GHF Advisory Privacy Policy

Privacy Notice

GHF Advisory Services Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
2. Your rights
3. The data we collect about you
4. How is your personal data collected
5. How we use your personal data
6. Disclosures of your personal data
7. International transfers
8. Data security
9. Data retention
10. Security
11. Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how GHF Advisory Services Ltd collects and processes your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

GHF Advisory Services Ltd is the controller and responsible for your personal data (collectively referred to as “GHF Advisory Services Ltd”, “GHF Advisory”, “we”, “us” or “our” in this privacy notice).

Contact details

GHF Advisory | [email protected] | +44 (0) 7870 582286

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1st January 2024 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Your rights

You have certain rights in relation to your personal data. Your rights in connection with personal information.
Under certain circumstances, by law you have the right to:

Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.
If you want to exercise any of these rights then please contact us. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: ico.org.uk.

3. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We capture your location based on your ID, in order to show you the most relevant data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, employer, job title.
Contact Data includes billing address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of services you have received from us.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email or if you subscribe to our company updates or request marketing to be sent to you.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Technical Data from analytics providers such as Google based outside the EU; Identity and Contact Data from data brokers or aggregators Data.com based outside the EU and from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Your location data is stored in a cookie, which is stored for a day.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. Such legitimate interests include; ensuring the quality of services we provide to you; collecting information for marketing purposes; or communicating with you.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing [email protected].

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

You will receive marketing communications from us if you have requested information from us and, in each case, you have opted in to receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages by emailing [email protected] at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a client project.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual.
The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
If you want to disable cookies you need to change your website browser settings to reject cookies. How to do this will depend on the browser you use and we provide further detail below on how to disable cookies for the most popular browsers:

For Microsoft Internet Explorer:

Choose the menu “tools” then “Internet Options”
Click on the “privacy” tab
Select the setting the appropriate setting

For Mozilla firefox:

Choose the menu “tools” then “Options”
Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

Choose the menu Files”> “Preferences”
Privacy

This depends on which cookies you disable, but in general the site may not operate properly if cookies are switched off. If you only disable 3rd party cookies you will not be prevented from properly using this site. If you disable all cookies you will be unable to use dynamic areas of this site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We share your personal data within the GHF Advisory Services Ltd Group. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

10. Security

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

11. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by [email protected].

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties
Other companies in the GHF Advisory Group acting as joint controllers (based in the United Kingdom).

External Third Parties
These include professional advisers, HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Terms and Conditions

This web site (“Site”) is maintained by GHF Advisory Services Ltd, (“GHF Advisory Services Ltd”, “GHF Advisory” or “we”) based in London. GHF Advisory Services Ltd may be contacted by sending an e-mail to [email protected]. GHF Advisory is authorised and regulated by the Financial Conduct Authority.

By accessing the Site you accept without limitation or qualification all of the terms and conditions in this Agreement and any subsequent amendments or variations as GHF Advisory, in its sole discretion, may make from time to time. “Agreement” means this document and any schedule, appendix or other document referred to in this document.

Content

The material on the Site is for general information purposes only and does not constitute financial or any other type of professional advice. GHF Advisory does not accept and, to the extent permitted by law, excludes liability to any person for any loss which may arise from relying upon or otherwise using the information contained in the Site. The information on the Site is provided “as is” without warranty of any kind and we shall not be liable for any loss or damage caused by your reliance on such information. No offer or solicitation to conduct investment business is made on the Site. The Site is directed at UK residents. Non-UK residents should inform themselves of their local regulations.

GHF Advisory maintains the right to change or delete any information on the Site without prior notice. We cannot guarantee that material on the Site will be continuously available or error-free, free from infection, viruses, worms, Trojan horses and/or other codes that have contaminating or destructive properties. It is your responsibility to take protective steps such as virus checking. While we attempt to ensure the accuracy and timeliness of all material posted on the Site, we take no responsibility for errors or omissions which are the result of technical causes, or otherwise. Any third-party links to other websites or web pages provided on the Site are given solely as a convenience to any users of the Site.

GHF Advisory does not control and is not responsible for any of these sites or their content and consequently shall not be liable for any damage or loss caused or alleged to be caused or in connection with use of or reliance of any third party website. If you decide to access linked third party web sites you do so at your own risk.

Contact

By sending an email to GHF Advisory or communicating with us you warrant that all the information submitted to us is true and accurate in all respects and you have the authority and capacity to complete the form, send the email or communicate with us. You agree to notify us immediately in writing of any changes in the information provided to us. You are solely responsible for any information provided to us.

It is possible that if provided with an email address that we may email you and contact you via an email exchange/network owned and/or operated by your employer. By providing us with such an email address you warrant that you are entitled to receive email correspondence from GHF Advisory at that address. You agree that we may cease sending emails to an address provided to us without notification to you, even if you have asked to receive them, if we are requested to do so by your employer.

Any legal issues which arise from or which are related to the use of the Site or any of the services described and provided on the Site shall be construed in accordance with English Law. You hereby agree to submit to the exclusive jurisdiction of the English Courts.