- on the types of personal data that Hope Capital will collect;
- why Hope Capital will collect and use your personal data;
- when and why we will share personal data within Hope Capital and with other organisations;
- the rights and choices you have when it comes to your personal data; and
- why and how it collects and processes your personal data through your use of its website, including any data you may provide through its website when you use any of the services by Hope Capital or invest in any of their products and to anyone else who contacts or otherwise submits information to Hope Capital.
2. THIRD PARTY LINKS
Hope Capital’s website may include links to third-party advertisers, affiliates, websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements, notices or policies. When you leave our website, we encourage you to read the privacy notice of every website you visit. We do not accept any responsibility or liability for the privacy policies or notices on third-party websites.
Please check these policies before you submit any personal data to these websites. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. HOPE CAPITAL AND THE DATA CONTROLLER
3.1. Hope Capital
3.2. Data Controller
4. WHY WE MAY COLLECT DATA ABOUT YOU
There are many reasons why we may legitimately collect and process your personal information and data, including:
In specific situations, we can collect and process your data with your consent.
b. Contractual obligations
We may process your information where it is necessary to either enter into a contract with you for the provision of our products or services or to perform our obligations under that contract or to provide you with advice or guidance in relation to our products or services that are offered by us.
c. Legal compliance
If the law or any regulator in any competent jurisdiction requires us to, we may need to collect and process your data and also provide this to any such regulator
d. Legitimate interest
We may process your information in the day to day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you.
5. HOW WE MAY OBTAIN AND SHARE YOUR DATA AND INFORMATION
We may obtain information in several ways which may include:
- Information which you give to us;
- Information that we receive from third parties – including other companies in Hope Capital, third parties who provide services to you or us (including via credit reference agencies, fraud prevention agencies or government agencies), and other banks (where permitted by law). We may also share data with credit reference agencies, such as Experian.
- Information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
- Information that we gather from the technology which you use to access our services (for example an IP address or telephone number;
- Information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.
6. WHAT INFORMATION WE MAY COLLECT AND PROCESS
- basic personal information, including name and address, date of birth and contact details;
- financial information, including account and transactional information and history;
- information about your family, lifestyle and social circumstances(such as dependents, marital status, next of kin and contact details); information about your financial circumstances, including personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history and needs and goals;
- education and employment information; goods and services provided;
- visual images and personal appearance (such as copies of passports or CCTV images); and
- online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, site visits and spending patterns. Where permitted by law or to fulfil our regulatory requirements, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.
7. HOW WE USE YOUR INFORMATION
We may use your personal information and/or data to:
- Administer, operate, facilitate and manage your relationship and/or account with Hope Capital. This may include sharing such information internally as well as disclosing it to third parties.
- Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, etc., in connection with your relationship and/or account;
- Provide you with information relating to our products and services
8. DISCLOSURE OF YOUR INFORMATION (INCLUDING OUTSIDE OF THE EUROPEAN ECONOMIC AREA “EEA”)
We may share your personal information within Hope Capital. When we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data with such third party. We will only share your personal data in compliance with the applicable data protection laws and regulatory requirements. We may disclose your information to third parties:
- When you specifically request this, such as when you submit information to inquire about jobs or submit a job application through the Hope Capital website;
- When other products and services within Hope Capital may interest you provided we have your consent;
- including buyers or sellers or any of our business or assets in which case we would write to advise you
- if we are under a duty to disclose or share your personal data to comply with any legal obligations or regulatory requirements or to protect the rights, property or safety of: (i) The Hope Capital website, (ii) our customers, or (iii) This includes (but is not limited to) exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may transfer data within Hope Capital and third-party agents so that Hope Capital can comply with the terms of this Privacy Notice and for the marketing of goods and services within Hope Capital. Transfers may be made outside the EEA where we are satisfied that appropriate safeguards are in place over the transferring and processing of such information or data. We may share some broader statistics and customer profiling information with third parties and within Hope Capital, but the information or data will be anonymised, so you will not be identifiable from that data. We will not rent or sell your data and/or information details to any other organisation or individual.
9. STORAGE OF YOUR PERSONAL DATA (INCLUDING OUTSIDE OF THE “EEA”)
The data and information that we collect, and process may be transferred to, and stored at, a destination outside of the UK. We will only do so on the basis that anyone to whom we transfer it to, protects it in the same way that we would and such entity or person or other third party is subject to the appropriate safeguards. In the event that we transfer information to countries outside of the EEA, we will only do so where:
- the European Commission has decided that the country or the organisation, entity or individual to whom we are transferring to or sharing your data and/or information with, will protect your information adequately;
- the transfer has been authorised by the relevant data protection authority; and/or
- we have entered into a contract with the organisation, entity or individual with whom we are sharing your data and/or information (on such terms as approved by the European Commission), to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses in such contracts, please contact us at firstname.lastname@example.org
11. YOUR RIGHTS
If at any point you believe retained information is incorrect you can request to see this information and even have it corrected and possibly deleted. Providing you with this information is free of charge, but charges may apply for excessive requests.
If you wish to raise a complaint on how we have handles your personal data, you can contact our Data Protection Office who will investigate the matter. Where relevant, you have the right to withdraw consent and object at any time and this means that we cannot process your data provided without your consent. More information about your rights can be found on the Information Commissioner’s website. https://ico.org.uk/
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO). Our Data Protection Officer can be contacted on 0345 494 0708 or hello@ hope-capital.co.uk
12. HOW LONG WE KEEP YOUR INFORMATION
By providing you with products or services, we create records that contain your information, and/or data such as customer account records, activity records, tax records and lending and credit account records. Records can be held on a variety of media (physical or electronic) and formats. We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and/or regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities. Retention periods for records are determined based on the type of record, the nature of the activity, product or service, applicable local legal or regulatory requirements. Retention periods may be changed from time to time based on business or legal and regulatory requirements. We may, on exception, retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the any courts of competent authority, or in relation to an investigation by law enforcement agencies or our regulators. This is intended to make sure that we are able to produce records as evidence, if needed to those respective authorities. If you would like more information about how long we keep your information, please contact us at email@example.com
13.1 Cookies – Privacy and Your rights
Cookies are used to uniquely identify a person and therefore at Hope Capital we treat them as personal identifiable information. Cookies are used for analytics and advertising to improve the experience and relevance of our websites. At Hope Capital we want our customers to understand what cookies are by being jargon free, whilst also being transparent regarding how we use them, please see the
- What are cookies?
- What cookies do we use? and
- How do I turn cookies off? so you are fully aware.
13.2 What are cookies?
Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the domain you are visiting are called “first party cookies.” Therefore, cookies served by Hope Capital whist you visit www.hope-capital.co.uk are first party cookies. Cookies served by companies that are not operating the domain you’re visiting are called “third party cookies.” For example, we may allow Google to set a cookie on your browser while you visit www.hope-capital.co.uk, and that would be a third-party cookie. Cookies may also endure for different periods of time. “Session Cookies” only last only as long as your browser is open. These are deleted automatically once you close your browser. Other cookies are “persistent cookies” meaning that they survive after your browser is closed. For example, they may recognise your device when you re-open your browser and browse the internet again.
13.3 What cookies do we use?
We use the following cookies:
- Analytical and performance cookies. We may use analytics service providers in relation to The Hope Capital website’ traffic analysis and reporting. Analytics service providers generate statistical and other information about the use of the Hope Capital website by using cookies. They allow us to recognise and count the number of visitors and to see how often visitors return to the Hope Capital website, how long they stay and how visitors move around the Hope Capital website when they are using them. This helps us to improve the way the Hope Capital website work, for example, by ensuring that users are finding what they are looking for easily. The information generated relating to the Hope Capital website may be used to create reports about the use of Hope Capital’s website and the analytics service provider will also store this information.
- Advertising and targeting cookies. These cookies record your visit to Hope Capital’s website, the pages you have visited and the links you have followed to other websites. We will use this information to try and make Hope Capital’s website and other websites that you visit more relevant to your interests. We may also share this information with others, within Hope Capital and carefully selected third parties for this purpose.
- Functionality cookies. We may use functional cookies that allow us to remember choices you have made in relation to Hope Capital’s website so as to provide a more personalised experience and enhanced user experience by delivering content specific to your interests.
13.4 Strictly necessary cookies – Third party cookies
13.5 How Do I turn cookies off?