Privacy Policy
Please read this information carefully. Access to this website is confirmation that you have understood and agree to be bound by all of these terms and conditions.
Wealth SuperHeroes understands that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Use to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. “We,” “our” means Wealth SuperHeroes and its affiliates. “You,” “your,” visitor,” or “user” means the individual accessing this site.
Our Privacy Policy identifies how we treat your personal and non-personal information.
Non personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. What is personal information and how is it collected? Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways: 
• When you send us an application or other form 
• When you conduct a transaction with us, our affiliates, or others 
• When we collect information about in you in support of a transaction, such as credit card information 
• In some places on this web site you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity.
Yes, we may use cookies and related technologies, such as web beacons, to collect information on our website. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps Wealth SuperHeroes to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Wealth SuperHeroes website, the information you previously provided can be retrieved, so you can easily use the features that you customized. A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may include web beacons in e-mail messages in order to count how many messages sent were actually opened, acted upon or forwarded.
Third party vendors also may use cookies on our web site. For instance, we may contract with third parties who will use cookies on our web site to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis. These third parties use persistent cookies to help us to improve the visitor experience, to manage our site content, and to track visitor behaviour. We may also contract with a third party to send e-mail to our registered [users/members].
To help measure and improve the effectiveness of our e-mail communications, the third party sets cookies. All data collected by this third party on behalf of Wealth SuperHeroes is used solely by or on behalf of Wealth SuperHeroes and is shared externally only on an anonymous, aggregated basis. From time to time we may allow third parties to post advertisements on our website, and those third-party advertisements may include a cookie or web beacon served by the third party. This Privacy Policy does not cover the use of information collected from you by third party ad servers. We do not control cookies in such third party ads, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad. We will not share your personal information with these companies, but these companies may use information about your visits to this and other websites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you, and they may share your personal information that you provide to them with others.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Wealth SuperHeroes websites you visit.
Wealth SuperHeroes may keep and use personal information we collect from or about you to provide you with access to this web site or other products or services, to respond to your requests, to bill you for products/services you purchased, and to provide ongoing service and support, to contact you with information that might be of interest to you, including information about products and services of ours and of others, or ask for your opinion about our products or the products of others, for record keeping and analytical purposes and to research, develop and improve programs, products, services and content.
Personal information collected online may be combined with information you provide to us through other sources We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information. Finally, we may use your personal information to protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or other legal process.
We will not share your personal information collected from this web site with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy. In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.
We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. For some sorts of transactions, in addition to our direct collection of information, our third party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect personal information directly from you to assist you with your transaction. We do not control how these third parties use such information, but we do ask them to disclose how they use your personal information before they collect it.
If you submit a review for a third party (person or business) using our Facebook Fan Review Application, during the submission process we ask your permission to gather your basic information (such as name and email address) which we then share with the third party for whom you are submitting the review. We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation.
We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior, which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal process. As discussed in the section on cookies and other technologies, from time to time we may allow a third party to serve advertisements on this web site.
If you share information with the advertiser, including by clicking on their ads, this Privacy Policy does not control the advertisers use of your personal information, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad.
We may contact you periodically by e-mail, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction. Only authorized personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
This site contains links to other sites that provide information that we consider to be interesting. Wealth SuperHeroes is not responsible for the privacy practices or the content of such web sites.
This site may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. Wealth SuperHeroes does not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums.
You may access, correct, update, and/or delete any personally-identifiable information that you submit to the web site. You may also unsubscribe from mailing lists or any registrations on the web site. To do so, please either follow instructions on the page of the web site on which you have provided such information or subscribed or registered or contact us at
Wealth SuperHeroes will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us.

Wealth SuperHeroes reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the web site for a period of time. If you have any questions about privacy at any websites operated by Wealth SuperHeroes or about our website practices, please contact us at:


The information published on this website is provided as a convenience to visitors and should be used for information purposes only and is subject to change without notice. None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact one of our personnel.

While we use reasonable efforts to ensure that the information contained on this website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. We accept no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. These documents should not be copied, reproduced or redistributed, in whole or in part.

No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros. Links from this website exist for information only and we accept no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by us or St. James's Place. Links to this website are not permitted without our prior written consent. Please note that clicking on links to external websites will cause you to leave this website.

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As Partners within the St. James's Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James's Place clients. St. James's Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.

This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.

"We", "us" "our" refers to the Partner named on this website.

Where St. James's Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by the St. James's Place Privacy Policy. The St. James's Place Privacy Policy can be found here.


In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a "data controller".

Advisory Cube Wealth Management the United Kingdom will be acting as data controller of your personal information, jointly with St. James's Place Wealth Management.

 Our processing of your personal information

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive "special categories of personal information" (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.

We also use details of any unspent criminal convictions for fraud prevention purposes.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.

In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us.

 What marketing activities do we carry out?

We carry out the following marketing activities depending on the relationship that we have with you:

1. Where you are a prospective client

We will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about our wealth management services that we offer which you might be interested in.

In these letters, we inform you that we will contact you via telephone to discuss our service offerings unless you notify us that you do not wish to receive such a call.

As part of our follow-up telephone call we will discuss the wealth management services we offer which you might be interested in and we will answer any questions that you may have.

Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you.

We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so.

We will also provide you with information of St. James's Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this.

2. Where you are an existing client

We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so.

We will also provide you with information of St. James's Place wealth management products and other third party products which we think may interest you where you have consented to receive this.

General marketing practices

If you wish to opt out of marketing, you may do so by clicking on any "unsubscribe" link or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.

 How long do we keep your personal information for?

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to.

If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 12.

 What is our approach to sending information overseas?

There may be some instances where your personal information is transferred to countries outside of the European Economic Area ("EEA") such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

 • Entering into data transfer contracts and using specific contractual provisions that has been approved by European data protection authorities otherwise known as the "standard contractual clauses". You can find out more about standard contractual clauses at 

 • Transferring personal information only to companies in the United States who are certified under the "Privacy Shield". The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield 

 • We will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this 

We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.

Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:

Country of transfer: China, Hong Kong and Singapore

Reason for the transfer: Provision of data to international offices to support clients living overseas.

Method we use to protect your information: We have standard contractual clauses in place

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 12.

 How do we protect your personal information?

At St. James's Place, we take our responsibility to look after your personal information and privacy seriously. In today's world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.

➡️ We have a dedicated group, the "Information Security Oversight Committee", that provides oversight and guidance to our information security and privacy programme.

➡️ We educate and train our employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.

➡️ When you login, or send us information on the internet we protect the security of this information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).

➡️ We will always interact with you in a safe, secure and consistent manner.

➡️ We continually review our physical and logical security controls in place across the business.

➡️ We conduct security testing of our applications and services in a controlled testing environment before they are made available for our Clients to use.

➡️ We have a business resiliency plan with a disaster recovery and business continuity testing.

However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.


The St. James's Place website and content provided by uses cookies - small text files that are stored on your computer or in your browser - to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors' rights of privacy, this information is anonymous and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser's 'Help', 'Tools' or 'Settings' menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting

 GOOgle Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. ('Google'). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

In addition, we use Google's remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.

We will only collect personal information about you if you send us an e-mail enquiry via the 'contact us' facility or you register to receive your Unit Trust Manager's Reports by email. In order for this to happen, you will need to fill out the on line 'contact us' form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the 'contact us' form, which also tells you how this information will be used. The type of information collected to register to receive the Unit Trust Manager's Reports by email will be apparent from the details requested when you register. The information collected when you register will only be used to email your Unit Trust Manager's Reports and for no other reason.

We take all reasonable precautions to protect our visitors' information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which St. James's Place handles data collected from you on this website, please email us at contact us.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.


Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James's Place employees comply with legal obligations and St. James's Place policies and procedures (including our customer relations practices).


We may provide hyperlinks from this website ('the Site') to websites of other organisations including websites of associated companies. Please note that this Privacy Policy applies only to this Site and that St. James's Place will not be liable for the contents of linked websites or any transactions carried out with organisations operating those websites.

 your rights

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 12 if you wish to exercise these rights; we will not usually charge you.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

 • in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or

 • in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.

We will of course inform you if any of the above situations arise and if we are unable to comply with your request.

 contacting us

If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact the St. James's Place Data Protection Officer at St. James's Place Wealth Management Group plc, St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, and 0800 0138 137.

 Updates to this Notice

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments.

This notice was last updated on 02-12-2020.
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