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 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 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 contract 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