Privacy Policy

Privacy Policy Last updated: January 5th 2023.

Our role in your privacy

If you are a HMBC Capital customer or subscriber, or just visiting our website, this policy applies to you.

Our responsibilities

If you are a registered HMBC Capital customer or a visitor to our website we act as the "data controller" of personal data. This means we determine how and why your data are processed.

Your responsibilities
  • Read this Privacy Policy
  • If you are our customer, please also check the contracts - including the Data Processing Agreement available upon request at support@hmbc.co.uk - between us: they may contain further details on how we collect and process your data.
  • If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.

When and how we collect data

If you are only a visitor to our website, please know that we do not collect any personal data before you request a demo of Bearer. We use the privacy-friendly analytics Plausible to carry out site measurement absolutely anonymously.

From the moment you request a demo of Bearer, we start collecting data. Sometimes you provide us with data, sometimes data about you is collected automatically.

Here’s when and how we do this:

DATA YOU GIVE
DATA 
WE COLLECT
ACTION

You request a demo of Bearer

We call you

You use Bearer

You receive emails from us

You chat with us for customer support

You opt-in to marketing messages

DATA YOU GIVE
DATA WE COLLECT
ACTION

You request a demo of HMB Capital

We call you

You use HMBC Capital

You receive emails from us

You chat with us for customer support

You opt-in to marketing messages

Types of data we collect

Your name, email address, role in your company, etc.

Contact details

Your bank account number, sort code, credit/debit card details, etc.

Financial information

The name of your code repositories / projects, APIs & databases, URLs to GitHub / GitLab files, last commit dat, etc.

Metadata from your code repositories

Your data sources & destinations, types of data, business processes, hosting location, security measures, etc.

Metadata from your teams

Your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version, etc.

Data that identifies you

Your URL clickstreams (the path you take through our site), pages viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.

Data on how you use Bearer
Read more

We don’t collect any "sensitive data" about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences).

What about really sensitive data?

Bearer is a business-to-business service directed to and intended for use only by those who are 18 years of age or over. We do not target Bearer at children, and we do not knowingly collect any personal data from any person under 16 years of age.

What about children’s data?

How and why we use your data

Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:

Keeping Bearer Running

Login and authentication, processing payments.

Improving Bearer

Product analytics, heat mapping our site, testing features, and session replay.

Customer Support

Notifying you of any changes to our service, solving issues via live chat support, phone or email including any bug fixing.

Marketing Purposes (With your Consent)

Sending you emails and messages about new features, products and services, and content.

Read more

Your privacy choices and rights

YOUR CHOICES

If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions without personal data.

You can choose not to provide us with personal data

You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use Bearer but certain services (like Intercom) will not work effectively.

You can turn off cookies in your browser by changing its settings

We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at support@bearer.com.

You can ask us not to use your data for marketing
Your Rights

You can exercise your rights by sending us an email at support@bearer.com.

This includes the right to ask us supplementary information about:

  • The categories of data we’re processing
  • The purposes of data processing
  • The categories of third parties to whom the data may be disclosed
  • How long the data will be stored (or the criteria used to determine that period)
  • Your other rights regarding our use of your data

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.

You have the right to access information we hold about you

You can object to us using your data for profiling you or making automated decisions about youWe may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior). Otherwise, the only circumstances in which we will do this is to provide the Bearer service to you.

You have the right to make us correct any inaccurate personal data about you

We will give you a copy of your data in CSV or JSON so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.

You have the right to port your data to another service

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of Bearer.

You have the right to be "forgotten" by us

Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the CNIL, either by calling their helpline or as directed on their website at https://www.cnil.fr/.

You have the right to lodge a complaint regarding our use of your data

How secure is the data we collect?

We have physical, electronic, and managerial procedures to safeguard and secure the information we collect.

And please remember:

  • You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
  • You are responsible of your username and password: keep them secret and safe!
  • If you believe your privacy has been breached, please contact us immediately on support@bearer.com

Where do we store the data?

The personal data we collect is primarily stored in our Amazon Web Services servers in Ireland. As we are a remote company, we process data in the countries we live in (including: Belgium, France, Netherlands, Poland, Portugal, South Africa, the United-Kingdom, the United States) and in any data processing facilities operated by the third parties identified below.

By submitting your personal data, you agree to this transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

How long do we store your data?

We will archive and stop actively using any personal identifiable information about you within 3 months from the last time you used Bearer. We will delete your personal data from our archives no later than 6 years from the last time you used Bearer or as agreed with you in a separate contract.

Third parties who process your data

Tech businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy. Where personal data is transferred to a third party in the United States we take steps to ensure we agree the standard contractual clauses with them. We continually monitor this transfer mechanism. Any data transfers to the US are encrypted and generally consist of insensitive personal data.

Read more

Here are the details of our main third-party service providers, and what data they collect or we share with them, where they store the data and why they need it:

Infrastructure
Amazon Web Services, Inc
Privacy Policy
Data collected or shared
  • Contact details
  • Metadata from your source code
  • Data that identifies you
Purpose

This is a web hosting provider: we use it to store data you generate by using the service securely in the cloud.

Place of processing

EU (Ireland)

SERVICE PROVIDER
Data collected or shared
Purpose
Place of processing

Amazon Web Services, Inc.

Privacy Policy
  • Contact details
  • Metadata from your source code
  • Data that identifies you

This is a web hosting provider: we use it to store data you generate by using the service securely in the cloud.

EEA (Ireland)

Integrations (by your request)
WorkOS, Inc.
Privacy Policy
Data collected or shared
  • Data that identifies you
Purpose

This enables users to authenticate via Single Sign-On.

Place of processing

US

SERVICE PROVIDER
Data collected or shared
Purpose
Place of processing

WorkOS, Inc.

Privacy Policy
  • Data that identifies you

This enables users to authenticate via Single Sign-On.

US

Communications
Intercom, Inc.
Privacy Policy
Data collected or shared
  • Contact details
  • How you use Bearer
  • Cookies
Purpose

We use this service for customer communications, user interaction and helpdesk assistance.

Place of processing

US

Outreach, Inc.
Privacy Policy
Data collected or shared
  • Contact details
  • How you use Bearer
Purpose

We use this service for customer communications.

Place of processing

US

Salesforce, Inc.
Privacy Policy
Data collected or shared
  • Contact details
  • How you use Bearer
Purpose

We use this service for customer communications, user interaction and helpdesk assistance.

Place of processing

US

Twilio, Inc.
Privacy Policy
Data collected or shared
  • Contact details
  • How you use Bearer
Purpose

We use this service for sending, storing and tracking emails.

Place of processing

US

SERVICE PROVIDER
Data collected or shared
Purpose
Place of processing

Calendly LLC

Privacy Policy
  • Contact details

We use this service to set up calls and meetings with customers.

US

Intercom, Inc.

Privacy Policy
  • Contact details
  • How you use Bearer
  • Cookies

We use this service for customer communications, user interaction and helpdesk assistance.

US

  • Contact details
  • Cookies

We use this service to provide webinars to our customers.

EEA (France)

Outreach, Inc.

Privacy Policy
  • Contact details

We use this service for customer communications.

US

Salesforce, Inc.

Privacy Policy
  • Contact details
  • How you use Bearer

We use this service for customer communications, user interaction and helpdesk assistance.

US

Twilio, Inc.

Privacy Policy
  • Contact details
  • How you use Bearer

We use this service for sending, storing and tracking emails.

US

Webflow, Inc.

Privacy Policy
  • Contact details

We use this service to build our website and our demo form.

US

Zapier, Inc.

Privacy Policy
  • Contact details

We use this service to automate tasks like sending emails.

US

Payments (Depending on your Payment Terms)
Stripe, Inc.
Privacy Policy
Data collected or shared
  • Contact details
  • Financial information
Purpose

This service processes payments for us.

Place of processing

EU & US

SERVICE PROVIDER
Data collected or shared
Purpose
Place of processing

Stripe, Inc.

Privacy Policy
  • Contact details
  • Financial information

This service processes payments for us.

EEA & US

Cookies

We don’t use cookies on visitors. We use Plausible to carry out our website measurement completely anonymously.

When you interact with Bearer as a user, we (and these third parties) will issue cookies unless you adjust your browser settings to refuse them. These may be ‘session’ cookies, meaning they delete themselves when you leave Bearer, or ‘persistent’ cookies which do not delete themselves and help us recognise you when you return so we can provide a tailored service.

How can I block cookies?

You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use those cookies

Read more
Which specific cookies do we use?
Intercom, Inc.
KEY COOKIES

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intercom-id-[TOCOMPLETE]

Purpose

Intercom uses cookies to recognise particular people who have interacted with Intercom through Bearer previously. This may be visitors to our website, Bearer users or counterparties.

You may refuse the transmission of your Information by opting out (contact them directly for more information), however, please note that you will delete the opt-out cookie when you delete your cookies in your browser settings.

SERVICE PROVIDER
Purpose

Intercom, Inc.

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intercom-id-i68d2lqu

Intercom uses cookies to recognise particular people who have interacted with Intercom through Bearer previously. This may be visitors to our website, Bearer users or counterparties.

You may refuse the transmission of your Information by opting out (contact them directly for more information), however, please note that you will delete the opt-out cookie when you delete your cookies in your browser settings.

Making this policy great

This privacy notice was built base on an open-source design from Juro adapted to Webflow by Bearer. Get these patterns free: privacy policy template and Webflow template.

‍Please don’t make this the last time you read it as we will post any changes on this page - significant changes will of course be notified to you by email.

Privacy Policy

Hunter Mahan Holding Limited ("HMH")

Privacy Policy last updated:
February 6th 2024.

Privacy Notice
"We", "our" or "us" means Hunter Mahan Holding Limited. For the purposes of data protection law (the Data Protection Act 1998), we are a data controller in respect of personal data. We collect and use personal data as described below. We are responsible for ensuring that we use personal data in compliance with applicable data protection law.

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, you can contact us via email to info@hunter-mahan.co.uk in the first instance.

Alternatively, our Data Protection Officer can be contacted using the details set out in the “Contact us” section below.

This notice applies to personal data we receive or otherwise create in connection with the provision of services to retail clients / professional clients / eligible counterparties and their personnel, including any associated services provided via our website at:

https://www.hunter-mahan.co.uk

It is important that you take the time to read this notice so that you understand how we will use yourpersonal data and your rights in relation to your personal data.


Personal data that we collect about you
We will collect and use the following information about you:

Information you give us
We use the information about you that you provide to us, including the information that you provide when filling in fields in a contract (or related application) or when registering to use sections of our website (such as your name, company name, address, e-mail address, phone number, job title, your preferences for receiving email communications from us) and any other information or updates to your information that you provide to us when corresponding with us (by phone, e-mail or otherwise).

Information we collect or generate about you
• When you submit information to us, we may use this information to interact with, and provide services to, you (or your employer), and to carry out our obligations arising under or in connection with a contract.
• We may also receive information from other sources for the above purposes.
• Website usage information – our website use Google Analytics and cookies to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. We do not identify individual users from this type of data and it does not involve the processing of personal data about you. This information helps us to measure how individuals use our website and our services, so that we can continually improve them. For more information on our use of cookies please refer to our cookies policy on the relevant website.
• We may record, monitor and retain any and all communications (which may include the recording and monitoring by a third party appointed by us), including email and other electronic messaging, telephone conversations and other electronic communications with you, for the purposes of providing services to you (or to your employer) and/or otherwise in order to comply with applicable law.
• We generate data for internal analysis and research.

If we do not receive this information we may not be able to provide certain services to you.

How we use your personal data
Your personal data may be processed by us for the following purposes:

• to provide you with services you request (or services requested by your employer) or other services reasonably ancillary thereto, and to carry out our obligations arising under or in connection with a contract;
• to administer and maintain user access to our services and/or website;
• to communicate with you in relation to the services we provide to you (or to your employer);
• to comply with our obligations under applicable law;
• to monitor and improve our website and services; and/or
• for internal analysis and research.

Legal basis for processing your personal data
We process your personal data pursuant to the following legal bases:

(i) where necessary to comply with a legal obligation (for example anti-money laundering, know-yourcustomer and counter-terrorist financing checks and the prevention and detection of fraud and other financial crime);

(ii) where necessary for the purpose of our legitimate business interests which includes:
• the provision of services to you (or your employer), the sending and receipt of communications in relation thereto and/or carrying out obligations arising in connection with a contract;
• compliance with legal and regulatory obligations (including applicable laws, rules and regulations outside of the European Union and requests or requirements of competent authorities);
• contacting you with email updates in relation to services;• generating data for internal analysis and research (including monitoring and improving our website and services);
• marketing HCL’s products and services, including event invitations and the sending of branded merchandise; and
• keeping a record of what individuals are interested in hearing about from us.

or

(iii) where you have separately consented for us to use your personal data to send you specific email updates and communications (by opting-in to such email updates/ communications).

You have the right to object to processing under (ii), and you may cancel your subscription under (iii), at any time by emailing us at info@hunter-mahan.co.uk and requesting the same.

Please note that any instruction to unsubscribe from communications will not affect any processing pursuant to (i) and (ii) in relation to compliance with a legal obligation.

Research Recipients
In order to send research recipients our research, we maintain a distribution list of email addresses. We have a legitimate interest in keeping those contact details on file in order to continue to provide research to inform and educate the investor community about their shareholdings or potential shareholdings and to assist our corporate client by publishing information about them to a wide audience of investors and potential investors. Therefore, we are relying on the legitimate interest basis for controlling and processing research recipients email addresses.

As set out in more detail below in the “Your rights” section, you have a number of rights in relation to how we process and control your data. In addition, if at any time you wish to stop receiving our research, you can either contact us via the information set out below in the “Contact us” section or you can follow the instructions on how to unsubscribe in the disclaimer on any piece of research.

Sharing your personal data
We may disclose your personal data to our third-party service providers in the circumstances described below:

• to facilitate the provision of services to you (or your employer);
• to facilitate the administration and maintenance of user access to our services and/or website;
• to conduct and/or improve our business development activities;
• to ensure the safety and security of our data (and that of third parties, including data vendors and other data sources); and
• as part of our internal research and statistical analysis activity.

We will take reasonable steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.

We may also share your personal data with third-parties:

• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third-party buyer; and
• to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this notice.We may also share your personal data with third parties (including, without limitation, regulatory, governmental, judicial and other bodies or authorities of competent jurisdiction) to the extent required by applicable law, for example if we are under a duty to disclose your personal data in order to comply with any legal or regulatory obligation, and to establish, exercise or defend our legal rights

Transfer of personal data outside the European Economic Area
The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for us or an affiliate or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

• the country that we send the data to might be approved by the European Commission or a relevant data protection authority (as offering equivalent protections to those afforded in the EEA);
• the recipient might have signed up to a contract based on “model contractual clauses”
• approved by the European Commission, obliging them to protect your personal data;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
• in other circumstances where the law permits us to otherwise transfer your personal data outside the EEA

In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose (for example, to communicate with you in respect of our services for so long as you (or your employer) remain a recipient of such services); and/or
• legal and regulatory obligations – applicable laws, rules or regulations may set a minimum period for which we have to store your personal data.

Your rights
You have a number of rights in relation to the personal data that we hold about you. These rights include:

• the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be required to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally required to retain it;
• the right to request that we restrict our processing of your personal data in certain circumstances.

Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;

• the right to object to the processing of your personal data for direct marketing purposes; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contact us” section below. You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk/

Changes to this Privacy Notice
We keep this notice under regular review. Any changes we make to this notice in the future will be posted on this page. Please check back frequently to see any updates or changes to this notice.

Sharing your personal data
Hunter Mahan Holding Limited is a company registered in England and Wales. Our registered address is at Wall House Green Lane, Wall, Lichfield, England, WS14 0AS and our company registration number is 12813705.

Please contact us if you have any questions about this notice or personal data that we may hold about you.

• By post: Data Protection Officer, Hunter Mahan Holding Limited, Wall House, Green Lane Wall, Lichfield, Staffordshire, WS14 0AS
• By telephone: +44 1543 483700; or
• By email: info@hunter-mahan.co.uk