We collect personal information on you including your name, date of birth, address, contact details, employment, information about your health, financial information, forms of identification, and other financial information. We may require further information depending on requirements that will help us carry out our duties to you, our product providers, and regulators.
If we do want to collect personally identifiable information in person, through our website, social media marketing channels, or other digital means we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it and allow you to opt-in or out of the service.
We also collect information about you through our website, which automatically collects information from your computer using “cookies” which provides us with limited personal information. A cookie is a small text file that is saved on your Internet browser when you use our website. The cookie is sent to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
We use this information to provide you with products or services, to assess your risk tolerance and determine strategies and recommendations consistent with your financial needs, objectives and personal circumstances. We may also use your personal information to provide you with advice and services about the following products.
- Financial advice and services.
- Investment products and services such as managed investment funds and investor directed portfolio services.
- Pension schemes, trusts and investment insurance policies.
- Life insurance products, such as insurance for your life, permanent disability and income replacement.
The purpose of collecting the above-mentioned information is to enable us to provide you with a comprehensive service and real value in your financial journey. This comprehensive service shall be subject to your opt-in agreement at initial engagement around our services.
Other purposes for which we may need to collect and use your personal information will include:
- To comply with legislative and regulatory requirements,
- To enable us to perform administrative operations such as accounting, record keeping, and archival retrieval;
- To enable us to contact you when conducting marketing and inviting you to events that you may be interested in; and
- Tell you about new services and/or products we can offer (unless you tell us not to contact you with this type of information.)
We shall process and control your information such that we can fulfil our contractual obligations to you, or such that it satisfies a legitimate interest which does not override the rights afforded to you. An example of legitimate interest, not limited to, is where your product provider requests information about you, in order to update their files and systems for your benefit.
Considering our role in the financial services industry, we take our responsibilities to the stability of the financial system seriously. As a result, we collect information that enables us to combat money laundering, to comply with our regulatory requirements and international best practice. With this said, where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions.
At Hoxton Capital Management we are committed to the protection of the personal data that you have provided us with in order to preserve their confidentiality and prevent any unauthorized access, use, alteration or destruction of your personal data.
As part of the information security policy implemented by us for the protection of our own sensitive information and our clients’ information, we apply organisational and technical measures to ensure appropriate security of the personal data we collect, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, and to ensure that your private information is only used for the above reasons.
Though we believe we apply appropriate measures, in particular, for the protection of the information system environment on which the data we collect are stored, it remains that no transfer of data via the Internet can be fully protected from unlawful access by third parties. Communications via the Internet may potentially be intercepted, lost or modified and such risks remain beyond Hoxton Capital Managements reasonable control. In the event of this occurrence, we shall notify the appropriate regulator of any breach within 72 hours.
Through our file keeping system we are obliged to keep all correspondence, contracts and transactions carried out on behalf of our clients for an indefinite term due to the lack of statute of limitations clause for financial advice. These files must also be kept and made available to Regulator’s examiners and law enforcement authorities, regarding criminalisation of money laundering, upon request at any given time in the future.
If you are not yet a client, or do not intend to engage with us in a business relationship, we will only retain your information for a period of 24 months after the point of becoming inactive, unless you have given us an instruction to delete your personal information.
Under the GDPR, European individuals and individuals within the European Economic Area are entitled to these rights. However, we believe in a universal right to privacy and this rings true with our values as a company. We intend to extend these rights to all, where appropriate.
The right to be informed: By providing you with this privacy note, we commit to and emphasise the need for transparency over how personal data is used.
The right of access: You will have the right to obtain confirmation that your data is being processed, access to your personal data, and other supplementary information.
The right to rectification: You are entitled to have personal data rectified if it is inaccurate or incomplete.
The right to erasure: The right to erasure enables you to request the deletion or removal of personal data when there is no compelling reason for its continued processing.
The right to restrict processing: When processing is restricted, it is permitted to store personal data, but not to further process it.
The right to data portability: The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services.
The right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority, direct marketing, or for purposes of scientific/historical research and statistics.
The right not to be subject to automated decision-making, including profiling: The GDPR provides safeguards for individuals against the risk that a potentially damaging decision is taken without human intervention.
This privacy notice/policy was updated on 18/09/2019, and we shall review and update it accordingly from time to time on our website.
If you have any questions, queries or would like more information/detail about the above mentioned, your private data, and rights, please feel free to contact us on firstname.lastname@example.org and we will do our best to get back to you in a timely and professional manner.
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.