Privacy Policy

At Thorntons Investments, we are committed to protecting your personal information.

At Thorntons Investments, we are committed to protecting your personal information.

This privacy notice contains information about what personal details we collect, what we do with that information and who we might share it with.

What information do we collect about you?

We collect information about you when you engage us for financial planning and investment management services. This information will relate to your personal and financial circumstances including but not limited to:

  • Information about you e.g. name, date of birth and contact details
  • Information connected with correspondence with us e.g. emails, meeting notes and phone calls
  • Information about you and your family’s financial affairs
  • Information relating to a service or product e.g. bank details
  • Information provided by you about another individual
  • Information regarded as “special category data” such as health. This will only be collected if necessary for the provision of our services.

Where we collect your information?

We collect personal information directly from you, using various sources including:

  • Know your Client Information Forms and contact forms on our website
  • Meetings/letters/emails/telephone conversations

We will also obtain information about you from some of the third parties we share data with but will only do this where it is necessary to provide services to you or to comply with legislation.

Why do we need to collect and use your personal data?

The information that we collect about you is essential for us to be able to carry out the services that you require from us. Without collecting your personal data, we would also be unable to fulfil certain legal, regulatory and contractual obligations.

Where special category data (e.g. details about your health) is required we will obtain this directly from you and explain why it is necessary for us to obtain that information.

How will we use the information about you?

We will only ever collect and use your personal information for the purposes we have agreed with you in our terms of business or otherwise with your explicit consent. We will do this in a fair and lawful manner.

How will we protect your information?

All information you provide to us is stored on our secure servers and/or in paper files, which have appropriate safeguards in place consistent with our data protection obligations.

Our security controls are aligned to industry standards which effectively manages confidentiality and availability of your information.

Who might we share your information with?

In order to deliver our services to you, we will send your details to only those third parties that we engage for professional services, as well as product and platform providers that we use to arrange financial products and services for you. We may also disclose your personal information to other professional services organisations you deal with (e.g. your solicitor or accountant) where you have given us your permission to do so.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, and that they have appropriate arrangements in place to protect your information and ensure that it is only used for the intended purpose.

Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes. There may also be circumstances where we are obliged to disclose your personal information to regulatory authorities.  

We will not share your information for marketing purposes with other companies.

How long do we keep your information?

In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. In any case, we will not retain your personal data for longer than is required by regulation. We have a detailed record retention policy which we are happy to share with you on request. 

You have the right to request deletion of your personal data and we have 30 days to comply with this request; subject to the restrictions imposed upon us by law and regulation. In these circumstances we would be unable to continue to provide our services to you.

Where a formal advice agreement is not entered into, Thorntons Investments may hold your personal data for a period of up to 6 months, after which your personal data will be deleted from our records, unless otherwise agreed in writing.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

We have an obligation to ensure that your personal information is accurate and up to date. If your information is incomplete or inaccurate you can request that it is corrected.

Investments made on behalf of children under 18

Thorntons Investments will use consent as a Lawful basis for processing children’s data and therefore, require consent from the parent or legal guardian of any child under the age of 18. Once they become 18, they will be treated as our client and we will require their consent.  We will rely on the individual(s) with parental responsibility to provide our privacy notice to those aged 13 and over.

Special Category Data

We will obtain explicit consent from our client(s) to process special category data, under condition (a) of Article 9.

Information about connected individuals

We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Our website

We use cookies to track visitor use of our website and to compile statistical reports on website activity.  Cookies are text files stored on your computer or mobile device to monitor user behaviour and improve user experience. We publish our Cookie Policy under the Privacy Policy section of our website.

You can set your browser not to accept cookies and our Cookie Policy explains how to remove cookies from your browser. However, in a few cases some of our website features may not function as effectively as a result.

Our website contains links to other websites. This privacy policy only applies to our own website, so when you link to other websites you should read their own privacy policies.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

In writing:            The Compliance Officer, Thorntons Investment Management Ltd, Whitehall House, 35 Yeaman Shore, Dundee, DD1 4BU  

By phone:            01382 797600   

By e-mail:  

What can you do if you are unhappy with how your personal data is processed?

You have the right to lodge a complaint with the supervisory authority for data protection, which is:

In writing:            Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By phone:            0303 123 1113

For additional information please visit:

 Changes to our privacy policy

We keep our privacy policy under regular review, and we will place any updates on our website.  We will inform you of any significant changes which we consider to be material when they occur.  This privacy policy was last updated in October 2021.


AJ Bell:

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