring, subject always to confidentiality obligations
- Auditing, assurance and compliance monitoring
- We may also use automated processes whenever we use your information
You have the right to object to processing where it is in our or a third party’s legitimate interests by contacting us at: The Data Protection Officer, Bestinvest, 45 Gresham Street, London, EC2V 7BG or by email: dataprivacy@evelyn.com
With your consent
With your consent, where such consent is required under the applicable regulations and Data Privacy laws, for example:
- To send you information about products and services of ours and other companies in our group which may be of interest to you. You may withdraw your consent or otherwise opt out of receiving this information at any point. You can contact us using the details below, or opt to unsubscribe from marketing communications by using the method contained in any marketing message
- To use images and video content of you for publicity purposes
- Where we have appropriate marketing permissions, we will send you relevant marketing information (including details of other products or services provided by us, other NatWest Group companies or other selected third parties which we believe may be of interest to you), by mail, phone, email, text, our digital services and other forms of electronic communication. We will not share your information with non-NatWest group third parties for their own marketing purposes.
- To collect special category information such as information about your health and wellbeing in order to provide you with help and support if you need it
- For any other purpose where you have provided your explicit consent for such processing
You have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing that we carried out before your withdrawal. If you choose to withdraw your consent, we may not be able to provide you with certain products and services.
Providing third party information to us
Sometimes we receive personal information relating to third parties, for example family members, joint account holders, underlying clients, beneficiaries or those acting on your authority. When this information is provided to us, we expect that you have obtained any necessary permissions from such persons to the reasonable use of their personal information for the purposes referred to in this Privacy Notice.
Cookies
We use cookies and similar technologies on our websites, mobile applications and in our emails. These technologies do many different things, such as letting you navigate between web pages efficiently and remembering your preferences. In emails they help us to understand whether you have opened the email and how you have interacted with it.
Please refer to our Cookie Policy for further details on these technologies, how and where we use them and how you can control them.
Who do we share your information with?
We share your personal information with:
- Other entities in the NatWest Group and Evelyn Partners group (for example, to satisfy our anti-money laundering requirements and account opening)
- Our service providers who act only on our instructions (e.g. service and software providers, IT and hosted services, compliance monitoring services) including their sub-contractors
- Third parties who provide services to you and/or us (e.g. independent financial advisers, platform providers and custodians) including their sub-contractors, your advisers or anyone you have confirmed has your permission to deal with your accounts
- Third parties who assist us with background checks for due diligence purposes and ongoing anti-money laundering and financial crime monitoring as required by law (e.g. Refinitiv)
- Our professional advisors (e.g. suppliers, professional advisors, solicitors, auditors, insurers)
- Parties to a complaint or internal investigation where required
- Website optimisation technologies (e.g. GetSiteControl, HotJar, Appcues, Fullstory)
- Statistics and research providers (e.g. Medallia)
- Websites that help us to identify new prospective clients such as Meta Pixel by Facebook, Google Tag Manager and LinkedIn Insight Tag
- The representatives of a potential buyer, transferee, merger partner or seller if we wish to buy, sell, transfer or merge part or all of our business or assets
- Another client where we collected your information as part of providing services to that client (e.g. relatives, partners or spouses)
- If you are a joint client, to the other client named in any relevant Terms of Business or any other contractual document
- Owners of other linked accounts where you have authorised this
- Prospective clients you refer to us (we may tell them that you referred us)
- Law enforcement agencies or other authorities to comply with legal or regulatory obligations (e.g. HMRC or the FCA)
- Where you are a beneficiary or policyholder in respect of a portfolio, fund or account which is legally owned by a third-party provider, to such third-party provider
Transfers of personal information outside the United Kingdom (UK)
Personal information in our possession may be transferred to countries and jurisdictions outside the UK, including where your investments are held, where transactions are effected, from where you receive or transmit information about your investments, where underlying managers conduct their activities and where some of our service providers operate from or provide out of hours support or development services.
These countries and jurisdictions may have differing (and potentially less stringent) laws relating to the privacy of personal information. They may also have less stringent laws relating to the degree of confidentiality afforded to your information.
Information can become subject to the laws and disclosure requirements of such territories, including disclosure to governmental bodies, regulatory agencies and private persons as a result of applicable governmental or regulatory inquiries, court orders or other similar processes.
If we transfer your information outside the UK, we will make sure that it is done lawfully and will only occur where:
- we have your consent to share, or the transfer is otherwise legally allowed;
- the transfer is to a country that the UK has determined offers adequate data privacy laws; or
- appropriate legal and other safeguards have been put in place in accordance with Data Privacy laws. For further information about the relevant safeguards, please contact Data Privacy using the details provided below.
Security of your information
We will take appropriate steps to store, process and send your personal information securely. Our colleagues are trained on and are aware of their responsibility to maintain your privacy.
We will take appropriate technical and organisational security measures against the accidental loss, destruction, damage and/or the unauthorised or unlawful use of your personal information. These will include ensuring that any service provider provides sufficient security guarantees in relation to any data processing it undertakes on our behalf.
Links
Our website contains links to other websites. Evelyn Partners are not responsible for the privacy policies of third-party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered, via our website.
How long do we keep hold of your information?
We will only hold your personal information for as long as it is required to provide you with the services you have asked for, or for as long as we are legally required under applicable laws. This includes:
- If you are interested in taking out a product or service with us, we will keep the information we have collected between six months and five years from the end of interactions, depending on the stage in the application process you are at (e.g. where you chose not to open your account with us but we have conducted verification of identity and other checks).
- If you are our client, we will keep the information we hold about you as long as you are a client and/or for as long as we are required to by applicable legal and regulatory requirements.
- If you used to have an account with us, or with a company we have acquired or merged with, but your account is now closed:
- For most products and services, your information will be retained for five years following account closure.
- If you have received services from us (or certain companies we have acquired or merged with) your information may be retained for longer periods so that we can respond to questions or complaints you might have, to maintain records according to rules that apply to us (including to ensure you receive no direct marketing from us), or to fight financial crime (including fraud, to manage our financial crime risk and to fulfil our obligations under applicable financial crime laws and regulations).
Fraud prevention agencies can hold your personal information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your personal information can be held for up to six years.
Once we no longer need your personal information, we securely destroy it.
What are your rights in relation to the personal information we hold about you?
This section explains what rights you have under Data Privacy laws. If you want to exercise any of these rights, or if you would like further information about them, you can contact us using the details set out in the ‘Contact Us’ section below.
We will grant your rights request to the extent that, following an assessment of your request, we are allowed and required to do so under Data Privacy laws. If fulfilling your request would unfairly reveal personal information about another person, or if you ask us to delete information which we are required by law or have a compelling legitimate interest to keep, your rights might be limited.
You have the right to:
- ask for a copy of the personal information we hold about you in a written format, free of charge.
- require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information.
- in certain cases, ask us to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.
- object to the processing of your personal information in certain circumstances.
- have the personal information we hold about you erased in certain circumstances, unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations.
- obtain and reuse your personal information for your own purposes across different organisations. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely (where technically feasible), without affecting its usability.
- lodge a complaint about how we collect, process and store your personal information with our Data Protection Officer (details below), or with the supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Contact us
You can contact the Evelyn Partners Privacy Office to exercise any of the rights relating to your personal information as set out above, or if you have any questions or comments about privacy issues, or wish to raise a complaint about how we are using your personal information, by emailing dataprivacy@evelyn.com.
You may also contact our Data Protection Officer by post: The Data Protection Officer, Bestinvest, 45 Gresham Street, London, EC2V 7BG.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will update this document from time to time as required. This Privacy Notice was last updated in June 2026.
Privacy Notices for specific services
If you are a client or prospective client, or a job applicant for Evelyn Partners and want to know more about how we process your personal information, copies of our Privacy Notices for our various service lines can be found here: