Privacy Notice

This Privacy Notice ("Notice"), together with our website terms of use and any other documents referred to in it, sets out the types of personal information Panmure Liberum collects from you, how we collect and process that information, who we may share it with in relation to the services we provide and certain rights and options that you have in this respect.

This Notice is addressed to individuals outside of our organisation, including visitors to our website, clients and potential clients (and their associates), contacts at firms we deal with in a non-client capacity, suppliers, and visitors to our offices. This Notice applies to personal data provided directly to us by individuals or obtained from a third party. This Notice does not set out personal data processed for internal purposes, as that information is set out in our Internal Privacy Policy.

We are committed to the protection of personal data and to fair and transparent processing in accordance applicable data protection and privacy legislation, including to the ex­tent applicable, the Data Protection Act 2018, the General Data Protection Regulation (“GDPR”), and the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (in each case as amended, supplemented or replaced from time to time) (“Data Protection Legislation”). If you have any questions about this Notice, you can contact our Legal Team via email at [email protected]

Who is responsible for your personal data?

Panmure Liberum Limited (“Panmure Liberum”, “we”, “our”, “us”) is an independent investment bank incorporated in England and Wales (no. 04915201) with its registered address at Ropemaker Place, Level 12, 25 Ropemaker Street, London EC2Y 9LY. Panmure Liberum is authorised and regulated in the UK by the Financial Conduct Authority (FCA Register number 403721).

Panmure Liberum is the data controller responsible for the personal data that you provide to us.

Personal data we collect about you:

Personal information is information which can be used to personally identify you. We collect and process different types of personal information, depending on the nature of our relationship. The following is a non-exhaustive list of personal data we may collect and process about you:

• Identity and Contact Data, including personal biographical information (name, gender, nationality, date of birth, marital status, passport number), contact data (address, email address and telephone number), professional data (employment history, educational or professional background, tax status, employee number, job title and function) and other personal data required for us to perform our services to our clients or maintain our client relationship management system;
• Business Information, including information provided in the course of the contractual or client relationship between you or your organisation and Panmure Liberum or otherwise voluntarily provided by you or your organisation, including any ‘Know-Your-Client’ information we may collect;
• Financial Data including bank account details or any other payment and billing data;
• Services Data including written communications with you (via post or email), telephone call recordings and video meeting recordings;
• Profile and Usage Data, including your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s) including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). To learn more about our use of cookies or similar technology please check our cookies policy;
• Technical Data, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform. To learn more about our use of cookies or similar technology please check our cookies policy set out below;
• Physical Access Data, relating to details of your visits to our premises; and
• Sensitive personal data: in the course of our client services, we may be required to collect and use sensitive personal information relating to you (that is, information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences).

We may use such data for the following purposes:

• to contact and interact with you to perform our obligations under our contract with you or your organisation;
• to carry out our legal and regulatory compliance obligations including anti-money laundering and terrorist financing checks and related actions which we consider appropriate to meet any legal or regulatory obligations imposed on us from time to time, or where the processing is in the public interest, or to pursue our legitimate interest to prevent fraud, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions on an ongoing basis, in accordance with our anti-money laundering procedures;
• to monitor and record calls and emails to comply with our legal and regulatory obligations and ensure compliance with our policies and standards and for investigation and crime prevention purposes, and to enforce or defend our legal rights, or pursue our legitimate interests in relation to such matters;
• to report tax related information to tax authorities in order to comply with our legal obligations;
• to monitor and record calls for quality, training, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
• to manage our relationships with you, develop and improve our business and services, maintain and develop our IT systems, manage and host events and to administer and manage our website, systems and applications;
• to manage access to our premises and for security purposes;
• to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
• to provide you with marketing information about our products and services that may be of interest to you as well as informing you of any changes to our service; and
• for any other purposes relating or ancillary to any of the above or any other purposes for which your personal data was provided to us.

Lawful grounds for using your data:

When processing your data for the purposes listed above, we rely on one or more of the following grounds in compliance with the Data Protection Legislation:

• you or they have explicitly agreed to us processing such information for a specific reason;
• the processing is necessary to perform the agreement we have with you or them or to take steps to enter into an agreement with you or them;
• the processing is necessary for compliance with a legal obligation we have; or
• the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:

(i) to ensure that our matters are well managed;

(ii) to prevent fraud;

(iii) to protect our business interests;

(iv) to ensure that complaints are investigated;

(v) to evaluate, develop or improve our services; or

(vi) to keep our clients informed about relevant services.

In relation to any processing of special categories of data, we will generally rely on obtaining specific consent in order to process such information, although it may be necessary for us to use certain information in order to comply with our legal obligations as a regulated entity (such as in relation to an alleged offence). Where you have consented to our processing of such information (including special categories of personal data) you may withdraw such consent at any time, by contacting us using the contact details set out below. Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described above is applicable.

Automated Processing:

We do not carry out automated decision-making or profiling in relation to our clients.

Information about other people

If you provide personal data to us about any person other than yourself, you shall ensure that you have provide all necessary information to the relevant individuals (known as “Data Subjects”) about our use of personal data. You may refer Data Subjects to this Notice.

Disclosure of your personal data

In order to be able to service our clients’ needs to the best of our ability, we may share any information you provide to us at the Panmure Liberum Group entities and their agents, counterparties and support service or data providers, wherever located.

We may also provide third party service providers access to client information where they support or provide services to us. We will ensure that if we share information with, or provide access to, third party service providers, any such disclosures or access is at all times in compliance with Data Protection Legislation.

If you have provided information to Panmure Liberum Group entities, those entities may also share that information with us.

We may disclose your personal data as follows:

• to our affiliated companies for the above mentioned purposes;
• to companies providing services for money laundering and terrorist financing checks and other fraud and crime prevention purposes and companies providing similar services;
• to courts, law enforcement authorities, regulators, governmental officials and other bodies as required by law or as requested;
• to third party system providers in order to process the personal data for the above mentioned purposes;
• to our and our affiliated companies’ accountants, auditors, legal advisors and any other professional advisors, subject to confidentiality obligations;
• third parties involved in assisting with marketing communications or organising events and seminars and;
• if we have collected your personal data in the course of providing services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing those services; and to purchasers of the whole or part of our business or on any merger or group reorganisation.

The disclosure of personal data to the parties noted above, may include the transfer of personal data outside the United Kingdom (“UK”). Such countries may not have the same data protection laws as your country. If we do transfer personal information to these countries when it is necessary for the services we provide to you, or it is necessary for the establishment, exercise or defence of legal claims or subject to safeguards including standard contractual clauses to ensure that your personal information will receive a similar degree of protection when it is outside of the UK.

Please contact our Legal Team for more information.

Security of your personal data

We have policies, procedures and training in place in respect of data protection, confidentiality and information security. We regularly review such measures with the objective of ensuring their continuing effectiveness.

Failure to provide personal data

Where we need to collect personal data to comply with our legal and/or regulatory obligations or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

Your Rights

In accordance with Data Protection Legislation, you have a number of rights concerning the way that we use your information, those include:

• Your right to be informed

You have the right to be informed about the collection and use of your personal data. This Notice sets out the purpose for processing your data, the retention period for that data and who it will be shared with.

• Your right to access

You have the right to access and request a copy of your personal data and how we process it.

• Your right to rectification

If the data we hold about you is inaccurate or incomplete, you have the right to rectify or update it. To do so, please either contact your usual Panmure Liberum contact or otherwise contact the Legal Team.

• Your right to erasure

You may request that we delete or remove your personal information in some circumstances, if we no longer need it or you exercise your right to withdraw consent.

• Your right to restrict or object

You have the right to object to, or request the restriction or suppression of your personal data. Where we process your personal data based on your consent, you have the right to withdraw the consent at any time by contacting our Legal Team.

You also have the right to request that we cease or stop marketing communication by one, some or all channel by contacting our Legal Team or clicking “unsubscribe” for the relevant communication.

• Your right to data portability

You have the right to obtain and reuse your personal data for your own services, or have the personal data processed by use transferred to another party.

• Your rights in relation to automated decision making including profiling

You have the right not to be subject to a decision when it is based on automatic professing, including profiling, if it affects you, unless, such profiling is necessary for us to enter into a contract with you.

You may exercise the rights set out above by contacting our Legal Team. In the event you wish to make a complaint about how we process your personal data, please use the contact details below and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to lodge a complaint about our use of personal data to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements and, where required for Panmure Liberum to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.

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 the applicable legal requirements.

Sending you marketing information

Panmure Liberum may use your personal data from time to time to inform you by letter, telephone, text (or similar), messages, email or other electronic means, about similar services (including those of third parties) which may be of interest to you or them.

You may, at any time, request that we cease or do not send such information by one, some or all channels, by contacting us using the contact details set out below or by clicking “unsubscribe” for the relevant communication.

Contact Us

Questions, comments and requests regarding this Notice should be sent to our Legal Team by:

• Sending an email to [email protected]; or
• Writing to us FAO Legal Team, Panmure Liberum Limited, Ropemaker Place, Level 12, 25 Ropemaker Street, London EC2Y 9LY

Changes to our Privacy Notice

We reserve the right to update and amend this Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Notice in the future will be posted on this page and, where appropriate, notified to you by email.

Please check back frequently to see any updates or changes to our Notice.

Last Updated

This privacy notice was last updated on 18th March 2024.

We will update this Notice from time to time and you should review it whenever you visit our website or before providing us with any personal information.