At Hurley Partners we do all we can to respect your right to privacy and the protection of your personal information. Our Privacy Notice explains what we and other companies in the group do with your information in order to run our business and provide you with services.
It will allow you to understand how we look after and process your personal information, including what you tell us about yourself and what we learn about you as a visitor to our website and when you are thinking of becoming a client. We explain how we do this and set out your privacy rights and how the law protects you.
Your information will be held by Hurley Partners Limited and/or other group companies.
For the purpose of the General Data Protection Regulation 2016 (“GDPR”) and any associated UK domestic laws, the data controller is Hurley Partners Limited (company number 8401891) of 12 Conduit Street, London W1S 2XH
- Why do we collect your information?
The principal purpose of processing your information is to enable us to manage our relationship with you so as to provide you with the most suitable advice and solutions.
GDPR and other data protection legislation set out that we can only use your personal information if we have a proper and lawful reason to do so. These reasons are:
- To carry out the services we have mutually agreed upon or to take necessary steps before you agree to enter into a contractual agreement with us. This might include carrying-out an initial fact find so we can decide whether we can assist you and to then make a proposal to you. As a client this will typically include managing your investments, providing pension advice, administering your pension and making and managing payments due to you.
- When we or a third party have a legitimate interest, such as a business or commercial reason where it is necessary to use your information e.g. to make our services more efficient or carry out fraud prevention activities.
- When it is our legal duty to process your data to comply with the law e.g. to undertake money laundering checks, provide information to HMRC and regulators such as the Financial Conduct Authority or record and monitor calls.
- When you give consent to us to process your data for one or more specific purposes e.g. to send you certain marketing materials.
We may also process certain special categories of information for specific and limited purposes such as detecting and preventing financial crime or to provide certain services to you. A full list of these special categories can be found in the table on page 4. We will only process special categories of information where we have obtained your explicit consent or are otherwise lawfully permitted to do so. The primary reasons are: for reasons of substantial public interest e.g. carrying out fraud prevention activities or providing pension advice to you; where you have made the information public e.g. if you have been profiled in a newspaper or magazine; where it is necessary for us to establish, exercise or defend legal claims.
Where we are processing any information that discloses any criminal convictions or offences, for example, in order for us to carry out our required anti-money laundering and “know your client” checks or undertake fraud detection or prevention activity, the main lawful reasons upon which are relied on for this processing are:
- Preventing or detecting unlawful acts
- Complying with our regulatory requirements in relation to unlawful acts or dishonesty
- Dealing with suspicions of terrorist financing or money laundering
- Where it is necessary for us to obtain legal advice or establish, exercise or defend legal rights
- The information we use
We collect and process various types of your personal information, including basic information such as name and contact details, and information about financial circumstances, investments and transactions.
In certain circumstances, the provision of information to us is required in order for us to decide whether to offer our services to you or to comply with our legal obligations e.g. in relation to certain information about your tax status or in relation to our anti-money laundering requirements.
What we need from you in each circumstance will be explained to you at the various exploratory and advice meetings with us. If you do not provide us with the required information, we will not be able to offer certain services to you.
A full description of the different types of personal information we use are shown in the table overleaf.
|Personal Information We Use||Description and Examples|
|Contact||Your name, address, email address, telephone numbers and any other contact details.|
|Financial||Your financial position, status and history and where applicable financial information regarding your business or family members including your dependent children. Details about your investments, pensions, loans and any payments to and from your accounts with us.|
|Communications||Information available from correspondence and conversations between us. Information we learn about you in order to provide our services to you and details regarding the actual services that we provide to you.|
|Social Relationships||Your family, friends, business associates and other relationships.|
|Socio-demographic||This includes details about your age, gender, where you work or your profession, your nationality, ethnicity, education levels and where you fit into income and social-economic groupings.|
|Locational||Information that we obtain about your physical location which may come from your mobile phone, the address where you connect a computer or mobile device to the internet.|
|National Identifier||The number or code given to you by a government entity to identify who you are such as your National Insurance Number.|
|Open Data & Public Records||Information about you that is available in public records such as the Electoral Register or Companies House and other information about you that is openly available on the internet.|
|Special categories of data||The law treats some types of personal data as being special and we only collect and use these types of data if the law allows us to do so. Special categories of data that we may process include:-|
|Behavioural||Details about how you use our products and services and your attitude to risk|
|Preferences||Any permissions, consents or preferences that you indicate to us such as how you would like us to contact you.|
|Documentary Data||Details about you that are stored in documents or copies of them (for example your passport, drivers licence or birth certificate).|
|Usage Data||Other data about how you use our services.|
- Where we get your information from
We will collect personal information about you (or other related parties or your business) from you, from other companies within our Group and from others as follows:
Information you give to us:
- When you apply for our services or complete other forms or documentation
- When you talk to us either in person or over the telephone
- Correspond via emails or letters or via our website
- During review meetings
- Information we collect when you use our services such as the nature of transactions originated by you.
- If you provide us with details of other individuals, you agree to inform them of our use of their data as detailed in this privacy notice.
Information from third parties we work with:
- Your professional advisers
- Organisations that introduce you to us
- Credit reference agencies such as Experian, Equifax and Smartsearch
- Fraud prevention agencies
- Government and law enforcement agencies
- Land agents
- Public information sources such as Companies House
- Medical practitioners
- Agents working on our behalf
- Companies that you work for or hold shares in
- How long will we keep your information?
We do not keep information for longer than is needed or required. If you are or were a Hurley Partners client we are required to keep your information for up to 7 years after your relationship with us ends. We are obliged by regulation to keep documents relating to pension advice and scheme administration indefinitely. Recordings of phone conversations with you are kept for 5 years.
If you do not become a client of ours and we have collected information in the course of making proposals to you, we will keep this for one year after we last heard from you.
Information that we may provide to other organisations such as law enforcement, fraud prevention or credit reference agencies will operate different retention periods over which we have limited, if any, control.
- Your rights
We want to make sure you are aware of your rights in relation to the personal information we process about you. These are shown in the table overleaf.
|Access – You have a right to get access to the personal information we hold about you||If you would like a copy of the personal information we hold about you, please contact us as shown on page 9.|
|Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.||If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.|
Please note that if you request us to restrict processing your information, we may have to suspend the operation of the services we provide to you.
|Erasure – You have a right to request that we delete your personal information.||You may request that we delete your personal information if you believe that:|
|Restrict Processing – You have a right to request us to restrict the processing of your personal information.||You may request us to restrict processing your personal information if you believe that:|
|Portability – You have a right to data portability.||Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format.|
You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your information, which will be governed by their agreement with you and any privacy statement they provide to you.
If you would like to request the personal information you provided to us in a portable format, please contact us as shown on page 9.
|Objection – You have a right to object to the processing of your personal information.||You have a right to object to us processing your personal information unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the provision of our services to you.|
|Marketing – You have a right to object to direct marketing.||You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing.|
|Withdraw consent – You have a right to withdraw your consent.||Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.|
|Lodge complaints – You have a right to lodge a complaint with the regulator.||If you wish to raise a complaint on how we have handled your personal information, you can contact our Operations Director who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit ico.org.uk|
- Who we might share your personal information with
Your personal data may be disclosed to other members of our Group, our agents, brokers and connected parties, and other financial institutions whose products we may provide or propose for you.
We may also share your personal information with:
- Other companies that we introduce you to
- HM Revenue & Customs, amongst other regulatory bodies and authorities
- UK Financial Services Compensation Scheme
- Credit reference agencies
- Fraud prevention agencies
- Parties linked directly to you by contract, such as a spouse with a joint account
- Agents and advisers who we use to help run your accounts and services, collect what you owe and explore new ways of doing business
- Companies, organisations or people where you have agreed with us to share your data.
We may need to share your personal information with other organisations to provide you with the product or service you have chosen.
We may also share your personal information if there are any corporate changes to the Group in the future:
- Where we may choose to sell, transfer, or merge parts of our business, or our assets.
- During any such process, we may share your data with other parties. We’ll only do this if they expressly agree to a formally binding contract to keep your data safe, private and confidential.
Some of the information you provide to us may be transferred to, stored and processed by third party organisations which process data for us and on our behalf. These third parties may be based (or store or process information) in the UK or elsewhere including outside of the EEA. As with many financial institutions, these third parties may include third party IT platforms (including cloud based platforms), suppliers of administrative and support services and suppliers of other specialist products. Section 7 explains how we ensure your data is handled in accordance with data protection legislation in these cases.
We may also be obliged to disclose data under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws. For example, we work with law enforcement agencies to support their duty to detect, investigate, prevent and prosecute crime.
Detecting fraud or money laundering
We use your personal information to help us to decide whether your personal or business accounts may be being used for fraud or money-laundering. We may detect suspicious activity on your account which could suggest that an account is being used in ways that fraudsters frequently work. Alternatively, we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them. Fraud prevention agencies will also keep a record of the risk that you or your business may pose. This may result in other organisations refusing to provide you with products or services, or to employ you.
- Transferring information overseas
Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside of the European Economic Area (EEA). Where this is necessary, we will ensure that we do this in accordance with current data protection legislation by only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission. We will only send your data outside of the EEA if:
- We need to provide information to a service provider who may be based outside of the EEA
- It is required in order to follow your instructions
- You request us to
- We have to comply with a legal duty
- We are establishing, exercising or defending our legal rights
- We are otherwise permitted to do so under applicable data protection laws
- Telephone Calls
To help us improve our service, telephone calls with you will be recorded and may be monitored for regulatory, training, quality and complaints’ investigation purposes.
Hurley Partners does not engage in mass marketing of services and opportunities to clients. We may from time to time use your personal information to tell you about relevant services that we think may be of specific interest or benefit to you. We also invite clients to social events which we believe from our knowledge of you will be of interest. We hope that you find the information and invitations of interest but if you would prefer not to receive this type of marketing information please let us know. You will also be given the opportunity when we initially establish a relationship with you to tell us whether or not you’d like this information and in what formats. We will not lend or sell your information to third parties.
- Websites and Cookies
Other Websites – Our website may link to other websites. Our Privacy Notice only applies to our website. You should appraise yourself of the privacy policies of these other websites.
Cookies – A cookie is a small piece of text stored on a user’s computer by a web browser. Most modern browsers allow you to decide whether to accept cookies, and the time frame to keep them, but rejecting cookies may impair some of the functionality of our Website. We undertake not to abuse the personal identification aspect of cookies. We use the information to track visitor use of the Hurley Partners website and to compile statistical reports on website activity. Our website only uses strictly necessary cookies that are required for the operation of the website. The only cookies we use are:
- utma – used by google analytics to track information on our website.
- utmz – again used for Google analytics purposes – scroll down to see more info on this page https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage there is table which lists those two cookies
- is_cookie_accepted – used to store the users choice to accept cookies. These are used for display features during the navigation of the site and they expire at the end of your session.
- Changes to this Privacy Notice
We keep our Privacy Notice under regular review. Where it is necessary to make any material changes to this notice we will advise you.
- Who to contact?
The Operations Director
Hurley Partners Limited
12 Conduit Street
London, W1S 2XH
Hurley Partners Limited is a limited company registered in England & Wales.
Registered office: 12 Conduit Street, London, W1S 2XH.
Authorised and regulated by the Financial Conduct Authority. No.665051
© Hurley Partners Limited 2020