Privacy Policy

PRIVACY NOTICE
We are committed to protecting and respecting your privacy. This notice sets out the basis on
which any personal data we collect will be processed by us. Please read this Privacy Notice
carefully to understand our views and practices and your rights regarding your personal data. By
visiting any of our websites (our sites) you are accepting and consenting to the practices
described in this notice.

For the purpose of data protection legislation, the data controller is HF Internet Services LLP.
What information do we collect from you?
We will collect and process the following data about you:
• Information you give us. This is information about you that you give us by filling in
forms on our site or by corresponding with us by phone, email or otherwise. The information
you give us may include your name, address, email address and phone number and financial
information. Please let us know if any of this information changes so we can keep our
records up to date.
• Information we collect from your use of our site. With regard to each of your visits to
our site we will automatically collect the following information:
o technical information, such as the Internet protocol (IP) address used to connect
your device to the Internet, whereabouts you connected to our service, your internet
service provider (ISP), and what type of device you are using to access our service;
• Information we collect throughout our relationship. This is information relating to
products that you download.
• Information we collect when you call us. If you call us we will automatically collect the
following information:
o the phone number used to call us
o a recording of all inbound and outbound calls
• Information we receive from other sources. We are working closely with other
organisations, including:
Linkedin, Facebook, Twitter, Instagram. When you click on an advert about us or
download from a social media site we may receive information about your
promotional offers and generating new business, building and maintaining loyalty or
market share.
• Information we collect from your use of the site. We will use this information for the
following purposes:
o to administer our site and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes;
o to improve our site to ensure that content is presented in the most effective
manner for you and for your device;
o as part of our efforts to keep our site safe and secure;
o to measure or understand the effectiveness of advertising we serve to you and
others, and to deliver relevant advertising to you;
• Information we collect throughout our relationship. We will use this information to
help us provide you with our services.
How long do we keep hold of your information?
• We will keep information about you for a maximum of 6 years after the end of our
relationship with you unless obligations to our regulators require otherwise or we are
required to remove such data from our records.
Who might we share your information with?
You agree that for the purposes set out in the ‘Why do we collect this information?’ section
above, we have the right to share your personal information with:
• Selected associated third parties, some of whom we appoint to provide services,
including:
o business partners, subsidiaries, affiliates, suppliers and sub-contractors for the
performance of any contract we enter into with you;
o analytics and search engine providers that assist us in the improvement and
optimisation of our site;
o Customer survey providers in order to receive feedback and improve our services.
• Any member of our group, which means our subsidiaries.
Additionally, we will disclose your personal information to the relevant third party:
• In the event that we sell or buy any business or assets, in which case we will disclose your
personal data to the prospective seller or buyer of such business or assets.
• If we are acquired by a third party, in which case personal data held by it about its
customers 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; or to
protect the rights, property, or safety of our customers, our regulator, or others.
How is your data stored and kept secure?
We take your safety and security very seriously and we are committed to protecting your personal
and financial information. All information kept by us is stored on our secure servers. Where we
have given you (or where you have chosen) a password that enables you to access certain parts of
our service, you are responsible for keeping this password confidential. We ask you not to share a
password with anyone.

We transfer personal data outside the EEA to the USA, but only where those organisations have
signed up to Privacy Shield or have other adequate safeguards in place such as an adequacy
decision by the European Commission, standard data protection clauses or binding corporate
rules.
Once we have received your information, we will use strict procedures and security features to try
to prevent unauthorised access.
What are your rights?
Where processing of your personal data is based on consent, you can withdraw that consent at
any time.
You have the following rights. You can exercise these rights at any time by contacting us at the
address above or through the “Contact Us” section of our Sites. You have the right:
• to ask us not to process your personal data for marketing purposes. We will inform you
(before collecting your data) if we intend to use your data for such purposes or if we intend
to disclose your information to any third party for such purposes;
• To ask us not to process your personal data where it is processed on the basis of
legitimate interests provided that there are no compelling reasons for that processing;
• To ask us not to process your personal data for scientific or historical research purposes,
where relevant, unless the processing is necessary in the public interest.
• to request from us access to personal information held about you;
• to ask for the information we hold about you to be rectified if it is inaccurate or
incomplete;
• to ask for data to be erased provided that the personal data is no longer necessary for the
purposes for which it was collected, you withdraw consent (if the legal basis for processing is
consent), you exercise your right to object, set out below, and there are no overriding
legitimate ground for processing, the data is unlawfully processed, the data needs to be
erased to comply with a legal obligation or the data is children’s data and was collected in
relation to an offer of information society services;
• to ask for the processing of that information to be restricted if the accuracy of that data is
contested, the processing is unlawful, the personal data is no longer necessary for the
purposes for which it was collected or you exercise your right to object (pending verification
of whether there are legitimate grounds for processing);
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of
data which is inaccurate, please let us know by contacting us using the contact details above. In
the event that you are not satisfied with our processing of your personal data, you have the right
to lodge a complaint with the relevant supervisory authority, which is the Information
Commissioner’s Office (ICO) in the UK, at any time.
Changes to our privacy Notice
This Notice may be updated from time to time. Please check back frequently to see any updates
or changes to our privacy notice.

IMPORTANT
Jonathan Horrocks and Healthy Wealthy Retirement are trading names of HF Internet Services LLP and the website and intellectual property belongs to that LLP. Telephone +44 7973 216 295.

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