Privacy Policy

In this Privacy Policy when we refer to “HCDWS” or “we”, “us” or “our”, we mean Host Capital Digital Wealth Solutions Limited.

This Privacy Policy

Host Capital Digital Wealth Solutions Limited (“HCDWS”) is committed to protecting the privacy of individuals who use our services or even if you are just visiting our website.

Under the General Data Protection Regulation 2016, HCDWS, registered at Windmill Place, Hill Green, Newbury, Berkshire, U.K. RG20 8RB, is defined as the controller. This Policy sets out the way HCDWS process, store and protect user data and information that you may supply to us. It also outlines the obligations and requirements of the users, the website and website owners.

You may contact us at any point with regards to this Privacy Policy or the way your personal data is being processed by one of the following means:

Postal address: Windmill Place, Hill Green, Newbury, Berkshire, U.K. RG20 8RB

Updates to this website Privacy Policy

From time to time we may amend this Privacy Policy to fall in line with changes to legislation, including from but not limited to the General Data Protection Regulation 2016, Privacy and Electronic Communication Regulation 2003 and the Data Protection Bill 2017 – 2019.

Any changes, updates or amendments to this Policy will be shown on our website with the date of the latest update.

Personal Data

‘Personal data’ is defined in law as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This may include but will not be limited to, name(s), email address, telephone number, bank details, date of birth, national insurance number.

We do not collect or amass personal data outside the delivery of a contract or the purposes of employment, nor do use said information for anything other than delivering the service that you signed up for. The personal data that we collect will never be sold to any third party for marketing purposes.

Purposes for the processing of personal data

When you enter a contract with HCDWS, you will always have clear visibility with regards to the type of personal data that is being collected.

You will have the opportunity to review the purposes of the data collection and you will have the choice to either approve or disapprove. Please note, that if you do not approve or agree to disclose the information required for the delivery of our services, we will be unable to provide these services as we are required to collect certain types of data under FCA regulation.

The information that is collected by HCDWS is used for the following purposes:

Business operations

  • The provisioning of financial services and products

Legal obligations

  • Anti-money laundering checks
  • Criminal background checks
  • Regulatory requirements

Personal Data Retention Periods

In general, and subject to exceptions, our main personal data retention periods are as follows:

Personal data of investors invested in any of our financial Products may be retained for up to 7 years after the relevant Product has ended, or up to 7 years after the earlier end of the relevant Product’s contractual relationship with the Product provider, for regulatory and legal purposes.

Our staff’s personal data is retained for up to 7 years after the termination of employment for contractual and legal purposes. Staff’s financial personal data is retained for 7 years on a rolling basis based on HMRC requirement.

Personal data we obtain as part of a recruitment process for a specific role related to candidates that have undergone an interview process is retained for 6 months after the role has been filled for legal purposes, unless longer retention periods have been agreed with and communicated to you by us or the recruitment agent as applicable.

Personal data we obtain in relation to employment candidates who have not been invited for an interview is deleted immediately upon internal review, unless communicated to you otherwise by us or via the recruitment agent as applicable.

If you are unsure about our retention periods related to your personal data, please contact at info@HCDWS.com

Consent

Where HCDWS needs to collect or pass on your information to a third party, we will obtain your consent where we require consent as grounds for processing. For example, if we need to process any highly sensitive or “special categories” of data, we will obtain your consent and explain the purposes of processing prior to doing so.

Third party sharing

HCDWS will never sell or share any of your details to others for marketing or advertising purposes. It may be necessary to provide your information onto a third party for the delivery of a service that you have requested, however we will always ensure that the appropriate safeguards are in place to protect your information prior to transferring.

HCDWS may share your information with parties that we have vetted and authorised for the provisioning of a service. Such parties include staff members, financial advisers, transfer agents and other services providers that we use to be able to deliver our services. These third party processors may disclose your information to others for the delivery of the service you have requested; please ensure you have familiarised yourself with their terms and conditions and / or their privacy notices.

If you would like a copy of our authorised third parties, please contact us at info@HCDWS.com. Please note that we will only disclose this information to those that we process data regarding.

Where we believe there is a need to investigate, prevent or report illegal activities, suspected fraud such as money laundering, issues pertaining to threats to the physical safety of any person we may pass your information onto other 3rd parties including but not limited to The Metropolitan Police, City Of London Police, Serious Fraud Office, Information Commissioners Office or the Health and Safety Executive.

Where your data is transmitted internationally, outside of the EEA, we shall ensure that enforceable binding contracts are in place in the absence of a suitable data protection legislation. We will not conduct business where there is neither an enforceable contract nor a suitable data protection legislation.

Social Media

Our website uses well known social media networks such as Twitter and Facebook to share and promote our content. On our website, you will usually find “like” buttons to view or share our content on social media networks which will take you to the relevant social media site. No related cookies are left on our website.

Cookies in use on this website

For any information regarding the cookies that are used on this website, please refer to the Cookie Policy.

Security controls

HCDWS has implemented a number of organisational and technical controls to ensure that the confidentiality, the integrity and the availability of the data that we process is always preserved. The main objective of those controls is to help protect your information from loss, destruction, misuse, unauthorised access or disclosure. The combination of organisational and technical controls ensures that your data is processed securely at all times.

Organisational controls

  • User access controls and limitation of data access has been implemented to ensure that only the authorised staff members have access to data.
  • We have adopted a data retention policy for the datasets that we process. The retention period for the data are either based on legal requirements set by the regulatory body or on a legitimate purposes basis to carry our business operations.
  • A password policy is in place.
  • We regularly review our information security policies and procedures to ensure that it is up to date with the latest technology and most importantly with the latest legislation with regards to data protection and data privacy.

Technical controls

  • Encryption has been and is being implemented on computer equipment that requires encryption to ensure that data will not be available in the event of loss or theft.
  • Passwords are used for data that is in transit and for email communication whilst e-mail encryption is being implemented.
  • Antivirus and malware protection is installed on all computer equipment.
  • We have implemented secure browsing (https) on our website to ensure that network packets are encrypted and that no data can be intercepted.
  • Regular backups of our data to ensure that it is readily available in the event of a technical issue or a natural disaster.
  • A firewall is installed within our corporate network to ensure that our assets are constantly protected against cyber-attacks and intrusion attempts.

Other Sites and external links

Our website may contain links to other sites that are not controlled by us; therefore we are not responsible for the content or use of these services. Please ensure that you understand this and also please review those website privacy policy and terms and conditions. HCDWS cannot and will not be held liable for any damage that might have been caused to your computer equipment by those websites. Such damage include but are not limited to: loss of data, exfiltration of data, unauthorised intrusion, virus and malware infection, hardware damage. The use of any external link or website is at your own risk.

General Data Protection Regulation Rights

You have many rights under the GDPR, they are defined as below:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object

Rights in relation to automated decision making and profiling.

If you are an existing client of us as the data controller or if you are a former employee or had another relationship with HCDWS and you would like to exercise your rights please contact us at info@HCDWS.com.

If you are an existing client of us as the data processor please contact your data controller who will then assist you in exercising your rights with us as a processor.

When an access request is submitted to us, we must verify your identity before any data can be sent to you. If we are unsure about your identity or if our controls do not match the information that is gathered, we reserve the right to nullify the access request.

Additional information

If you have any questions with regards to this Privacy Policy, the way your data is handled or if you would like to exercise any of your rights under the General Data Protection Regulation, please contact us at info@HCDWS.com

If you would like to learn more about the current regulations and legislations about data protection, please refer to the following links:

The General Data Protection Regulation (GDPR)

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

The Privacy and Electronic Communications Regulation (PECR)

https://ico.org.uk/for-organisations/guide-to-pecr/what-are-pecr/

For any concerns with regards to your personal data, please contact the Information Commissioner’s Officer at the following link:

https://ico.org.uk/

This Policy was updated on the 16th September 2019


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