1. Introduction

HBI Capital Ltd (“HBI”, “we”, “us”, “our”) is committed to protecting the privacy and security of personal data.

This Privacy Policy explains how we collect, use, store and protect personal data in accordance with:

• The UK General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018

HBI Capital Ltd is registered with the Information Commissioner’s Office (ICO) under registration number: 00011795386.

2. Who We Are

HBI Capital Ltd is a company registered in England and Wales.
Company number: 15597712
Registered office: The Oaks, Kem Mill Lane, Whittle-le-Woods, Chorley, PR6 7DZ

For the purposes of data protection legislation, HBI Capital Ltd acts as a data controller.

If you have any questions regarding this policy or your personal data, please contact:

Email: info@hbicapital.co.uk

3. The Information We Collect

We collect personal data directly from you, or via authorised intermediaries such as brokers, introducers or professional advisers.

The categories of data we may process include:

A. Website Enquiries

• Name
• Email address
• Telephone number
• IP address
• Any information submitted via website forms

B. Investors and Funding Partners (where applicable)

Where we engage with investors or funding partners, we may process personal data, including:

• Identification documents (passport, driving licence)
• Proof of address
• Date of birth
• Financial information
• Bank account details
• Source of wealth and source of funds documentation
• Communications and correspondence

Such data is processed for contractual, regulatory and anti-money laundering purposes.

C. Borrowers and Introducers

• Personal and company contact details
• Corporate structure information
• Financial statements
• Property details
• Credit and background information
• Identification and AML documentation

We do not collect more personal data than is reasonably necessary for legitimate business purposes.

4. Lawful Basis for Processing

We process personal data under one or more of the following lawful bases:

• Contractual necessity – to assess, arrange and administer loans or investments
• Legal obligation – including compliance with anti-money laundering (AML) and financial crime regulations
• Legitimate interests – operating, improving and protecting our business
• Consent – where required (for example, certain marketing communications)

5. How We Use Personal Data

We use personal data to:

• Respond to enquiries
• Assess and process loan applications
• Conduct identity verification and AML checks
• Administer investor and funding relationships
• Manage loan agreements and ongoing communications
• Comply with legal and regulatory obligations
• Prevent fraud and financial crime
• Improve our website and services

We do not sell personal data to third parties.

6. Disclosure of Personal Data

We may share personal data with:

• Professional advisers (including legal, compliance and accounting advisers)
• AML and identity verification providers
• Credit reference agencies
• Banking partners
• Regulators, law enforcement or government authorities (where required by law)
• IT and website hosting providers

All third parties are required to respect the security of personal data and to treat it in accordance with applicable law.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected.

Where subject to regulatory obligations, including anti-money laundering regulations, records may be retained for a minimum of five (5) years following the end of a business relationship.

Data may be retained for longer where required for legal proceedings, dispute resolution or regulatory investigation.

8. Data Security

We implement appropriate technical and organisational measures designed to protect personal data from:

• Unauthorised access
• Accidental loss
• Alteration
• Disclosure

Access to personal data is restricted to individuals who have a legitimate business need to access it.

While we take reasonable steps to protect personal data, no method of electronic transmission or storage can be guaranteed to be completely secure.

9. International Transfers

Personal data is processed primarily within the United Kingdom.

Where personal data is transferred outside the UK, appropriate safeguards will be implemented in accordance with UK GDPR requirements.

10. Your Rights

Under data protection law, you have the right to:

• Request access to your personal data
• Request correction of inaccurate or incomplete data
• Request erasure (in certain circumstances)
• Request restriction of processing
• Object to processing
• Request data portability

To exercise any of these rights, please contact us at:

Email: info@hbicapital.co.uk

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at:

www.ico.org.uk

11. Cookies

Our website uses cookies. Further information is available in our separate Cookie Policy.

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12. Changes to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be available on our website.