This notice describes how Moulton Harrox Limited (“MHL”) uses personal data. It outlines MHL’s data protection obligations and your data protection rights under the General Data Protection Regulation 2018 (“GDPR”).
Moulton Harrox Limited is the data controller of your personal information, and this policy applies to the processing of activities by us. The name of the Data Protection Officer is Nicholas Hargrave.
Moulton Harrox is a trading name of Messels Limited, which is authorised and regulated by the Financial Conduct Authority.
Collection of your data
As part of providing our services, or information about our services, to you, and to ensure we do this in a compliant way we must collect some personal information from our members, potential members, visitors to our website and service providers or suppliers.
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might have expressed interest in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way. If you do not wish to receive this information, please contact us by emailing firstname.lastname@example.org or by writing to us at the following address:
Data Protection Officer
Moulton Harrox Limited
71-75 Shelton Street
Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.
We may collect the following types of information from actual or potential customers:
- Your full name, address and contact information including but not limited to phone number and email address;
- Your professional and employment details;
- Your identification details such as your passport or driver’s licence.
We obtain this information through your use of our services or our websites, the application process and from information provided in the course of ongoing customer communication.
Sensitive information: We do not process sensitive information.
Payment information: We may collect data necessary to process your payments, such as your payment instrument number (such as a credit card), and the security code associated with your payment instrument. All payment data is stored by Stripe. Your may find their privacy notice link here: https://stripe.com/gb/privacy
This information is held by us on servers based in the United Kingdom. When you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: the source of your IP address, the time of access, the date of access and the web pages you visited. We need this information to provide you with our services.
We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
We take care to ensure your personal information is safe, secure and is protected from misuse, interference, unauthorised access, loss, modification or disclosure. Your personal information is generally stored in our computer database. Any paper-based information is stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
- passwords are required to access the system and passwords and are not shared;
- employees have restricted access to certain sections of the system;
- all computers which contain personal information are secured both physically and electronically;
- print reporting of data containing personal information is limited.
We regard breaches of your privacy very seriously and will impose appropriate penalties where necessary.
When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. We may need to hold some information and maintain certain records for up to 7 years after the end of us providing services to you.
We may be required to disclose your personal information if requested to do so by law, or if we believe in good faith that such action is necessary;
- to comply with any legal process served on us or in circumstances where we are under a similar legal or regulatory obligation;
- to protect and defend our rights or property; or
- to act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us or any other user of the services in any way including, but not limited to, market or price manipulation, payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).
Where required to disclose information we reserve the right to share information, together with your identity with other financial services providers, banks, credit card companies, and appropriate regulatory and legal agencies.
Transfer of personal data abroad
We may on occasion need to transfer some of your information to other group companies or service providers in countries in or outside the EEA (European Economic Area). This may happen if our servers or suppliers and service providers are located elsewhere. When we transfer your personal data outside the EEA, we will ensure the data recipient is subject to the same data requirements under GDPR. By using our services and providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the EEA.
Your personal data rights
- You have the right to be informed,
- You have the right to check what personal information is held by us, at no cost,
- You have the right to have wrongly recorded data amended,
- You have the right to “be forgotten” i.e the removal of your data,
- You have the right to “Opt out”
- You have the right to object to the processing of your personal information,
- You have the right to request the restriction of the processing of your personal information,
- You have the right to request the transfer of your personal information,
- You have the right to withdraw your consent.
Concerns or complaints
If you are concerned about us any aspect of our conduct regarding your privacy, you can make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at email@example.com We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your response, or you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissioner’s Officer (the ‘ICO’). You can find further details on the ICO website at https://ico.org.uk/
You also have the right, at any time, to complain to the Information Commissioner’s Office. As an independent UK authority, the ICO upholds information rights in the public interest, promotes openness by public bodies and data privacy for individuals.
Users Aged 18 or Under
Protecting the safety of children when they use the internet is important to us.
The site is intended for use only by persons who are at least 18 years of age. By using this site, you confirm to us that you meet this requirement. If you are aged 18 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information.
Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies on this website: We use both session cookies and persistent cookies on this website.
We may use the information we obtain from your use of our cookies for the following purposes:
- to recognise your computer when you visit our website;
- to track you as you navigate our website, and to enable the use of the some of the features on our website;
- to improve the website’s usability;
- to analyse the use of our website;
- in the administration of this website;
- to personalise content on our website for you.
Third party cookies
Most browsers allow you to refuse to accept cookies. For example:
- in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
- in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.
Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use many of the features of this website.
You can also delete cookies already stored on your computer. The method of doing so will depend upon your web browser. Instructions are available at the following URLs.
Internet Explorer: http://support.microsoft.com