Updated: May 2025
Namier believes that protecting the privacy of non-public personal data is of the utmost importance and is committed to maintaining the privacy of any non-public personal data in our possession.
This privacy notice tells you what to expect us to do with your personal information.
1. Contact details
2. What information we collect, use, and why
3. Lawful bases and data protection rights
4. Where we get personal information from
5. How long we keep information
6. Who we share information with
7. How to complain
1. Contact details
Email: rgordon@namiercapital.com
2. What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Records of meetings and decisions
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Date of birth
- National insurance number
- Financial information
- Identification documents which can include biometric data
- Any other personal information required to comply with legal obligations
3. Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure – You have the right to ask us to delete your personal information.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
- Your right to object to processing – You have the right to object to the processing of your personal data.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
4. Where we get personal information from
- Directly from you
- From your professional advisers
5. How long we keep information
- We will keep information for a period of seven years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or to use your information where we need to for our legitimate purposes such as dealing with disputes that may arise.
- If we don’t need to retain information for this period of time, we may destroy, delete or anonymize it more promptly.
6. Who we share information with
Data processors
MUINMOS
This data processor does the following activities for us: they provide our client due diligence and anti-money laundering verification checks which include searches on identity and proof of address, PEPs and sanctions and adverse media.
AFFINITY SYSTEMS
This data processor does the following activities for us: they provide IT investment management services.
FERGUSON-MAIDMENT
This data processor does the following activities for us: they produce our payroll and financial statements.
CLARION COMMUNICATION MANAGEMENT
This data processor does the following activities for us: they provide our IT services.
Others we share personal information with
- Professional advisors
- Regulatory authorities
7. How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113