Hartmoor customer facing privacy policy

Hartmoor Financial – Fair Processing Notice

‘Hartmoor Financial’ is a trading name of Target Servicing Limited.  Target Servicing Limited is the “controller” of your personal data contained in the records we hold of your investment account. A controller is the person who determines the purpose and manner in which your personal data is processed. 

This privacy notice explains what information we hold and collect about you, how we’ll use that information, who we’ll share it with, the circumstances in which we’ll share it and what steps we’ll take to make sure it stays private and secure.

It continues to apply even if your loan ends. It should also be read alongside the terms and conditions of your investment agreement, as these are likely to include sections relating to the use and disclosure of information.

Who we are

‘Hartmoor Financial’ is a trading name of Target Servicing Limited with company number 05618062. Target Servicing Limited is authorised and regulated by the FCA with reference number 454569.

Our Customer Services team can be contacted on 0345 650 6225.  You can write to us at Target Servicing Limited, PO Box 900, Newport NP20 9NN.

The contact details for our data protection officer are as follows:

By post: For the attention of the Data Protection Officer, Target Servicing Limited, PO Box 900, Newport NP20 9NN

By email: DPO@targetgroup.com

What data do we collect about you?

We may collect the following personal data: your name, address, contact details, bank details, and investment account information.

If you are an Independent Financial Advisor, we may also collect your business contact details, private investor, corporate entity or other person or institution you represent for investment purposes and/or for whom you provide financial advisory services.

You may provide us with information which is classified as ‘special categories of personal data’ such as information regarding your health.  We will only record and use this information with your explicit consent.  You can withdraw your consent at any time by contacting us.

Who we obtain your data from

We have obtained your personal data from the Independent Financial Advisor who set up the account with us on your behalf.  We may also obtain data directly from you during the administration of your account.

How your personal data will be used by us

We will store, access and use your personal data:

  1. for the purpose of administering your investment product including responding to your enquiries or comments;
  2. to help investigate, prevent and detect fraud or financial crime;
  3. to let you know about other products and services that we believe you may be interested in. You have a right to opt out of receiving such communications at any time (see “Your rights” below);
  4. to retain a history of your account for future reference by you and/or us in case of any legal claim.

Legal grounds for our use of your personal data

Our use of your personal data (as described above) is necessary for:

  1. our performance of the investment agreement between us;
  2. compliance with our legal and regulatory obligations;
  3. the legitimate interest of:
  1. helping to prevent and detect fraud and financial crime;
  2. marketing and advertising our products and services to you via letter and unautomated telephone calls. You have a right to opt out of receiving such communications at any time; and
  3. retaining a historical record of your account in case of any future legal claim.

Where you have provided us with information regarding your health, our lawful basis for processing the information about your health is your consent.  You can withdraw your consent at any time by contacting us. 

Our use of your personal data is subject to a framework of safeguards that help make sure your rights are protected. This includes ensuring you have the ability to exercise your rights in relation to your personal data and complain if you are dissatisfied (please see “Your rights” below).

Retention and deletion

We will retain your personal data about your account for no longer than is necessary which will normally be the life of the account and for a period of typically 7 years after your account has been closed or settled.

We will normally retain personal data for a period after the investment has ended.  The criteria that determine this period are:

  1. our obligation to comply with regulatory or legal requirements,
  2. our legitimate interests in complying with good practice in the industry,
  3. our legitimate interests, for example to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc,
  4. our legitimate interests in dealing with any disputes or concerns that may arise in the future.

Generally, we will normally retain personal data for the life of the account and for a period of 7 years after the account has been closed.  If we do not need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.

We will generally delete accounts in batches periodically (for example, quarterly, six monthly, yearly) so, depending on when the batch is run, your personal data may be deleted earlier or later than set out above.

Marketing

We may use your information to provide you with information about our products and services, and also products and services from our partners and other relevant third parties that we believe you might be interested in. The lawful basis for this is our legitimate interest and, where you have previously consented, your consent.

We may need your consent to communicate by certain channels and we will always make sure we get this where we need to.

You have right to opt out of receiving such communications at any time (see ‘Your rights’ below).

Who we share your personal data with

We pass your personal data on to the following third parties that provide services to us in connection with your investment account: print houses, payment service providers, telephony service providers and storage companies. These third parties are obliged to keep your details secure and use them only to fulfil instructions provided by us.

For the purposes set out above it may sometimes be necessary to process your personal data outside the European Economic Area (being the EU, Iceland, Liechtenstein and Norway).  If this happens we will ensure the transfer is compliant with data protection legislation and appropriate safeguards are in place to protect your personal data.  Where a destination country is not deemed to already have adequate safeguards in place to protect personal data, our standard practice is to use approved ‘standard data protection clauses’ for such transfers.

As set out in Marketing above, we may also share your information with our partners and other relevant third parties.

Keeping your information safe

We use a range of measures to keep your information safe and secure.  We require our staff and any third parties who carry out any work for us to comply with/appropriate compliance standards including obligations to protect information and applying appropriate measures for the use and transfer of information.

What we expect from you

We rely on you to make sure that the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible.

If you provide information for another person in relation to your account, for example a joint account holder, a dependant or someone to act on your behalf, you’ll need to tell them how to find this notice and make sure they agree to us using their information as described in it.

Your rights

You have a number of rights in relation to the information that we hold about you including:

  • the right to access information we hold about you and to obtain information about how we process it.
  • the right to withdraw your consent to us processing your information.  However, may continue to process your information if we have another lawful reason for doing so.
  • the right to receive certain information you’ve provided to us in an electronic format and/or request that we send it to a third party.
  • the right to request that we rectify your information if it is inaccurate or incomplete.
  • the right to ask us to delete your information. We may continue to keep your information if we are entitled or required to.
  • the right to object to, and to request that we restrict, our processing of your information in some circumstances
  • the right not to receive marketing communications. 

If you wish to exercise any of the above rights please contact us at Target Servicing Limited, PO Box 900, Newport NP20 9NN; or email us at: servicing@targetgroup.com

Complaints

If you are unhappy about how we are handling your personal data contact us (see “Who we are” above for our contact details). You may also file a complaint our DPO (details set out above) or with the Information Commissioner’s Office, which regulates our processing of personal data. You can contact them by:

Phone: 0303 123 1113

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF

Via their website at www.ico.org.uk

Fraud prevention agencies

We may provide information about you to fraud prevention agencies.  Those agencies may make that information available to other organisations, including law enforcement agencies, and used by them and us to prevent crime, fraud and money laundering by, for example:

  1. checking details provided on applications for credit and credit related or other facilities;
  2. managing credit and credit related accounts or facilities;
  3. cross checking details provided on proposals and claims for all types of insurance;
  4. checking details on applications for jobs or when checked as part of employment;
  5. verifying your identity if you or your financial associate applies for other facilities including all types of insurance proposals and claims;
  6. tracing your whereabouts and recovery of debts that you owe; and/or
  7. conducting other checks to prevent or detect fraud.

We and other organisations may also access and use the information recorded by fraud prevention agencies from other countries.