PRIVACY POLICY

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Email Marketing

 

This privacy notice sets out how Market Hedge Limited, registered at North Lodge, Armitage Lane, Hawkesyard, Rugeley, Staffordshire, England, WS15 1PS, also referred to in this privacy notice as “we”, “our” or “us”, collects and uses your personal information. We are committed to being transparent and protecting your data; therefore, this notice outlines how we store and protect your data, who we share it with, and how long we retain it. This notice also outlines your rights and the actions you can take if you have concerns about how Market Hedge is handling your personal data. If we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy notice.
 

Market Hedge is the data controller and is responsible for the processing of client data. Our Data Protection Officer, who ensures Market Hedge and its employees comply with GDPR and serves as the first point of contact for individuals whose data is processed, can be contacted at dpo@market-hedge.co.uk.

 

References in this notice to “your information” refer to personal data that you provide or that is provided to us.

 

How we collect your personal data:
 

• Directly from you

• From third parties (for example, legal representatives, financial intermediaries, or counterparties to transactions)

 

What type of personal data may be collected by Market Hedge?
 

• Full name (may include marital status)

• Photographic identification

• Personal business email address

• Telephone number

• Nationality

• Date of birth

• Passport number

• Proof of address

• Bank account details such as sort code and account number

• Tax or National Insurance Number

• Name(s) of the executor

• Name(s) of the beneficiary

• Employment contract (if we are acting as Facility Agent)

 

How we use your personal data and our lawful basis for processing it:
 

• Personal business email address: Used to contact you in relation to a transaction/agreement. The lawful basis for processing this data is the pursuit of our legitimate interests.

• Photographic Identification (passport, national ID, driving licence): Used to verify identity as part of our Know Your Customer (KYC) procedures, fulfilling our obligations under Anti-Money Laundering & Counter Terrorist Financing regulations.

• Proof of address: Required to verify identity under KYC and Anti-Money Laundering regulations.

• Name, email address and telephone number provided via our website: Used for contacting you to offer our services and for operational and business purposes. Our lawful basis for processing this information is the pursuit of our legitimate interests.

• Bank account details: Required for making interest payments or distributing funds (if applicable). The basis for processing is contractual necessity and legitimate interest.

• Tax or National Insurance Number: Used for identity verification under KYC regulations and compliance with legal requirements.

• Original sealed Grant of Probate (including executor and/or beneficiary names): Required for the maintenance of registers and processing payments in certain financial transactions. The basis for processing is the pursuit of our legitimate interests.

• Employment Contract: If Market Hedge is acting as Facility Agent, we may receive employment contracts to verify employment status. The lawful basis for this is a legal obligation.

 

Who we share your personal data with
 

If the personal data you provide is for KYC purposes, it will be securely transferred to our compliance team for processing.

Your name and personal email address will be shared with our third-party marketing platform MailChimp to send marketing communications. The same data will also be stored within our Customer Relationship Management system (CRM).

 

We may also disclose your personal data where necessary for:
 

• Compliance with legal obligations

• Protecting the safety of our employees, the public, or Market Hedge property

• Complying with judicial proceedings, court orders, or legal processes

• The prevention or detection of crime (including fraud)

 

Storage, Security and Transfers
 

Market Hedge takes data security seriously. We have technical and organisational measures in place to protect your personal data against unauthorised access, loss, destruction, or misuse. Access to personal data is restricted to individuals who require it for processing purposes. We have also established backup and recovery procedures to ensure data integrity.
 

Once your data is processed, it is securely stored within a private Microsoft Office 365 portal with restricted access.

Your name and personal business email address will be stored in our CRM system, which is SOC 2 compliant and applies EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework security standards.
 

MailChimp’s servers are located in the United States, meaning information may be transferred, stored, or processed outside the UK and European Economic Area (EEA). However, MailChimp complies with EU-U.S. Privacy Shield Framework standards.
 

Market Hedge may transfer your personal data outside the EEA or receive data from outside the EEA. Where such transfers occur, we implement suitable safeguards to ensure the security of your personal data to the same standard as within the UK.

 

Email Marketing and Legal Basis for Processing
 

We send marketing emails based on:
 

• Our legitimate interests in promoting our business

• Your explicit consent

 

By ‘legitimate interests’, we mean that we have a business reason to use this data in a way that does not unfairly conflict with your interests.

 

If you have provided us with your business card, we may add you to our marketing list to send relevant updates. You can unsubscribe at any time.

 

If you have given consent via our website, we may use your email to send marketing materials, updates, and event invitations. You can unsubscribe at any time via the link at the bottom of our emails.

 

How long does Market Hedge keep your data?
 

We retain personal data in line with legal and regulatory requirements. Our Anti-Money Laundering (AML) Policy requires us to store identification records for five years after an account is closed or a transaction matures. During this time, your personal data will be securely archived in Microsoft Office 365 SharePoint.

 

After five years, we will securely delete your data and ensure it cannot be recovered. However, if we maintain an ongoing business relationship with you (directly or indirectly), we may continue to store and update your data where necessary.

 

Use of Cookies
 

Cookies are small text files placed on your device to track usage and compile analytics.

For more information, visit www.aboutcookies.org or www.allaboutcookies.org.

You can disable cookies via browser settings, though this may affect website functionality.

 

Links to Other Websites
 

Our website may contain links to third-party websites. This privacy notice applies only to our website, so we encourage you to review third-party privacy policies when visiting external sites.

 

Your Rights
 

Under data protection laws, you have the following rights:
 

• Right to be informed about how your data is used

• Right to access your data (subject access request)

• Right to rectify inaccurate or incomplete data

• Right to erase your personal data (the “right to be forgotten”)

• Right to restrict processing of your data

• Right to data portability (transfer your data to another provider)

• Right to object to processing

• Rights in relation to automated decision-making

 

If processing is based on your consent, you have the right to withdraw consent at any time.

 

If you have concerns about how we process your data, you can contact our Data Protection Officer or escalate the matter to the UK

Information Commissioner’s Office (ICO) at www.ico.org.uk or 0303 123 1113.

 

Market Hedge may update this Privacy Notice periodically. Please review it regularly for changes.