Terms and Conditions - Privacy Policy

About us

Hilbert Investment Solutions Limited (“HILBERT”) is authorised and regulated by the Financial Conduct Authority (FCA), No. 698380. Companies House Number 08956837.

HILBERT is committed to protecting and respecting your personal data, and we do not access or use it for any purpose other than providing, maintaining, and improving our services, and as otherwise required by law. We collect personal information from you to enable us to establish and verify your identity, opening account, administration, marketing and customer services to ensure that the content and services that we offer are tailored to your needs and interests.

Collection of your personal data

HILBERT manages and collects your personal data including but not limited to, through its websites, emails, post, and telephones to ensure that we meet our obligations to respect our clients' privacy and that all such information remains confidential. We obtain and store personal information in order to open and maintain client investment accounts. We are bound by the terms of the Data Protection Act 2018, and the General Data Protection Regulation EU 2016/679.

Processing your personal data

Your personal data is processed by the staff of HILBERT that need it for the execution of contractual, legal and regulatory obligations.

We process the personal data in compliance with the provisions of UK and EU GDPR and the applicable local legislation as amended from time to time. Please note that we may also be processing information in relation with all or one of the following:

  • Any anti-money laundering legislation and recommendations;
  • The Markets in Financial Instruments Directive II (MiFID II) and all relevant implementing rules and regulations;
  • Performing our duties and/or obligations and exercising our rights under our business relationship, such as communicating with you with regards to updates to our products, services and/or marketing guidelines;
  • Safeguarding our legitimate interests.

Sharing your personal data

To comply with the law and the regulatory obligation, and to protect the security or integrity of our services rights and interest, HILBERT may share or disclose your personal data to but not limited to:

  • Solicitors/lawyers,
  • External auditors or advisors,
  • Banks/Financial Institutions,
  • Credit reference agencies,
  • Courts, regulators, governmental, administrative or any other official bodies as agreed or may be required by law.

International data transfer

HILBERT stores all your personal data on secure servers. We use rigorous procedures to protect against loss, misuse, unauthorized access, alteration, disclosure, or destruction of your personal data. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

The personal data that we collect from you may be transferred to and stored at a destination outside the UK or European Economic Area (EEA), including at destinations that are or aren't subject to a decision by the European Commission establishing an adequate level of protection of personal data. It can be shared with other companies within the HILBERT Group, processed by staff working for us or for one of our suppliers, located outside the EEA. Such personnel may for example be involved in execution of our support services. We will take all reasonable necessary steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy and have adopted appropriate safeguards to protect it.

Please note that if service providers in a third country are used, all reasonable and practicable measures will be taken to ensure that they will comply with the data protection level in Europe in accordance with the GDPR.

Any transfers to parties located outside the European Union will be in line with the legal and regulatory provisions of the GDPR and applicable local legislation as amended from time to time.

Data storage

We will keep your personal information for as long as we maintain our business relationship. Upon termination of our business relationship we will maintain your data in compliance with our legal and regulatory obligations for a period of 5 to 7 years. Further, any personal data will not be retained for longer than the time necessary for satisfying the purposes of its processing, subject to the general statutory limitation periods and the mentioned retention period where the applicable laws requires that the personal data is retained for a certain period after the termination of our business relationship with you.

At the expiration of data retention time the data is erased by irreversible destruction and/or is anonymised.

Marketing

Where you have consented to direct marketing, we may send you marketing material of our products, news and services from time to time by email, telephone, post or other electronic messaging services.

You can object at any time to your personal information being used for marketing purposes by contacting HILBERT to opt-out at any time.

Your rights

Access to and correction of your personal data - You have the right to access data held about you. Your right of access can be exercised in accordance with UK & EU GDPR and other applicable laws.

When you contact us about a potential personal data error, we will confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry.

Restriction of your personal data - You have the right to request a restriction of your personal data, and in most circumstances, we will only store your data unless we need to use it for the establishment, exercise or defense of a legal claim, for the protection of the rights of another natural person, or in the public interest. You may request a restriction of your data where you contest the accuracy of your data while we work to verify the data source, where you oppose to our data erasure and you request the restriction of your data instead, where your data is required for a legal reason, or where your data is pending verification as to whether we can retain the data in our legitimate interest.

Erasure of your personal data - You may request for your data to be erased, which is also known as your 'right to be forgotten'. You can successfully exercise this right where we no longer have a legal reason under the UK & EU GDPR to hold your data unless we are required to retain your data for the establishment or defense of legal claims. We will action all requests in accordance with the GDPR regulation.

Portability of your personal data - You have a right to ask us to provide your personal information to a third-party provider of services.

Complaints - If you have any complaints or concerns about our handling of your personal information please contact our compliance department on:

UK
Email: contact@hilbert-is.com,
Post: 27 Clements Lane, London, EC4N 7AE
Telephone: +203 808 7138

Changes to our privacy policy

We reserve the right to modify our Privacy Policy from time to time and without notice. If we make significant changes in the way we treat your personal data, or to the Privacy Policy, we will endeavour to provide you notice through our website or by some other means, such as email.

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