Privacy Statement

Privacy Policy

We take your privacy very seriously and ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact supervisory authorities and us in the event you have a complaint.

Who we are
HRi Investments Ltd is a regulated financial advisory firm (company number 02905291) and our registered office is 2 Blade Mews, London SW15 2NL.  HRi Investments Ltd is authorised and regulated by the Financial Conduct Authority (FCA) and our Financial Services Register number is 170637.
 
When we mention “we”, “our”, “us”, “the Company” we are referring to HRi Investments Ltd.  
We provide you with financial advice excluding mortgages and equity release products.

What personal data we collect
Our service requires we collect some, or all, of the following:
* Contact information
* Identity information
* Financial information
* Employment status
* Lifestyle information
* Health information
* Product details
* Details of any vulnerability
* Details of dependents/beneficiaries under a policy

If you are providing information about another person, we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns, please contact us in one of the ways described below.

Information collected from other sources
We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party, it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:

 From product providers:
  • product details
 From identification and verification checking agencies:
  • identity information
  • sanction check information

For what purpose
We need all the information listed above (see: What personal data do we collect and Information collected from other sources) primarily to undertake our contracted services with you and to comply with the law. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

  a) To register you as a client;
  b) To process enquiries and respond to requests;
  c) To communicate with you;
  d) To perform our service;
  e) To manage our relationship with you, including notifying you about changes to our contract or  
      services or asking you to provide us with feedback;
  f) To administer and protect the business and our website;
  g) To follow up the referral with a survey assessing the service you have received from the IFA you have
      been referred to;
  h) To improve the quality of our services;
  i) We may periodically use your email to send our newsletter updating you on areas we believe of
     interest to our clients, though you may unsubscribe from this;

How we use your personal data
The table below shows the legal basis in which we use and retain your personal data and with whom that data may be shared.

Rationale for Processing Lawful basis for processing Third party recipients linked to that activity
To provide you with intermediary services Performance of a contract Include details of who the data will be shared with
To apply for quotations and products for protection insurance products on your behalf Performance of a contract Product Providers
To retain records of any services or advice provided to you by us in order to defend potential legal claims or complaints. Legitimate interests External supplier(s) of data storage and data hosting services to retain records on our behalf
To provide you with details of products and services from third parties and us that may be of interest to you in accordance with your preferences. Consent IT Systems and Software Providers

Special Category Data
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.


We may process:

  • health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
  • criminal conviction or offence information when providing intermediary services in relation to a protection product


In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.

In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above table, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.


Marketing
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:

  • By phone: 0208 875 6480
  • By email: info@hri-investments.co.uk
  • By Post: HRi Investments Ltd, Gable House, 18-24 Turnham Green Terrace, London W4 1QP.


Whether information has to be provided by you, and if so why
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, you must provide your personal data in order for us to provide you with intermediary services.


How long your personal information will be kept
We will keep your personal information securely stored for as long as we need it to provide you with the services you want from us. We so keep it to comply with our legal and regulatory obligaaltions and to help us to resolve any issues or disputes that may arise.

Depending on what information we hold and what products or services you are signed up to, we may need to retain certain details for longer than others. In every case, we regularly reassess whether we need to hold your personal information and securely dispose of any information that we no longer need.


Transfer of Information outside the EEA
We will not transfer your personal data outside of the European Economic Area (EEA) or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

The management of information about you
We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to.


Any personal information we hold about you is stored and processed under our data protection policy, in compliance with the General Data Protection Regulations 2018.


Your rights
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:


  • To access personal data
  • To correct / erase personal data
  • To restrict how we use personal data
  • To object to how we use personal data
  • To ask us to transfer personal data to another organisation
  • To object to automated decisions
  • To find out more about how we use personal data


We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.


We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.


We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests.  We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.


We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.


To access personal data
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.


You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.


You can also ask that we erase your personal data if you have either:

  • withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or
  • exercised your right to object to further legitimate use of your information, or 
  • where we have used it unlawfully or 
  • where we are subject to a legal obligation to erase your personal data.


We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.


To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example


  • where you think the information is inaccurate and we need to verify it;
  • where our use of your personal data is not lawful but you do not want us to erase it;
  • where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
  • where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.


We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.


To object to use of personal data
You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our

legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.


To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).


You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.


To contest decisions based on automatic decision making
If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision-making processes to protect your rights and freedoms.


You can contact us for more information
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about:

  • what personal data we have about you,
  • what we use your information for,
  • who we disclose your information to,
  • whether we transfer it abroad,
  • how we protect it,
  • how long we keep it for,
  • what rights you have,
  • how you can make a complaint,
  • where we got your data from and whether we have carried out any automated decision making using your personal data.


If you would like to exercise any of the above rights, please:


  • email or write to John Page our Data Protection Officer at john@hri-investments.co.uk or HRi Investments Ltd, Gable House, 18-24 Turnham Green Terrace, London W4 1DX;


  • let us have enough information to identify you, e.g. name, address, date of birth;
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know the information to which your request relates.


Keeping your personal data secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.


Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.


How to contact us
Please contact us if you have any questions about this privacy notice and the information we hold about you.


Please send us an email to info@hri-investments.co.uk or write to HRi Investments Ltd, Gable House, 28-24 Turnham Green Terrace, London W4 1QP.


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