1. Who we are
RAM Capital Partners LLP ("RAM Capital", "we", "us") is the controller of the personal information described in this notice. That means we decide why and how it is used.
| Registered office | Mappin House, 4 Winsley Street, London W1W 8HF |
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| Registered number | OC329154, registered in England and Wales |
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| Regulator | Authorised and regulated by the Financial Conduct Authority, FRN 470347 |
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| ICO registration | ZC226774 |
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| Contact | taxsolutions@ramcapital.co.uk · 020 3006 7530 |
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We have not appointed a Data Protection Officer. One is not required for a firm of our size and activities. Matthew Brown is the partner responsible for data protection at RAM Capital, and any question about this notice or about your information should be sent to taxsolutions@ramcapital.co.uk in the first instance.
2. Who this notice is for
This notice is for the financial advisers, paraplanners and firm staff who use our website and our services. RAM Capital does not advise or deal with retail clients, and we hold no client records of our own.
We do, though, see a little information about your clients, because you send it to us. When you ask us to prepare an illustration you give us a client's name, the amount to be invested and your fee. When you ask us about an existing holding you give us a name, the fund and roughly when it was bought. That is the whole of it — we do not ask for addresses, dates of birth, National Insurance numbers or anything else, and we do not build a record of anyone's investments.
We tell you this because a name and an amount are still information about a person, even without an address attached. If you would rather not send us a client's name, initials or your own client reference are enough for us to do the work.
It is worth being clear about one point, because it is often misunderstood: an adviser's name, work email address and firm are personal information under UK data protection law. There is no business-to-business exemption. This notice therefore applies to you as an individual, even though our relationship with you is entirely professional.
One thing to flag at the outset. If you use the RAM Academy, we keep a record of which videos you opened, how far through each one you got and how you scored in the quizzes. We do that so we can issue your CPD certificate and stand behind it if anyone queries it. Section 3 sets out exactly what is recorded and section 7 says how long we keep it.
3. What we collect
Most of the information below is collected through our website. We also hold whatever you send us by email, tell us over the telephone, or give us on a business card when we meet. We have never bought a marketing list and we do not use list brokers or data vendors.
We do, though, identify advisers ourselves. Where we do, the source is a publicly available professional one — a firm's own website, the FCA Register, or LinkedIn — and what we take from it is limited to your name, your firm and your professional contact details. We also record professional contact details that reach us when business is placed with us.
If we hold your details because we found them rather than because you gave them to us, we will tell you so, and tell you where we found them, no later than the first time we contact you. You can ask us to stop at any time, and we will.
| Category | What this includes | When it is collected |
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| Identity and contact | Your name, your firm, your work email address | When you request documents, register interest in an offer, or ask to be told when a closed offer reopens |
| Enquiry details | Which documents you asked for; which offer you registered interest in; anything you write to us | At the point of the request |
| Document activity | Which document links you open from the Adviser Fund Centre | Each time a document is opened |
| Learning activity | Which RAM Academy videos you open, how much of each you watched, your quiz scores, CPD hours recorded, certificate reference and completion date and time | Each time you use the CPD section |
| Technical data | Your IP address, passed to our forms provider's spam-filtering services along with your email address | Automatically, when you submit any form |
| Details we have found ourselves | Your name, your firm and your professional contact details, taken from a firm website, the FCA Register or LinkedIn | When we identify you as an adviser we may work with |
| Client details you send us | Where you ask us to prepare an illustration: your client's name, the amount and your fee. Where you ask us about an existing holding: your client's name, the fund and approximately when it was bought | When you send us the request, by email or over the telephone |
Please note: the learning activity above is more detailed than most advisers would expect. It records what an individual studied, how far through they got and how they scored. It is collected so that CPD certificates can be issued and evidenced, but it should be described plainly rather than buried — which is why it has its own row.
We keep this learning record for 12 months and no longer, so that we can answer a query about a certificate we have issued.
Do you have to give us this information? No. Neither the law nor any contract with us requires you to give us your name, your firm or your email address. But we cannot send you the documents you have asked for, tell you when an offer reopens, or issue you a CPD certificate without them.
4. Why we use it, and our lawful basis
UK data protection law requires us to have a lawful basis for each purpose. Ours are set out below.
| What we use it for | Lawful basis |
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| Sending you the documents and information you have asked for | Legitimate interests — responding to a request you made |
| Telling you when an offer you registered interest in reopens | Consent — you asked us to contact you, and you can withdraw at any time |
| Issuing and evidencing CPD certificates | Legitimate interests — providing a service you have chosen to use, and being able to stand behind a certificate we issued |
| Understanding which materials advisers find useful, so we can improve them | Legitimate interests — running and improving our business |
| Sending you information about offers and market developments | Legitimate interests, and you may object at any time. If you are a sole trader or an unincorporated partnership, electronic marketing rules treat you as an individual and we will not email you marketing unless you have consented to it |
| Keeping records we are required to keep as an FCA-regulated firm | Legal obligation |
| Preparing an illustration you have asked for, and passing a servicing enquiry to the manager or their administrator | Legitimate interests — doing the thing you have asked us to do, and passing it to the only people who can answer it |
Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights. We think it is not, because the information is limited to professional contact details and your use of professional materials, you gave it to us in a business context, and you can object at any time. You may ask us for our assessment.
5. Who else sees it
We do not sell your information, and we do not share it with anyone for their own marketing. We do not give the fund managers whose products we distribute a list of the advisers we deal with.
There is one routine exception, and it is worth setting out plainly. We cannot value an existing holding or change the details on one ourselves — only the product manager or their administrator can. So when you ask us about a holding, we pass your enquiry to them: to the manager's investor relations team, or to an administrator such as The City Partnership. That message carries your name, your firm and whatever you have told us, which will usually include your client's name. We pass on the enquiry and nothing else.
The third parties involved are set out below. The first seven are suppliers who run our systems on our behalf and may only act on our instructions. The last two rows are different: those are organisations that receive your information in their own right — because you have asked us to pass your enquiry on, or because we are required to disclose it or need advice.
| Who | Why | Where |
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| Web3Forms (Web3Creative) | Processes every form submission on our website on our behalf, under a data processing agreement | India |
| Amazon Web Services, Cloudflare and Hetzner | Hosting, storage, email delivery and security for those submissions, engaged by Web3Forms | AWS regions as configured, Cloudflare's global edge network, and the EU (Germany and Finland) |
| CleanTalk and Akismet (Automattic) | Spam and abuse filtering. Each receives your IP address and email address to assess whether a submission is genuine | United States |
| Nxt Gen IT | Our IT support provider. They administer our Microsoft 365 tenancy and our domain on our behalf, and can access those systems in order to support them | United Kingdom |
| Microsoft | Hosts our email. Anything you send to us, and our replies, are stored in our Microsoft 365 mailboxes | United Kingdom |
| 20i | Hosts our domain and our website | United Kingdom |
| Intuit Mailchimp | Holds our mailing list and sends our email newsletters and offer updates on our behalf | United States |
| Product managers and their administrators, such as The City Partnership | Where you ask us about an existing holding and only they can answer it, we pass your enquiry to them | United Kingdom |
| Regulators, auditors and professional advisers | Where we are required to disclose, or need advice | United Kingdom |
With the exception of the last two rows, these are suppliers acting on instructions, not organisations we have chosen to give your information to. A current list of the companies our forms provider uses is available from us on request.
6. Sending information outside the UK
Our forms provider, and the suppliers it uses, process submissions outside the United Kingdom — in India, the European Union and the United States. Transfers to the European Union are covered by UK adequacy regulations, which means the UK has recognised that those countries protect personal information to an equivalent standard. Transfers to India and the United States are governed by a data processing agreement with Web3Creative which incorporates the Standard Contractual Clauses together with the UK Addendum, the safeguards UK law recognises for transfers of this kind. We hold a copy of that agreement and will give you a copy of those safeguards if you ask.
Our email service, Intuit Mailchimp, also holds our mailing list in the United States. Intuit is certified under the UK Extension to the EU–US Data Privacy Framework, which the UK recognises as giving an adequate level of protection, and its processing terms additionally incorporate the Standard Contractual Clauses as a fallback.
7. How long we keep it
We keep personal information only as long as we need it. Our periods are:
| Information | How long we keep it |
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| Document requests and enquiries | 24 months from your last contact with us |
| Illustration requests, and enquiries about an existing holding | 12 months from the request, after which the message and anything in it about your client is deleted |
| Registrations of interest in a closed offer | Until the offer reopens and we have told you, or 24 months, whichever is sooner |
| CPD records and certificates issued | 12 months, so that we can answer a query about a certificate we issued |
| Marketing contact details | Until you object, and in any event we review contacts who have not engaged for 24 months |
| Form submissions held by our forms provider | Deleted automatically after three years — so a copy of your original form submission can sit with our provider for longer than the periods above. If we stopped using the service, everything would be deleted within ninety days |
8. Cookies and similar technologies
We inspected the website in preparing this notice, and checked it again in a browser on 24 August 2026. It sets no cookies of its own and runs no analytics or advertising trackers. The only cookies WordPress sets are two that record screen preferences for our own staff when they sign in to administer the site; a visitor never receives them.
The site does, however, keep up to three things in your own browser, using what is called local storage rather than cookies:
- your name, your firm and your work email address, once you have entered them on one of our forms, so that you are not asked to type them again;
- if you use RAM Academy, your progress through the eight modules — your name, firm and email address, and the certificate reference and date for each module you have passed — so that the site can show you where you have got to and produce your combined certificate; and
- a short list of which videos you have already opened in the past 24 hours, kept against your email address and used only to stop us being notified twice about the same video. Entries older than 24 hours are discarded.
All three are held on the device you are using, and you can remove them at any time by clearing site data for ramcapital.co.uk in your browser. We will talk you through it if you ask. None of the three is uploaded from your device by itself. Separately, and whether or not anything is stored on your device, we are sent your name, firm and email address together with the document or video concerned at the moment you request a document or open a video, and your quiz score, CPD hours and certificate reference at the moment you pass a module. Section 3 sets out what we then hold and section 7 says for how long.
The rules on storing information on your device are not limited to cookies. At present the site saves these items as soon as you first give us your details. We are adding a way for you to decline them, and we will ask before saving anything once it is in place. In the meantime nothing is lost by removing them, and you can do that at any time as described above.
Because we set no cookies of our own and run no analytics, there is no cookie banner on the site. If that ever changes, we will ask for your agreement before anything is set.
This holds for our forms too. When you submit one, your details are sent quietly in the background to our forms provider's system; your browser is not taken to their website and none of their code runs on this page. So nothing they use on their own systems — including any analytics or session-recording tools — can see or record what you do here.
The typefaces used on this site are served from this website itself. Your browser makes no request to Google or to any other outside company in order to display these pages.
9. Your rights
You have the right to:
- be told what we hold about you and why, which is what this notice does;
- ask for a copy of the information we hold about you;
- have inaccurate or incomplete information corrected;
- ask us to delete information we no longer need;
- ask us to restrict how we use it while a question is resolved;
- receive information you gave us in a portable format, or have it sent to someone else, where we hold it with your consent or under a contract with you;
- withdraw your consent at any time where we rely on it — for offer alerts, by using the unsubscribe link in any message from us or by emailing us. Withdrawing your consent does not affect anything we did before you withdrew it;
- object to our use of your information where we rely on legitimate interests; and
- object to direct marketing at any time. This right is absolute — if you object, we stop.
To exercise any of these, email taxsolutions@ramcapital.co.uk. We will respond within one month. If your request is complex we may need up to a further two months, and we will tell you within the first month if that is the case. There is no charge. We may need to check who you are before we respond. Some of these rights are qualified and depend on why we hold your information; where we cannot do what you have asked, we will tell you why.
Your right to object to marketing. You can tell us to stop sending you marketing at any time and we will stop. You do not have to give a reason and there is nothing to justify. Email taxsolutions@ramcapital.co.uk, or use the unsubscribe link in any message we send you.
10. How to complain
If you are unhappy with how we have handled your personal information, please tell us first — email taxsolutions@ramcapital.co.uk or call 020 3006 7530. We will acknowledge your complaint within 30 days and respond as quickly as we can.
You also have the right to complain to the Information Commissioner's Office, and you do not have to come to us first. The ICO can be reached at ico.org.uk/make-a-complaint or on 0303 123 1113.
11. Automated decisions
We do not make any decision about you by automated means, and we do not profile you.
12. Changes to this notice
This notice replaces the RAM Capital privacy statement of 3 May 2018. If we change it we will publish the new version here and update the version and date below. We will tell you directly if a change is significant. If we ever want to use your information for a new purpose, we will tell you directly and explain that purpose before we start, rather than rely on you noticing a change to this page.
Version 1.0 — 28 August 2026.
