Privacy Policy
Hedosophia Services Limited
Registered Office: 2 Soho Place, London W1D 3BG
Registered: England and Wales
Registration Number: 09369134
Hedosophia Services Limited (“we”, “us”, “our”) are committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you 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. By visiting www.hedosophia.com (our site) you are accepting and consenting to the practices described in this policy. You can withdraw such consent at any time.
For the purpose of the Data Protection Act 2018 (“the Act”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation” or “GDPR”), the data processer and controller is Hedosophia Services Limited of 152 Great Portland Street, London, W1W 6AJ. As used in this policy, the term “Regulations” shall include, together, the Act and the General Data Protection Regulation, each of them, as from time to time applicable, amended, restated or supplemented.
1. Information we may collect from you
We may collect and process the following data about you (including without limitation):
1.1 Information we may collect about you
With regard to each of your visits to our site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page and any phone number used to call our customer service number.
1.2 Information we may receive from other sources
We may also work closely with third parties (including, for example, business partners, subcontractors, analytics providers, search information providers) and may receive information about you from them.
2. Uses made and processing of the information
We may use information held about you (information we collect about you and information we receive from other sources) in the following ways:
2.1 Information we may collect about you
We may process information that we collect about you:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- As part of our efforts to keep our site safe and/or secure;
- To collect broad demographic information for aggregate use; and
- In co-operation with your internet provider, to identify you if we feel it is necessary to enforce compliance with our terms or use or to protect our service, site, users or others. The legal basis for this processing is our legitimate interests and business and, the proper administration of our website and business.
2.2 Information we may receive from other sources
We may combine information that we receive about you from other sources and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
3. Where we store your personal data
The data that we may collect from you may be stored physically or transferred to, and stored on a cloud-based service, that may be a destination outside the European Economic Area (“EEA”). By submitting your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and in compliance with the Regulations.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. We cannot prevent the use (or misuse) of such personal data by others.
4. Disclosure of your information
4.1 Group members
We may share your information, where applicable, with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 for the purposes set out in this policy.
4.2 Selected third parties
We may also share your information with selected third parties for the purposes set out in this policy. These selected third parties may include:
- Analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- Insurers and/or professional advisors for the purposes of maintaining appropriate insurance levels, managing risks, obtaining legal advice and managing disputes.
We may disclose your information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its members will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; and/or
- To protect the rights, property, or safety of Hedosophia Services Limited and our members or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Retention and deletion of personal data
We will retain and store personal data for as long as necessary for the purposes of compliance with our legal obligations under the Regulations, following which all your personal data stored and retained by us will be deleted from our files and records.
6. Your rights
Your rights under the Regulations are: You have the right to be informed of your rights and how your personal data will be stored, treated, deleted and controlled, as all is set out in this policy.
6.2 Access to information
You have the right to access your personal data, so that you are aware of and can verify the lawfulness of the processing. The Regulations give you the right to access information held about you. Your right of access can be exercised in accordance therewith. Any access request is free of charge. We reserve the right to charge a reasonable fee taking into account administrative costs and/or refuse to respond to excessive, repetitive, or manifestly unfounded requests. If denied, you have the right to complain to the supervisory authority (the Information Commissioner’s Office).
6.3 Rectification
You have the right to rectify incorrect data and request incomplete information be completed.
6.4 Erasure
You can request data erasure in these circumstances:
- Where the personal data is no longer necessary for its original purpose;
- When you withdraw consent;
- When you object to processing and there is no overriding legitimate interest;
- When your personal data has been unlawfully processed;
- To comply with a legal obligation.
6.5 Restriction
Processing may be restricted if:
- There is a dispute over accuracy;
- You object to processing while a legitimate interest assessment is conducted;
- Processing is unlawful but you oppose erasure;
- We no longer need your data but you require it to establish, exercise or defend legal claims.
6.6 Data Access Portability
You may request access to your personal and transaction data in a portable format.
6.7 Objection
You may object to:
- Processing based on legitimate interests or public tasks;
- Direct marketing;
- Processing for scientific/historical research and statistics.
7. Data accuracy
Whilst we accept responsibility for maintaining personal information, we are not responsible for its accuracy over time. If you identify any inaccuracy, you may correct it as per this policy.
8. Changes to our privacy policy
Any changes will be posted on this page and, where appropriate, notified by email. Check back frequently for updates.
9. Contact
Questions, comments and requests regarding this privacy policy are welcomed. You can contact us:
- By email: info@hedosophia.com
- By post: At our registered office address set out above
- By telephone: Using the contact number published on our website from time to time.
10. Filing of complaints
If you have any complaints or concerns, you can address these with the supervisory authority, the Information Commissioner’s Office.
Terms of Website Use
Please read these terms and conditions carefully before using this site
This page (together with the documents referred to on it) tells you the terms of use on which you may make use of our website www.hedosophia.com (our site) as a guest.
Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them.
If you do not agree to these terms of use, please refrain from using our site.
Information about us
www.hedosophia.com is a site operated by Hedosophia Services Limited (“we”, “us”, “our”).
We are a company registered in England and Wales under company registration number 098975224 and have our registered office at 2 Soho Place, London, England, W1D 3BG.
We are authorised and regulated by the Financial Conduct Authority.
Where appropriate, references to “we”, “us” and “our” in these terms of use shall include Hedosophia Services Limited, other members of our group of companies and third parties connected to us, including without limitation directors, officers, employees, partners, shareholders and agents of the foregoing.
Information about you and your visits to our site
We process information about you in accordance with our Privacy Policy as found on our website. By using our site, you consent to such processing.
Linking to our site
You are not permitted to establish a link to our site in any way.
Prohibited uses
You may use our site only for lawful purposes. You also agree:
- not to reproduce, duplicate, copy or re-sell any part of our site in contravention of these terms.
- not to attack our site via a denial-of-service attack or a distributed denial-of service attack.
- not to access without authority, interfere with, damage or disrupt:
- any part of our site.
- any equipment, server or network on which our site is stored or any server, computer or database connected to our site.
- any software used in the provision of our site.
- any equipment or network or software owned or used by any third party.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990.
We may report any such breach to the relevant law enforcement authorities and will co-operate with those authorities by disclosing your identity to them.
In the event of such a breach, your right to use our site will cease immediately.
Intellectual property rights
We are the owner or the licensee of all intellectual property rights in our site, and in any material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way.
Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.
If you print, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
Trade marks
Any trade marks shown on the site are the trade marks of ours unless expressly stated otherwise. No permission is given by us in respect of the use of any such trade marks, service marks, company names or logos or copyrights and such use may constitute an infringement of the holder’s rights.
Reliance on information posted
Any content on our site is provided on an “as is” basis, for general information only. It has not been audited or verified by any third party and is subject to change at any time, without notice. It is not intended to amount to advice on which you should rely.
Specifically, our site and any information contained herein is not, and must not be treated as, investment advice, investment recommendations, or investment research and no person must take (or refrain from taking) any investment decision on the basis of the information set out on our site.
Before making any investment decision, you should seek independent investment, legal, tax, accounting or other professional advice as appropriate.
Although we make reasonable efforts to update any information provided on our site, we make no representations, warranties or guarantees, whether express or implied, as to the condition, quality, accuracy, suitability, fitness for purpose, completeness, or freedom from viruses or bugs (you should use your own virus protection software) of the information contained on our site or that such content will be accurate, complete, up to date, uninterrupted or error-free.
We therefore disclaim all liability and responsibility arising from any use of or reliance placed on all content on our site by any visitor to our site, or by anyone who may be informed of any of its contents.
No offer
Any content on our site is not intended to and does not constitute an offer, invitation, solicitation or recommendation to invest in any fund, security or other product or service. Any information contained on our site should not be relied upon for any purpose.
Any offer or invitation, if made, would be made only by way of a confidential private placement memorandum (or other formal or informal offering document) and only in jurisdictions in which such an offer or invitation would be lawful.
The information on our site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution would be contrary to local law or regulation.
Our site changes regularly
We aim to update our site regularly and may change the content at any time. If the need arises, we may suspend access to our site or close it indefinitely.
Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.
We do not guarantee that our site, or any content on it, will be free from errors or omissions.
Our liability
Whether you are a consumer or business user, to the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:
- all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
- any liability for any direct, indirect or consequential loss, and any other loss, fines or damage whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, and any materials posted on it.
We will not be liable for any loss, fines or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.
If you are a consumer user, please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
Suspension and termination
We will determine, in our sole discretion, whether there has been a breach of these terms through your use of our site. When a breach of these terms has occurred, we may take such action as we deem appropriate in our sole discretion.
We exclude liability for actions taken in response to breaches of these terms.
Indemnity
You hereby indemnify and hold us, other members of our group of companies and third parties connected to us and our, their directors, officers, employees, partners and agents harmless from and against all liabilities, damages, losses, fines, costs and other expenses (including, without limitation, legal fees and any amounts paid by us to a third party in settlement of a claim or dispute) incurred or suffered by us arising out of any breach by you of any provision of these terms or other liabilities arising out of your use of our site.
Severability
If any part of these terms of use is found by any court, tribunal, administrative body or authority of competent jurisdiction to be illegal, invalid or unenforceable, then that part shall, to the extent required, be severed from these terms of use and shall be ineffective without modifying any other part of these terms of use. This shall not affect any other provision of these terms of use, which shall remain in full force and effect.
Amendments
We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we may make, as they are legally binding on you.
Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.
Jurisdiction and applicable law
If you are an individual, please note that these terms of use, its subject matter and its formation, are governed by English law.
You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.
If you are a business, these terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.
We both agree that the English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site, although we retain the right to bring proceedings against you for breach of these terms in your country of residence or any other country.
Your concerns
If you have any concerns about material that appears on our site, please contact info@hedosophia.com.
Thank you for visiting our site.
