Privacy Notice

About this privacy notice

STRAT7 Researchbods, a division of STRAT7 Limited, registered in England under company number 07642707 whose registered office is at 11 Soho Street, London, W1D 3AD (Researchbods), is an online data collection company that focuses on building and managing large online consumer communities to provide high quality research data to its clients.

The Wisdom Council is a trading name of Wisdom Global Limited, a company registered in England under company number 08589400 whose registered office is Cannon Green, 27 Bush Lane, London EC4R 0AA. The Wisdom Council are an insight and consultancy company, specialising in the financial services industry.

Reference to “we, us, or our” are jointly references to The Wisdom Council and Researchbods together.

Researchbods and The Wisdom Council administer and operate the website www.sjpclientcommunity.co.uk (referred to as the “Site”), the St. James’s Place Client Community (referred to as “Community”) and the Partner Consultation programme ( referred to as “Consultation programme”) on behalf of St. James’s Place Wealth Management plc, a company registered in England under company number 04113955 whose registered office is at St. James’s Place House, 1 Tetbury Road, Cirencester, GL7 1FP (“St. James’s Place”).

For the purposes of data protection, St. James’s Place Wealth Management is the data controller and The Wisdom Council and Researchbods are the data processors.

This privacy notice covers the collection of personal information from users of the Site and members of the Community or Consultation programme ("you" and "your") and use of that information by Researchbods, The Wisdom Council, St. James’s Place Wealth Management plc and parties that we authorise, such as our suppliers and subcontractors.

Your information is very important to us and we look after your information carefully in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information. We’ve set out below more detail on what information we collect about you and how we use that information.

Please do read this privacy notice and our Cookies Notice, so you know what we are doing with your information. By accessing and using the Site and by participating in the Community or Consultation programme, you are agreeing to the terms of this privacy notice and to our Cookies Notice. We may update this privacy notice and our Cookies Notice from time to time and we’ll post any changes on our Site.

This privacy notice was last updated on 03/02/2023

What information do we collect?

The information we collect about you depends on how you’re using the Site and participating in the Community or Consultation programme, but we will only collect your personal information where necessary.

To become a member of the Community, you need to register with us. When you register we ask you to provide some basic information about yourself, such as your name, email address, postcode and your month and year of birth - which we call “Registration Data”. If you decide not to complete the registration process, any personal data that we have collected will be held for a limited period of time before being deleted. Please also note that once you have successfully registered, we may delete your account if you’ve been inactive for a period of time, so please make sure that any Registration Data is accurate and kept up to date.

To become a member of the Consultation programme, you need to register with us. When you register we ask you to provide some basic information about yourself and your business as an Adviser or Partner of St. James’s Place – which we call “Registration Data”. If you decide not to complete the registration process, any personal data that we have collected will be held for a limited period of time before being deleted. Please also note that once you have successfully registered, we may delete your account if you’ve been inactive for a period of time, so please make sure that any Registration Data is accurate and kept up to date.

We also collect information you submit when completing any of the research tasks (e.g. surveys, polls or forum discussions) we invite you to participate in, or feedback, comments or other information that you provide to us through the Site or otherwise, including any information, photos and/or videos which you may upload. This may include the collection of Special Categories of Data such as your ethnicity, which helps us to ensure that our Community is representative of the UK population and to conduct research more effectively. Providing Special Categories of Data is always voluntary, and you may withdraw your consent at any time by emailing us at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members).

Other information we may collect includes:

• information about your use of our Site, the Community or Consultation programme, including details of your internet protocol (IP) address, operating system, browser version, cookie details, how long you stayed and on which pages, and your navigation around the Site, Community and Consultation programme; and
• other data to ensure and check compliance with the Terms and Conditions of Use and/or otherwise as required by law.

When and how do we collect information?

We (or our authorised third parties) may collect information about you:

• when you first complete the registration process to become a member of the Community or Consultation programme;
• when you update your details via the Site or otherwise;
• when you voluntarily complete any of the research tasks (such as surveys, polls or forum discussions) we invite you to participate in;
• when you contact us or provide us with information through the Site or otherwise at any other point (for instance, when you contact us with an enquiry, request or feedback);
• in monitoring your use of the Site and engagement with the Community or Consultation programme, including without limitation communications sent by you via the Site;
• when we are checking compliance with the Terms and Conditions of Use and/or otherwise as required by law;
• through the use of “cookies” and/or other devices (for details, see our Cookies Notice); and
• from third party suppliers who have confirmed to us that they are authorised to pass your information to us in accordance with your legal rights.

Information on the Site may be publicly available

Please always think carefully before disclosing information to other members of the Community or when making your information publicly available to other members on the Site. We recommend that you do not reveal to others via the Site any personal information about yourself or anyone else (such as your telephone number or home address).

It is important that you are aware that any information you disclose to another member may then be disclosed by that member. We have no responsibility or control over the contents of communications made between members on our Site.

Do we use cookies?

We, and our authorised third parties, may use cookies and/or other tools to store and sometimes track information about you. For more details about what cookies are, the cookies we use and how to disable them, please see our Cookie Policy.

How long do we keep your information for?

We will keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the information was obtained and its nature. For example:

• We may need to keep some personal information about you so that we can deal with any complaints you might make about the Site, the Community, Consultation programme or our services.
• If you ask us to stop sending you emails in connection with research tasks, the Site and the Community or Consultation programme, we need to retain enough information about you to enable us to ensure we stop including you in any communications.
• We may need to keep personal information so that we can defend possible future legal claims.
• We may have a legal or regulatory duty to retain particular personal information for a certain minimum period (for example, under HMRC tax rules).

How do we use your information?

We and our authorised third parties may use your information in a variety of ways, to:

• verify your identity (e.g. when you register as a member of the Community or Consultation programme or return to the Site);
• administer and manage the Site, Community or Consultation programme;
• invite you to participate in and communicate with you about research tasks (such as surveys, polls and forum discussions) on the Site and other research activities that we feel may be relevant to you based on the information you provided to us;
• create anonymous, statistical profiles of membership based on the information provided by you and other members of the Community and Consultation programme;
• collate and aggregate responses to research tasks by you and other members of the Community and Consultation programme to present the anonymised results in research reports - these will not be used to identify any individual member;
• send you communications about the Site, Community or Consultation programme (including service messages to make you aware of new features or changes on the Site, Community or Consultation Programme newsletters and information about Community prize draws and rewards);
• to show our appreciation for participating in the Community, we may reward Community members for completing research tasks (e.g. surveys, polls and forum discussions). Rewards include vouchers and free prize draws, which are run in accordance with our General Prize Draw Terms and Conditions and any additional terms which may be stated on the Site. For the avoidance of doubt, we will use your information to enter you into any prize draws that you are eligible to take part in or, where invited to do so, have asked to be entered into;
• administer rewards (such vouchers or prize draws;
• monitor and develop the Site, Community and Consultation programme to improve your experience;
• conduct market research, which may include statistical, technical and logistical analysis;
• verify that the Community is representative of the UK population;
• process and deal with any complaints or enquiries made by or about you;
• monitor compliance with and investigating any suspected breach of the Terms and Conditions of Use or other applicable terms including without limitation by way of (a) checking postings or submissions in connection with your use of the Site, and/or (b) using keyword triggers to investigate usage that may be inappropriate; and/or
• We will only process your personal information where we have a lawful basis to do so. Generally, we will only process your personal information on the following grounds:
• you have given your explicit consent for the processing. When we rely on consent to process your personal information including when we collect Special Categories of Data such as relating to ethnicity, you always have the right to withdraw your consent. If you withdraw your consent to us processing Special Categories of Data, we will stop sending you any research tasks which require this information but may
• continue to send you other research tasks and we may still use the anonymised, aggregated data which we have created using your information;
• the processing is necessary for the performance of a contract to which you are a party (including our Terms and Conditions of Use);
• the processing is necessary in order to take steps at your request prior to entering into a contract (including our Terms and Conditions of Use);
• the processing is necessary for compliance with a legal obligation placed on us and/or St. James’s Place, or one of our authorised third parties;
• the processing is necessary for the purposes of the legitimate interests pursued by us, St. James’s Place Wealth Management plc or by a third party. For example, we are a market research provider so have a legitimate interests in carrying out research, and St. James’s Place Wealth Management plc has a legitimate interest in undertaking market research and using the results of that research to gain insight about its business, including in relation to its audience, programming, channels, platforms, brands and the advertisements that are shown, which may involve processing of your personal information. In certain limited circumstances you may have the right to object to processing based on such legitimate interests.

St. James’s Place Client Community Website and Partner Consultation programme

When you use the Site we may process your data in the following ways:

Emails from the St. James’s Place Client Community and Partner Consultation programme

All Community and Consultation programme members will receive service emails in connection with the Site, Community or Consultation programme which include emails about new features or changes on the Site, and general news and updates such as Community or Consultation programme newsletters, newsflashes, research tasks (e.g. surveys, polls or forum discussions) on the Site, and other research activities that we feel may be relevant to you based on the information you provided to us, as well as information about rewards, including prize draws in connection with research tasks on the Site.

These emails are necessary for us to provide our research services and by registering to be a member of the Community, you agree that you understand this.

You can decide to stop receiving these emails from us at any time. The easiest way to do this is to click on the ‘unsubscribe’ link at the bottom of any of the emails. Alternatively, you can email us at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members) from your registered email address and ask to unsubscribe from the emails. As these emails are critical to us being able to run our services, if you do unsubscribe, we will keep your account active for a short period in case you change your mind but will then delete your account (please see the “Closing your account” section below).

Do we share your information?

We will share your personal information with St. James’s Place, as the owner of the Site, the Community and the Consultation programme, although St. James’s Place will only receive information as needed for the purposes described in this privacy notice. Generally, the information that is provided to St. James’s Place will be in the form of aggregated, anonymised results of the research tasks that are completed by you and other members. Please note that St. James’s Place also has access to those parts of the Site that are also visible to other members as well as open and closed online discussion forums on the Site, and may engage with you directly via such discussion forums and other areas of the Site.

We will also create research reports for St. James’s Place to use for its business purposes, which may include disclosure to other members in the St. James’s Place group of companies and third parties (such as advertiser clients and media buying agencies).

As you have an interest in St. James’s Place services, they may also share your personal information with other members in the group of companies to provide other services and products that you request. If you are a user of another group service, St. James’s Place may combine the data it holds about you from that service with your Registration Data and your responses to the research tasks on the Site. St. James’s Place may use the combined data to confirm that the data it holds about you is accurate, and to improve its products and services which may include creating and using models to help provide a more personalised experience. St. James’s Place may also combine your data to help us conduct research more effectively on the Site, for instance by matching your Registration Data from the Community or Consultation programme with other data they hold about you in order to allow us to gain a better understanding of how you use St. James’s Place so that we can invite you to participate in research tasks that are more relevant to you.

We may also pass information about you to other parties as follows:

• to third parties authorised by us and acting on our behalf such as our employees, contractors, suppliers and/or agents including without limitation our customer care teams to administer and manage the Site, the Community and Consultation programme now or in the future. These third parties are only allowed access to your information as needed to perform functions connected with the Site, the Community or Consultation programme, or to provide services to us. They’re not allowed to use it for any other purpose;
• as part of general statistical information about the membership base, traffic volumes and related matters. These details will not include information from which you could personally be identified;
• to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms and Conditions of Use and/or the breach of any other applicable terms or where required by law or where we suspect harm or potential harm to others. We will cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders;
• the Site contains public forums and pages which are displayed to other members. When you engage with these areas of the Site, your user name and some profile information you voluntarily provide and your submissions will be publicly available. Please always think carefully about creating your user name (which will be the identity by which you are known on those areas) and before disclosing information to other users or otherwise making your information publicly available;
• if there are changes to St. James’s Place’s or The Wisdom Council’s or Researchbods’s business (see section below on “Changes to business”).

What are your rights?

Any personal information you supply will be treated in accordance with applicable data protection laws including the General Data Protection Regulation and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These include:

• the right to request a copy of the personal information we hold about you. To do this, please contact us at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members) making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit proof of your identity.
• the right to object to your personal information being processed where the legal basis for the processing is our or St. James’s Place’s legitimate interests as a business (see “How will we use your information?” section above). We will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our services.
• the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information.
• the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time by contacting us at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members)
• the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal information, such as keeping your payment information for several years to comply with HMRC rules.
• the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible.
• the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, the Information Commissioner’s Office in the United Kingdom (“ICO”) regulates our processing of your personal data and you do have the right to lodge a complaint with the ICO. Details of how to contact the ICO can be found on the ICO website at ico.org.uk.
• access, correction and updates to your information - You have the right to access your personal information and to correct it. Please make sure that you update your details as soon as possible with all relevant changes. - When you register as a member of the Community and open a user account on the Site, you can access your membership information on your ‘Profile’ page by logging into the Site. If you need to update or correct any of your membership information, you can do this within the ‘Profile’ page. - Alternatively, you can email us at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members) in order to access and/or update your data at any time.

What this privacy notice does not cover

This privacy notice doesn’t cover companies, services or applications that we don’t own or control, or people that we don’t employ or manage. This includes (without limitation) third party websites or applications/widgets (e.g. from social media platforms such as Facebook or Twitter) that we may link to or offer via our Site.

Also, it doesn’t cover certain pages and services provided via our Site that are hosted, managed and operated by other parties. These third parties, applications and services are wholly independent of us and are solely responsible for all aspects of their relationship with you and any use you may make of them. They may have their own privacy notices and/or terms and conditions of use, which we recommend you read before using.

Service providers based outside Europe

If we do engage a new supplier located, or with servers that are located, outside the European Economic Area in the future then we will take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy notice. We‘ll only transfer your personal information to a territory outside of the European Economic Area under the following circumstances:

• the European Commission has determined that an adequate level of protection for personal information is in place in the country to which we transfer your data; or
• standard data protection clauses as adopted by the European Commission are in place governing the transfer (you can view the standard clauses on the European Union’s legal website at eur-lex.europa.eu/)

Closing your account

You may close your member account at any time. This can be done by going directly to your ‘Profile’ page. If you close your member account, your profile information will be removed, you will be unable to access the Site and you will no longer receive emails from us.

We will delete your account as soon as reasonably practicable following receipt of the deletion request, and in any event within 5 business days. If you delete your account, we may continue to process your data for contractual reasons e.g. if we need to provide you with a prize won before closing your account. Please note if you have not earned a reward or incentive or rewards at the time you delete your account, you will forfeit any rights to try and earn or receive those incentives or rewards.

We also reserve the right to suspend or terminate your membership, or your ability to access to the Site immediately and without notice at any time, at our sole and absolute discretion. This may be because, for example, we consider that you have breached the Terms and Conditions of Use or any other applicable terms or if you have been inactive for a period of time.

We may close the Community or Consultation programme and your account when the research programme ends or is cancelled. In these circumstances, we will inform all members by email of the Community or Consultation programme being closed, at which point your access to it will cease.

Business Changes

The Site, the Community and the Consultation programme is part of St. James’s Place’s business. St. James’s Place may choose to run these services itself, engage one of its group companies to run it or to appoint a new supplier to run it, in which case your information may be passed to St. James’s Place or that new supplier. Use of your personal information will remain subject to this privacy notice (as amended from time to time).

If we or St. James’s Place become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction may involve us or St. James’s Place’s:(i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction. St. James’s Place, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.

Contact us

You can email us with any questions, concerns or complaints at support@sjpclientcommunity.co.uk (for Community members) or partnersupport@sjpclientcommunity.co.uk (for Consultation programme members).