Last revised: 20th June 2024
HFMC Wealth takes the privacy and security of your personal information very seriously. We will only use your personal data to administer your account and to provide the products and services that you have requested from us.
However, from time to time we would like to contact you.
HFMC Wealth and the entities listed as data controllers below (together referred to as “we” or “us”) are committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you or third parties 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 Data Protection Act 2018, the data controller in respect of the HFMC Wealth websites
(www.hfmcwealth.com, www.hfmceb.com and www.hfmcmortgages.com) are as follows:
The data controller for HFMC Wealth Ltd, (incorporated in England and Wales as a limited company
Registered Number: 01911493).
The data controller for HFMC Wealth Partners LLP (incorporated in England and Wales as a limited liability company partnership Registered Number OC309139).
The data controller for HFMC Wealth Management Ltd (incorporated in England and Wales as a limited company Registered Number 02355062).
The data controller for Aspinalls Family Office LLP (a partnership registered in England and Wales under company number OC350440).
The data controller for Aspinalls Private Clients Ltd (a company registered in England and Wales under company number 08637053).
The data controller for HFMC Private Client Services Ltd (a company registered in England and Wales under company number 05993367).
The data controller for HFMC Wealth Holdings Ltd (a company registered in England and Wales under company number 10271944).
The data controller for HFMC Group Services LLP (incorporated in England and Wales as a limited liability company partnership Registered Number OC373151).
The data controller for HFMC Group Holdings Ltd (a company registered in England and Wales under company number 05484681).
The data controller for HFM Trust company Ltd (a company registered in England and Wales under company number 03003517).
The data controller for Aspinalls Fiduciary Ltd (a company registered in England and Wales under company number 05055979).
The data controller for R&S Associates Financial Planning Ltd (a company registered in England and Wales under company number 09763763).
The data controller for Weston-Cummins Ltd (a company registered in England and Wales under company number 02540744).
The above named are part of the HFMC Wealth Group of Companies and their registered office address is
Russell House, 140 High Street, Edgware, Middlesex, HA8 7LW.
For the purpose of the Data Protection Act 2018, the data controller in respect of our sister company, HFMC Asset Management and their website (www.hfmcam.com) is as follows:
The data controller for HFMC Asset Management Ltd (a company registered in England and Wales under company number 03891979, whose registered office is also at Russell House, 140 High Street, Edgware, Middlesex, HA8 7LW).
By visiting either the HFMC Wealth or HFMC Asset Management website or using our mobile and/or tablet apps (collectively referred to as “our sites”) you are accepting and consenting to the practices described in this notice.
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Mark Waller, HFMC Wealth, 29 St John’s Lane, Clerkenwell, London, EC1M 4NA, or you can email us, or call us on +44 20 7400 4700:
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here.
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
We may collect and process the following data about you when you engage us for financial planning, financial advice, mortgage advice, employee benefit services, investment management services and tax compliance services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may receive information about you from third parties. Where we receive information from a third party, we assume that they have obtained your consent prior to providing us with your information. For example, this could be a spouse providing details about their husband or wife.
The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be business in any industry, sector, sub-sector or location.
We may also receive information about you from a business that you are already contracted with, such as a pension provider, insurance company, investment company or a solicitor or accountant. We would only expect to be provided this information on request, and with your explicit permission.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required, we’ll obtain your explicit consent in order to collect and process this information.
Our legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass your information on to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
We may use information held about you in the following ways:
You have the following rights in relation to your information, which you may again exercise by writing to Mark Waller, HFMC Wealth, 29 St John’s Lane, Clerkenwell, London, EC1M 4NA, or you can email us, or call us on +44 20 7400 4700:
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
We may share the personal data we hold about you across the Group, subject to your agreement, to enable us to better understand your needs and run your accounts in the efficient way that you expect. Your personal data may also be used by the Group for customer modelling, statistical and trend analysis, with the aim of developing and improving our products and services.
HFMC Wealth will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on HFMC or the site; (b) protect and defend the rights or property of HFMC (including enforcing this agreement); and, (c) act under exigent circumstances to protect the personal safety of users of HFMC, or the public.
Where you do not enter a contractual relationship with HFMC Wealth we would expect to retain your information for a period of up to two years.
This timeframe has been selected as a reasonable time period for you to decide whether you wish to utilise the services of HFMC Wealth. Should this length of time be insufficient, and you wish to extend this period, we are then able to do so at your request.
Where you do not enter into a contractual relationship with HFMC Wealth, but a related third party does, and your data is provided with your consent and is relevant to support an assessment of ongoing suitability advice for them, and to meet our ongoing contractual obligations to them, we would expect to retain your information for a period of seven years after disengaging from us, unless there is a legal or regulatory requirement for us to maintain the data for longer.
Your personal data will be retained for as long as is necessary to enter into or perform a contract with you; or for compliance with a legal obligation under EU law or the laws of the United Kingdom; or for the establishment, exercise, or defence of future legal claims, usually seven years, however for some types of business this may be longer.
Everybody has a right to erasure under the General Data Protection Regulations. However, given that HFMC Wealth operates within a regulated financial services environment it is unlikely that we will delete or remove any data from our systems once a contractual relationship has been entered into as we may be required to provide this either by the Financial Conduct Authority, The Financial Ombudsman service or in the establishment, exercise, or defence of future legal claims. As such, data provided as part of a contractual relationship is likely to be retained until past the time of your death given the open-ended nature of some legal claims.
This does not impact upon your rights to rights of access, rectification, or portability of personal data. You also have the right to withdraw your consent to the processing of your data at any time.
We store your data on our secure servers in the United Kingdom and retain it for a period of seven years after disengaging with you, or longer if the law requires. However, your data may be transferred to, stored at, and processed at a destination inside or outside the European Economic Area by our partners or service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps necessary to ensure that your data is treated respectfully and securely and in accordance with this Privacy Notice.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
However, the internet is an open medium and we cannot guarantee that any information you send to us by email or via our sites will not be intercepted or tampered with; any transmission is at your own risk.
Some older browsers do not allow the use of current SSL technology and we therefore recommend that you use an up-to-date browser. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We’d like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out later.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or by clicking here.
Our sites may, from time to time, contain links to and from the websites of our partner network and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your data. Please check these policies before you submit any personal data to these websites.
HFMC Wealth uses “cookies” to make parts of our website work and to collect data that helps us understand our visitors better. A cookie is a text file that is placed on your hard disk by our web page server. Cookies cannot be used to run programs or deliver viruses to your computer.
Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile device when you browse websites.
Cookies don’t harm your computer. Like many other companies with a website, we use cookies to provide you with more relevant and useful information. We don’t store personally identifiable information such as credit card details, but we do use information gathered from cookies to help improve your experience of the HFMC Wealth website.
Our cookies help us:
On entering our website we request your consent to cookies being placed or used on your device for non- essential cookies. We still allow you to access our website if you don’t consent to these cookies. We are still able to use strictly essential cookies.
We have ensured that any non-essential cookies are not placed on our landing page (and similarly that any non-essential scripts or other technologies do not run until you have given your consent).
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to remembering your consent settings
These cookies do not store any personally identifiable information.
We use cookies to compile visitor statistics, such as how many people have visited our website, what type of technology they are using (e.g. Windows, Mac or Android) which helps us to identify when our website isn’t working, how long our clients spend on our website, what page they look at and so forth. This helps us to continuously improve our website. These “analytics” programs also tell us, on an anonymous basis, how people reached our web site (e.g. from a search engine) and whether they have been here before, helping us to develop our services for our customers.
All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies on your browser we will not know when our clients visited our site and will not be able to improve its performance.
Our website, like most websites, includes functionality provided by third parties. A common example is an embedded Vimeo hosted video. Disabling these cookies will likely break the functions offered by these third parties.
Except for essential cookies, most of the cookies on our websites expire at the end of your current session on our website. However, some of our cookies have an extended lifespan which ranges from 1 day to 26 years. Some of our cookies are persistent and will never expire. If the cookie used is a flash cookie, please note that flash cookies do not expire.
Our website provides you with the ability to select only strictly necessary cookies so that the site may still operate. You are able to turn off non-essential cookies by declining or removing your consent to them.
You can also usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our’s and a large proportion of the world’s websites as cookies are a standard part of most modern websites.
Amending cookies setting in different types of browser:
Cookie settings in Edge – https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-
25dc-1de753474879
Cookie settings in Firefox – https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox
Cookie settings in Chrome – https://support.google.com/chrome/answer/95647?hl=en-GB&co=GENIE.Platform%3DDesktop
Cookie settings in Safari – https://support.apple.com/en- gb/guide/safari/ibrw850f6c51/mac#:~:text=You%20can%20change%20Safari%20settings,blocks%20cook ies%20and%20website%20data.&text=In%20the%20Safari%20app%20on,other%20data%20on%20your
%20Mac.
It may be that your concern around cookies relates to so called “spyware”. Rather than switching off cookies in your browser, you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.
We reserve the right to revise or supplement this Privacy Notice from time to time. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Privacy Notice and so you are aware of what information we collect, how we use it and under what circumstances we disclose it.
29 St John’s Lane
Clerkenwell, London
EC1M 4NA
t: +44 20 7400 4700
HFMC House
New Road, Weybridge
Surrey KT13 9BW
t: + 44 1932 870000