Privacy Policy

1. Introduction

We, William John (HV plc, also referred to as William John), take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).

This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the us using the contact information in section 15 of this privacy notice.

Contents
2. Why we Collect your personal information…………………………………………………………..2
3. Lawful Basis Of Processing Information……………………………………………………………….2
4. What Information we collect and where from………………………………………………………2
     4.1 Special Category Data………………………………………………………………………………………3
     4.2 Third Party Collection of Personal Data………………………………………………………….3
5. How Long we Keep Information For………………………………………………………………………3
6. Security of personal information…………………………………………………………………………….3
7. Children’s information……………………………………………………………………………………………..3
8. Your individual rights……………………………………………………………………………………………….4
9. Consent……………………………………………………………………………………………………………………..5
10. Failure To Provide Personal Information……………………………………………………………..5
11. Cookies……………………………………………………………………………………………………………………5
12. Automated Decision Making………………………………………………………………………………..6
13. Transfers To Third Parties…………………………………………………………………………………….6
14. Transfers Outside Of The UK……………………………………………………………………………….6
15. Right to complaint…………………………………………………………………………………………………7
16. Additional information…………………………………………………………………………………………..7
2. Why we collect your Personal Information

 We collect your personal data for one of the following purposes:

  • To manage communications between you and us
  • Where we need to perform the contract we have entered into with you
  • To provide you with information you have requested or which we may feel may be of interest to you 
  • To ensure the safe operation of our website and to monitor the performance of our website
  • Internal record keeping
  • Proof that you are who you claim you are
  • We may use the information to improve our Bond application procedure
  • We may periodically send promotional emails or other information which we think you may find interesting using the email address which you have provided
  • From time to time, we may also use your information to contact you for market research purposes 
  • We may pass your information to a third party if this is required for legal purposes or to prove your identity
  • To contact you as an Investment Professional or Agent
  • To contact you as a Bondholder
  • To administer the Bond process
  • To enable the company to comply with any anti-money laundering, regulatory or tax requirements.
3. Lawful Basis of Processing Information

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where: 

  • The data subject (you) has given consent to the processing activity taking place, e.g. Investment Professionals or Agents supply us with their personal information required to enable registration to use our website.  In turn they provide you with a link where you initially enter your name and email address, confirm acceptance of this Privacy Notice and confirm your investor status. 
  • If the processing is necessary for the performance of a contract
  • If the processing is necessary for compliance with a legal obligation to which the controller is subject
  • If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners. 

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

The purpose test – to identify the legitimate interest

Necessity test – to consider if the processing is necessary for the purpose identified

Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

4. What Information we collect and where from
The information we collect is not limited to but may include the following:

We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:

  • Name
  • Contact information including email address and telephone numbers
  • Demographic information such as full postal address including postcode
  • Personal information for the purposes of carrying out an identity check which may require address history
  • other information relevant to providing you with our service
  • Electronic identity checks and/or references as part of our Bondholder verification procedure
  • We may monitor and record telephone calls as part of our compliance and training procedures
  • if you invest in our Bond we will also collect details of your bank account including the account number and sort code.


4.1 Special Category Data

We do not process special category data. If we have collected personal information special category data, please contact us using the details in section 15, so we can remove this information without any undue delay. 

4.2 Third Party Collection of Personal Data

We may also collect your data through Third Parties such in any instance where you provide us with personal information of any other person, for example, information about a joint applicant, you must ensure they have a copy of this Privacy Notice.

5. How long we keep Information for
We require this information mainly for the following reasons:

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see “additional information”, section 16 of this policy.

6. Security of Personal Information
We may share your personal data with:

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed.  We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

Part of these procedures may be to ask you security questions, if you telephone our office, prior to disclosing any information to you. We will not disclose your personal information to any third party other than as required to process an Application for a Bond.  

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so. If you would like more details of the security we have in place, please see “additional information”, section 16 of this policy.

7. Children's Information

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.

8. Your Individual Rights

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. 

Your principal rights under General Data Protection Regulation are:

  • Right to Object
  • Right of Access
  • Right to be informed
  • Right to Rectification
  • Right to Erasure
  • Right to Restrict Processing
  • Right to Data Portability
  • The right to object

 

You can exercise this right if

    • Processing relies on legitimate interest
    • Processing is for scientific or historical research
    • Processing includes automated decision making and profiling
    • Processing is for direct marketing purposes
  • The right of access
    • You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge. 
    • We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you. 
  • The right to be informed
  • We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right. 
  • The right of rectification
    • If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made. 
  • The right to erasure
    • If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.  
  • The right to restrict processing
    • You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
    • Processing is unlawful
    • We no longer need the personal data, but it is required for a legal process
    • You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made. 
    • If you are exercising your right to rectification
  • The right to data portability
    • You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
    • Processing is based on consent
    • Processing is by automated means (i.e. not paper based)
    • Processing is necessary for the fulfilment of a contractual obligation

 

If you have any question about these rights, please see “additional information”, section 16 of this policy.

9. Consent

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

10. Failure to provide Personal Information

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

11. Cookies

Our website uses cookies. Please see our cookies policy for full details of the cookies used.

12. Automated Decision Making

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

13. Transfers to Third Parties

William John may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:

  • Business partners, suppliers, contractors for the performance of any contract we enter into with them or you
  • Companies within our group where necessary for administrative purposes and to provide services to you
  • Third parties that support us to provide products and services e.g. IT support, cloud-based software services, providers of telecommunications equipment)
  • Payment service providers
  • Professional advisors e.g. lawyers, auditors
  • Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
  • Other group companies and organisations to enable us to administer the Bonds.  For example, if you invest in our Bond we will share your information with the Registrar and Receiving Agent, the Security Trustee, our legal or professional advisers, Accountants/Auditors and any organisation as required by law – for example HMRC
  • We will also share information where appropriate to comply with the US Foreign Account Tax Compliance Act and OECD and any other organisation in any jurisdiction that seeks to implement a similar tax reporting regime
  • We may also share your information with any organisation with whom we have a legal Introducer’s Agreement
  • We may conduct an identity check with a reference agency to verify your identity and to prevent financial crime
  • If you are an Investment Professional or agent we may share your personal data with any organisation with whom we have a legal Introducer’s Agreement.
14. Transfers Outside of the UK

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information to third parties outside of the United Kingdom (UK). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws. 

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

Standard Contractual Clauses + UK Addendum

Binding Corporate Rules

An exception as defined in Article 49 of the EU GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 16.

15. Right to Complaint

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email on compliance@williamjohn.co.uk 

Alternatively, you can contact us:

By Post: William John (HV) plc, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here

By Email: Click Here

By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate) 

16. Additional Information

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on compliance@williamjohn.co.uk

17. Policy Review and Amendments

We keep this Policy under regular review. This Policy was last updated on 06/01/2025. We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.