Hamilton Financial (Scotland) Ltd Privacy policy

Hamilton Financial is authorised and regulated by the Financial Conduct Authority (485546). We provide financial advice and investment management on an advisory basis.

We are committed to protecting and respecting your privacy and this policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the UK Data Protection Act 2018 and subsequently the General Data Protection Regulation (the Act), Hamilton Financial (Scotland) Ltd of 38 Dean Park Mews, Edinburgh, EH4 1ED is the data controller.

Information we may collect from you

Personal data, or personal information, means any information about an individual from which they can be identified.

We may collect, use, store and transfer different kinds of personal data about you such as:-

• Identity data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact data – includes home address, email address and telephone numbers.
• Financial data includes bank account.
• Transaction data includes details about transactions and trades that we place on your behalf.
• Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Usage data includes information about how you use our website, products and services.
• Communications data includes your preferences in receiving information from us.

If you contact us by post, telephone, e-mail or through our website, we may keep a record of that correspondence.

In particular, we are required to record all telephone conversations where an individual gives a specific instruction to execute a trade on their behalf. This will be done in written format by way of a note of telephone conversation.

We will on occasion require special categories of personal data in respect of health for certain products such as life insurance and income protection. If you do provide data of this nature, we will process it in accordance with the terms of this privacy policy.

How will we use the information we collect about you?

We will collect and process the information held about you in the following circumstances:

• Where it is necessary for the performance of a contract to which you are party.
• When we are required to comply with a legal obligation.
• If the processing is for our legitimate interest or those of a third party.

We will collect and process information about you for the following specific purposes:

• To enable us to provide the advice and investment management services required.
• To process the applications required to invest in funds or obtain suitable products.
• To provide clients with information relevant to their investment and our services.
• To ensure that our website is presented in the most effective manner for you and your device (eg. Cookies); and
• For all other purposes consistent with the proper performance of our advice, investment management and services.

We may contact you by post, telephone or email. If you change your mind about how you wish to be contacted, then please let us know. Should we require to process information for any purpose not included within this policy, we shall communicate this to you in advance of doing so.

Security

All personal information provided to us is stored on secure servers. While we take all reasonable steps to protect your personal data, its security cannot be guaranteed. Once personal information has been received, we will use strict procedures and security software to prevent unauthorised access. All reasonable steps will be taken to ensure that your data is treated securely and in accordance with this privacy policy.

Where we store your personal data

Your personal data may be transferred to, and stored in, a destination outside the European Economic Area (“EEA”). It may also be processed by staff based outside the EEA who work for us, or one of our third party business partners. If your personal information is transferred, we will take all steps necessary to ensure it is held securely and in accordance with this privacy policy – in particular by ensuring the appropriate technical and organisational safeguards are in place.

Disclosure of Information

We process all data in accordance with Data Protection Laws. We may share your information with third party business partners with whom we have contracted to help us provide our service to you.

We may have to send your data to organisations which help us to confirm your identity, to comply with Anti-Money Laundering regulations, or for other purposes such as the detection of crime. To confirm your identity, such processing may require the use of automated decision making by the relevant organisation. If the relevant organisation cannot confirm your identity, we will take additional measures to enable us to do so.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party business partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will not share your information for marketing purposes with any organisation outside the firms.

Your rights in relation to your personal information

Data protection laws give you rights in relation to your personal information, you can:

• Check whether we hold information about you;
• Ask to see a copy of the information we hold about you and under certain circumstances ask us to rectify any inaccurate and/or complete any incomplete personal information we hold about you.
• Ask us to stop processing your personal information.
• Ask us to erase your personal information.
• Ask us to restrict the processing of your personal information.
• Ask us to provide your personal information to you in a structured, commonly used readable format and have it transferred to another provider of the same or similar services.
• Withdraw your consent to processing.

In addition to the above you have the right to lodge a complaint with the Information Commissioner’s Office, or its successor.

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.

Retention of your personal information

Data protection laws allow us to retain your personal information for as long as is necessary for the purposes for which your personal information was obtained, or for longer periods where a statutory or regulatory requirement exists. Our record retention policy is to remove your personal information from our records 6 years after business relationship with you has ended, unless:-

• There is a statutory or regulatory reason why we require to retain your personal information for longer;
• We have already erased your personal information following an earlier request to do so.

Cookies

A cookie is a piece of software that places a text file on the hard drive of your computer that remembers information about the configuration of your computer (and its IP address) and collects standard internet log and visitor behaviour information. The information is used to track visitor use of the website and to personalise any repeat visits you make to our website.

Some cookies may contain personal information relating to you and therefore such cookies will be processed in accordance with this privacy policy. When you start to use our website you will be asked whether you agree to the use of cookies. You can set your browser not to accept cookies and you can remove existing cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other third party websites. Clicking on those links 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. When you leave our website, we encourage you to read the privacy notice of the websites you visit. This privacy policy only relates to our website.

Amendments to our privacy policy

This version of our policy was last updated on 1st May 2018. We keep our privacy policy under regular review and any updates will be made on this webpage.

How to contact us

If you wish to exercise any of the rights set out in this policy or should you have any questions or comments in respect of this policy, please contact us by either sending an email to vm@hamilton-financial.co.uk or by writing to Andrew Hamilton, Director, Hamilton Financial (Scotland) Ltd, 38 Dean Park Mews, Edinburgh, EH4 1ED.

Our registration number with the UK Commissioner’s Office is Z9572512.

Making a complaint

If for any reason you are not satisfied with our response, you can complain to the supervisory authority for data protection. In Scotland this is:

ICO Scotland contact details

The Information Commissioner’s Office – Scotland
45 Melville Street
Edinburgh
EH3 7HL

Telephone: 0303 123 1115

Email: Scotland@ico.org.uk