Hamilton Court Foreign Exchange Limited (We/Us) is a company registered in England with Company registration number 11366742. We are registered with ICO in the UK with registration number ZA469532 and we are a data controller.
Our registered DPO (Data Protection Officer) is Briony Griffin. If you have read the following and have any questions, you can contact our firms Compliance team at Compliance@Hamiltoncourtfx.com.
We will collect and process data entered into this site, including in our application form, in order to meet out Legal Obligations and for the Performance of a contract with us.
In all cases where Personally Identifiable Data is collected about you, this is carried out with your consent, and you will be required to provide consent for us to collect and process your data, and for us to enter int a contract with you.
For regulatory reasons, HCFX is required to collect Know Your Customer information which will include your full name, address and date of birth.
In order to fulfil our contract with you, we will require that data be passed to 3rd parties who process data on behalf of HCFX. This may include us passing your name or the name of your company to our banking partners in order to comply with Wire Transfer Regulations, passing details to credit agencies in order comply with AML legislation and passing details of certain trades to regulatory bodies, such as for transaction reporting reasons.
HCFX may also collect other data from public sources (such as company records) or may purchase data (such as credit data) in order to help facilitate our contract with you, or to meet our compliance obligations. A full list of where your data may be passed and the purposes of us holding and using this data is available on request.
HCFX will not sell your data to 3rd parties for the purposes of marketing, or share your data with parties for any reason other than for the performance of our contract, or compliance with legislative requirements.
HCFX will not intentionally collect any information which is considered sensitive, but may discover such information during general conversations with you, for example we may be able to discern your political views based on discussions about current affairs affecting the FX markets.
HCFX will not record this data in its systems and will take all possible steps to protect this sensitive data including encrypting call recordings.
By agreeing to the terms of the application form on this website you consent to your personal data being held for the provision of payment services and acknowledge that HCFX is required by law to retain all data for a period of 5 years from the point at which you cease to trade with Hamilton Court (as required by Anti Money Laundering Legislation).
This obligation to hold data overrides your rights to having your data deleted and your ability to withdraw consent to hold data.
You may request at any time that we provide a copy of all data held on you, or request that we correct any data we hold on you, should you believe that it is incorrect.
In relation to our market commentary, if you subscribe to receive our market commentary, you agree that Hamilton Court may processes your email and contact details for the purposes of sending daily market commentary, and consent to Hamilton Court retaining your name and email address in order to send these emails.
This data will not be sold to any 3rd parties and will be used solely for direct communication with you by Hamilton Court.
Once you have subscribed, HCFX will assume that it has a Legitimate Interest in holding limited data on you, which you may revoke at any time by clicking Unsubscribe.
If you have any question or queries, you can contact us at firstname.lastname@example.org. If you are unhappy with the way in which your data is held, you can contact the Information Commissioners office, quoting ZA469532
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