HCF Data Protection Privacy Policy

This Privacy Policy (the Policy) describes how HCF International Advisers Ltd deals with the information you provide to us and the information we collect in the course of operating our business and our website in accordance with the requirements of applicable data protection laws, including the European Union’s General Data Protection Regulation (GDPR).

In this Policy “HCF”/“we”/“us”/“our” refers to HCF International Advisers Ltd. HCF is registered in England and Wales (No. 4639026), with its registered office at 3rd Floor, Portland House, Bressenden Place, London, SW1E 5BH. We are authorised and regulated by the Financial Conduct Authority.

From time to time we may need to make changes to this privacy policy. You should check the HCF website periodically to view the most up to date privacy policy.

How we collect personal information

“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.

We collect the following personal information:

1. Information you provide to us: We will process personal information that you give to us including when you email us or contact us through various channels in connection with our provision of financial advisory services (via business cards, emails, mail, phone calls) as well as your recruitment application.
2. Information we collect from you: We collect and store information when you visit our website. Please refer to our cookie policy.
3. Information we collect from other sources: If you apply for a position with HCF we may collect personal information relating to past employment, qualifications and education, references from your previous employers, and other details about you. These will be provided to us by a third party that provides headhunting services or by your previous employers. We may also collect or receive your personal information from third parties in connection with our financial advisory services. Examples include information received from your employer, parties involved in / relevant to the transactions we are involved in.

We frequently collect:

1. Name
2. Gender
3. Contact details for work and/or home including address, email address and phone numbers

We occasionally collect:

1. Date of birth
2. Passport or other identification documents.

How we use your personal information

We may use your personal information for the following purposes:

• Provision of financial advisory services to the relevant client;
• Review and processing of your job application;
• Compliance with legal and regulatory obligations including to check the identity of new clients and to prevent money laundering and/or fraud
• Review of any complaints or queries you may have;
• Establishment, exercise or defence of our legal rights or for the purpose of legal proceedings;
• Marketing and business development activities in relation to our financial services, from time to time. You have the right at any time to stop us from contacting you for marketing purposes (see below contact details);
• Should we undergo re-organisation or be sold to a third party, transfer of information to that re-organised entity or third party.

By providing us with your personal data you consent to your data being used for the purposes described above.

Legal basis for using your personal information

We will only process your personal information where we have a legal basis to do so, namely:

• Consent. You can withdraw your consent by contacting us (see below).
• Performance of a contract.
• Legitimate interest.
• Compliance with law or regulation.

How we share information with third parties

We only share your personal data with your consent or in accordance with this Policy.

We may share your personal information outside HCF. This may include:

• Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy.
• Third parties relevant to the financial services that we provide.
• To the extent required by law, regulation or court order.
• Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.

Keeping your information and information security

We will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information as well as to comply with state, local, federal regulations, or country specific regulations and requirements.

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage.

Your choices and rights

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.

These rights include:

• The right of access to your personal information;
• The right to request rectification off inaccuracies;
• The right to request the erasure of your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
• The right to restrict the processing of your personal information on legitimate grounds. Note that we are legally entitled to refuse that request. This means we are permitted to store the data but not further process it.
• The right to object to the processing of your personal data on legitimate grounds. Note that we are legally entitled to refuse that request.
• The right to have (some of) your personal information transmitted to a third party in a structured, commonly used and machine-readable format where this is technically feasible and where you have provided us with such information.
• The right to withdraw your consent to us processing your personal data, although we may continue processing it without your consent if we have another legitimate reason for doing so.
• Lodging a complaint with the relevant data protection authority, regarding the processing of your personal data by us or on our behalf.

How to contact us and other important information

If you would like further information on the collection, use, access to, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at: info @ hcfintl.com