Privacy Policy
Hoxton Wealth and its affiliates are committed to providing professional services, maintaining the trust of our clients, and respecting your private information. We take great care in handling and processing your information securely and professionally. This privacy policy outlines when and why we collect your personal information, how we use it, the steps we have taken to secure it, under which limited conditions we disclose your information to others, and your rights under the law.
Please click to view the previous version of our Privacy Policy.
This Data Privacy Notice explains how Hoxton Wealth (DIFC) Limited (“we”, “us”, or “our”), incorporated in the Dubai International Financial Centre (DIFC), collects, processes, and protects your personal data in compliance with the DIFC Data Protection Law.
As a data controller, we are committed to safeguarding your privacy and information rights. This notice outlines the types of personal information we collect, the purposes for which we use it, and your rights regarding that information.
Personal Data refers to any information that relates to an identified or identifiable natural person. This includes, but is not limited to, the following types of information:
- Name
- Contact information (address, email address, phone number)
- Date of birth
- Identification numbers (e.g., passport, Emirates ID)
- Financial details (e.g., bank account information, source of wealth)
- Health information related to financial planning or long-term insurance contracts
We may collect the following personal information:
Identity Information: Such as your name, address, email, date of birth, and identification documents.
Financial Information: Including bank account details, source of funds, source of wealth, and economic profile.
Health Information: Only when relevant for financial planning or when dealing with long-term insurance contracts. This may include medical history, health status, and any other related data.
Usage Information: Data regarding your interactions with our website, such as IP address, browser type, and cookies.
Service Information: Preferences, investment profiles, and details about beneficiaries and dependents.
Customer due diligence information: Information related to electronic searches concerning any political exposure you may have, criminal convictions, or negative publicity.
Communications: Any information you provide when contacting us via email, phone, or other means. This may include video recordings of clients' meetings where the recording is made with your prior consent.
We collect your information through various means, including:
- When you engage with our services or otherwise provide personal information
- Through information requests we make to you to satisfy regulatory or legal obligations, such as anti-money laundering checks.
- Information provided when you register to attend or have attended one of our seminars or webinars.
- You have given us express consent to record certain information, as is relevant to your required services.
- You use our website and enter personal information, or via the Hoxton Wealth online application.
- You have completed an optional online review or contact form
- Information available through public records or third-party services.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Our affiliates and partners
We may share your personal information with affiliates (such as our parent, subsidiary or sister entities) and partners or enable our affiliates and partners to collect information directly via our Service. For example, we may share your personal information with capital management firms with which you hold certain assets or other third-party financial or asset management institutions with which we partner. Please see our list of third-party Privacy Policies here for more information.
Service providers
Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and analytics).
Advertising partners
Third-party advertising companies for the interest-based advertising purposes described above.
Partners
We may share your personal information with partners or enable partners to collect information directly via our Service. For example, we may be integrated with a capital management firm with which you hold assets, in which case we may exchange your personal information with such firm.
Data aggregators
We may share your personal information with our third-party financial data aggregators. Please see our list of third-party companies that we use and their Privacy Notices.
Third-party integrations
Third parties, such as banks and other financial institutions that we integrate with and that you can log into through, or otherwise link to, your Service account. This data may include your username, financial and investment data, and other information associated with your account on that third-party service made available to us. Please see our list of third-party Privacy Policies here for more information.
Business and marketing partners
Third parties with whom we co-sponsor events or promotions, jointly offer products or services, or whose products or services may interest you.
Professional advisers
Professional advisers, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others
Law enforcement, government authorities, and private parties, as we believe in good faith, are necessary or appropriate for the Compliance and protection purposes described above.
Business transferees
We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Hoxton Wealth, financing of Hoxton Wealth, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Hoxton Wealth as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
We process your personal information for the following purposes:
- To provide information about our products, services, and events that may be relevant to you.
- To advise you on financial products and investments that meet your specific needs
- To facilitate transactions and manage our ongoing relationship with you.
- To respond to your inquiries, requests, and feedback.
- To liaise with third-party investment providers or insurance companies on your behalf.
- To comply with legal obligations, including financial services and anti-money laundering regulations.
- To assess health information for the purpose of financial planning and managing long-term insurance contracts.
We process your personal data based on the following legal grounds as outlined in the DIFC Data Protection Law:
Consent: Where you have given us explicit consent to process your personal data for specific purposes.
Contractual Necessity: When processing is necessary for the performance of a contract with you.
Legitimate Interests: To pursue our legitimate interests, provided that your interests and fundamental rights do not override those interests.
Legal and Regulatory Compliance: To comply with our legal and regulatory compliance obligations.
We may share your personal information with third parties in the following circumstances:
Service Providers: Third-party vendors who assist with our operations (e.g., IT services, data processing).
Investment Providers: Investment Platform companies, stockbrokers, custodians, or administrators involved in holding your financial assets or processing instructions
Insurance Companies: Insurers or insurance brokerages, so they can assess the risk of providing insurance coverage for you or to onboard you and manage your insurance contrac,t should you become their client.
Regulatory Authorities: Competent authorities as required by law or regulation.
Group Companies: Any member of our corporate group for operational purposes.
Your personal data may be transferred, stored, and processed outside the DIFC, including in jurisdictions that may not provide the same level of data protection. We will ensure that appropriate safeguards are in place to protect your data in compliance with the DIFC Data Protection Law.
We will retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including:
- Responding to inquiries or complaints.
- Complying with legal obligations or regulatory obligations.
- Improving our services.
When determining retention periods, we consider the nature of the data, the purposes of processing, and applicable legal requirements.
Under the DIFC Data Protection Law, you have the following rights regarding your personal data:
Right to Access: Request a copy of your personal information.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure: Request deletion of your personal data when it is no longer necessary.
Right to Restriction: Request to limit processing of your personal data
Right to Object: Object to processing based on legitimate interests and for marketing activities
Right to data portability: Request your data in a structured, commonly used format
Withdraw your consent – withdraw your consent at any time for the use of your personal information for a particular purpose.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is repetitive or excessive.
Hoxton Wealth (DIFC) Limited has a dedicated Data Protection Officer who can be contacted using the details below:
Data Protection Officer: Paul Tate
Email: privacy@hoxtonwealth.ae
Telephone: +971 (0)4-575089
Address: Hoxton Wealth (DIFC) Limited, Office 515, Level 5, Liberty House, Dubai International Financial Centre, Dubai, United Arab Emirates.
Please do contact us in the first instance using the details above.
Hoxton Wealth (DIFC) Limited has a dedicated Complaint Handler who can be contacted using the details below:
Complaint Handler: Paul Tate
Email: complaints@hoxtonwealth.ae
Telephone: +971 (0)4-575089
Address: Hoxton Wealth (DIFC) Limited, Office 515, Level 5, Liberty House, Dubai International Financial Centre, Dubai, United Arab Emirates.
If we cannot resolve the matter, you always have the right to complain directly to the Dubai International Financial Centre data protection Commissioner. Details as follows:
Address: DIFC Commissioner of Data Protection
Level 14, The Gate
Dubai International Financial Centre
PO Box 74777
Dubai
United Arab EmiratesTelephone: +971 (0)4 362 2222
