Privacy Policy
How we collect, use, share and protect your personal data through our website and related enquiry processes.
Quorum Capital Limited (“Quorum Capital”, “we”, “us” or “our”) is committed to protecting your personal data and handling it in a lawful, fair and transparent manner. This Privacy Policy explains how we collect, use, share and protect personal data through our website and related enquiry processes.
We process personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations, where applicable.
1. Who We Are
Quorum Capital Limited is a discretionary fund manager authorised and regulated by the Financial Conduct Authority (FCA Reference No. 601037) and registered in England and Wales (Company No. 08355499). Our registered office is 27 Old Gloucester Street, London, England, WC1N 3AX.
We provide discretionary investment management services, including risk-graded model portfolio services, to FCA-authorised financial advisers and their clients. Quorum Capital Limited is the controller for personal data collected through this website and related enquiry processes.
2. Personal Data We Collect
Through our website and related enquiry processes, we may collect and process the following personal data:
- Contact information: name, email address, telephone number and the content of your message or enquiry.
- Professional and firm information: firm name, job title, FCA authorisation status, FCA reference number, platform, AUM band, enquiry type and other information relevant to adviser or platform enquiries.
- Investor referral information: postcode or approximate location, contact details and any information you provide when asking us to identify financial advisers who use Quorum Capital portfolios.
- Correspondence records: records of emails, forms, calls or other communications you have with us.
- Technical data: IP address, browser type and version, time zone, browser plug-in types and versions, operating system, platform and other technology identifiers on the devices used to access this website.
- Usage data: information about how you use our website, including pages visited, time spent on pages and referring URLs.
- Cookie data and preferences: as described in our Cookie Policy.
- Marketing preferences: whether you have agreed to receive updates, information or other communications from us and any opt-out preferences.
We do not intentionally collect special category data, such as health information, through this website. We do not collect payment card details through this website. Please do not include sensitive personal data in website forms unless it is strictly necessary for your enquiry.
3. How We Collect Personal Data
We collect personal data in the following ways:
- directly from you when you complete an enquiry, contact, investor referral or other website form;
- directly from you when you contact us by email, telephone or other means;
- automatically through cookies and similar technologies when you browse our website, subject to your cookie preferences;
- from third-party service providers, such as analytics providers, where such data is generated from your use of our website and where the relevant consent has been given.
4. How We Use Your Personal Data
We may use personal data collected through this website and related enquiry processes for the following purposes:
- to respond to enquiries submitted through contact, adviser, investor referral or other website forms;
- to assess adviser and platform enquiries and provide information about our services where relevant;
- to provide details of financial advisers who use Quorum Capital portfolios where an investor has requested this;
- to manage business relationships with advisers, platforms, service providers and other professional contacts;
- to improve our website, website content and user experience through analytics;
- to send marketing communications, updates or other information where permitted by law;
- to comply with legal, regulatory, FCA, audit, compliance and record-keeping obligations;
- to protect our website, systems, business and legal rights.
We do not use personal data collected through this website for automated decision-making or profiling that produces legal or similarly significant effects.
5. Legal Basis for Processing
The table below summarises the main lawful bases we rely on when processing personal data collected through this website and related enquiry processes.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Responding to website enquiries | Contact details, professional details and enquiry content | Legitimate interests in responding to enquiries and managing business relationships |
| Assessing adviser, platform or professional enquiries | Firm name, job title, FCA status, FCA reference number, platform, AUM band and enquiry details | Legitimate interests in assessing whether and how our services may be relevant |
| Providing adviser details to investors who request them | Name, contact details, postcode or approximate location and enquiry content | Consent where we share your details with selected advisers; legitimate interests where we use the information internally to respond |
| Marketing communications and service updates | Contact details, professional details and marketing preferences | Consent where required; legitimate interests where business-to-business communications are permitted and your rights do not override those interests |
| Website analytics and improvement | Technical data, usage data and cookie data | Consent for non-essential analytics cookies and similar technologies |
| Website security and operation | Technical data, usage data and essential cookie data | Legitimate interests in operating, securing and maintaining the website |
| Compliance, audit, regulatory and legal record keeping | Relevant enquiry, relationship, correspondence and technical records | Legal obligation and legitimate interests in demonstrating compliance and protecting legal rights |
6. Legitimate Interests
Where we rely on legitimate interests, we consider whether our interests are overridden by your rights, freedoms or interests. Our legitimate interests include operating a regulated investment management business, responding to enquiries, managing professional relationships, maintaining website security, improving our services and demonstrating compliance with applicable legal and regulatory obligations.
7. Marketing Communications
We will only send marketing communications where permitted by law. Where consent is required, we will ask for it separately and you can withdraw it at any time. You can opt out of marketing communications by using any unsubscribe option provided or by contacting us using the details at the end of this policy. We may retain a suppression record to ensure that we do not contact you again after you have opted out.
8. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies. Essential cookies are used where necessary for the website to function. Non-essential cookies, including analytics cookies such as Google Analytics 4, are used only where the required consent has been obtained. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.
9. Sharing Your Personal Data
We only share personal data where necessary and proportionate. We may share personal data with:
- members of the Quorum Capital group and affiliated entities for operational, administrative and compliance purposes;
- third-party service providers who assist us in operating our website and services, including website hosting, IT, analytics, form management, CRM and cookie consent management providers;
- analytics providers, including Google Analytics, subject to your cookie preferences;
- selected FCA-authorised financial advisers where you have asked us to provide adviser details or pass on an enquiry;
- professional advisers, including lawyers, accountants, auditors and compliance consultants, where necessary;
- regulators, government bodies, law enforcement agencies, courts or other authorities where required or permitted by law;
- prospective purchasers, funders or advisers in connection with a corporate transaction, restructuring or due diligence exercise, where appropriate safeguards are used.
We do not sell your personal data to third parties.
10. International Transfers
Some third-party service providers, including Google, may process personal data outside the UK or European Economic Area (EEA). Where such transfers occur, we ensure that appropriate safeguards are in place, which may include adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or other safeguards permitted under UK GDPR.
11. How Long We Keep Your Data
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, audit, compliance and business requirements. The following periods apply unless a longer retention period is required or justified by law, regulation, dispute, investigation, audit requirement or ongoing business relationship.
| Data category | Typical retention period |
|---|---|
| General website enquiries | 3 years from the date of last substantive contact |
| Adviser, platform or professional enquiries | 3 years from the date of last substantive contact, unless the firm becomes an active relationship |
| Investor adviser-referral requests | 12 months from the date of last substantive contact |
| Marketing consent and preference records | Until consent is withdrawn or the relationship ends, with a suppression record retained where necessary to avoid re-contact |
| Analytics data | In accordance with our analytics configuration, expected to be 14 months unless changed |
| Complaints, regulatory correspondence and compliance records | In accordance with applicable regulatory and internal record-retention requirements |
| Technical security logs | For as long as reasonably necessary for website security, troubleshooting and audit purposes |
When personal data is no longer required, we will securely delete or anonymise it.
12. Your Rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right to be informed – to receive clear information about how your data is used, as set out in this policy;
- Right of access – to request a copy of the personal data we hold about you;
- Right to rectification – to ask us to correct inaccurate or incomplete data;
- Right to erasure – to request deletion of your personal data in certain circumstances;
- Right to restrict processing – to ask us to limit how we use your data in certain circumstances;
- Right to data portability – to request your data in a structured, commonly used and machine-readable format where applicable;
- Right to object – to object to processing based on legitimate interests and to direct marketing at any time;
- Right to withdraw consent – where processing is based on consent, to withdraw that consent at any time.
Some rights may be limited where we are required or permitted to retain data to comply with legal, regulatory, contractual or legitimate business requirements.
13. Exercising Your Rights
To exercise any of your rights, please contact us using the details below. We will usually respond within one month. If a request is complex or you make multiple requests, we may extend the response period by up to two further months where permitted by law. We may need to verify your identity before responding.
14. How to Contact Us
For questions, to exercise your rights, or to raise a concern about how we handle your data, please contact:
- Email: dataprotectionenquiries@quorumcapital.co.uk
- Post: Data Protection, Quorum Capital Limited, Rosedale Studios, Rosedale Road, Richmond, London, UK, TW9 2SX
15. Complaints
If you are dissatisfied with how we handle your personal data, please contact us first so that we can try to resolve your concern. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
- Website: https://ico.org.uk/global/contact-us/
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Telephone: 0303 123 1113
16. Updates to This Policy
This Privacy Policy will be reviewed periodically and updated to reflect changes in our data practices, website functionality, service providers or applicable law. The date of the most recent update is shown at the top of this document. The version published on our website applies from the date shown.