Privacy Notice
Why our privacy policy matters
On this page you can find out everything you need to know about the personal data we keep, how it complies with current legislation and your rights when it comes to opting out.
We have split our privacy notice into separate sections, to make it easier for you to find the information you are looking for:
- Who to contact about the data we hold.
- What information we collect about you and when.
- How we collect your information.
- How we use your information.
- Who we share your data with.
- Your rights.
- At a glance: key facts.
- Our use of cookies.
Who to contact about the data we hold
If you have any comments, queries or complaints about this notice, or about how we use your personal data, please contact:
Data Protection Officer
Harbour Rock Capital Limited
Affinity House
Beaufort Court
Medway City Estate
Rochester
Kent
ME2 4FD
adviseme@harbourrockcapital.co.uk
You can also contact the UK information commissioner about anything relating to your personal data or to make a complaint. Visit ico.org.uk to find out how to report a concern. Or you can write to:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
What information we collect about you and when
People come to us for help and information, or we communicate directly with people for all sorts of reasons and in many different ways. And there are different stages to someone’s journey with us, from simply requesting information, to receiving financial advice and an ongoing service.
Depending on where you are at in the client journey, we will collect the following data:
- All contact information including: full name, phone number, email address and postal address.
- All relevant ID documents.
- Likeness image & Biometric Data (via a 3rd party – Thirdfort). We use this purely for identification purposes.
- All relevant financial and employment information.
- All relevant personal information including: medical details, beneficiaries and any benefits you are receiving.
- We may also receive your contact details (name, address) from selected 3rd parties, who have collected your information for marketing purposes and disclose this to us, using the legal basis of Legitimate Interest.
- Special category data (sensitive data) will only be used with your explicit consent.
We only keep your personal data for as long as we need to provide the products and services you have requested, or to fulfil our legal and regulatory obligations.
How we use your information
Data protection rules are very clear. We can only use and share your personal data if we have one or more legally defined reasons to do so. The four legally defined reasons are:
- Contract: your personal data is processed to fulfil a contractual arrangement (e.g. to carry out your financial advice).
- Consent: this is where you agree to us using your personal data for specified reasons (e.g. the latest news and updates).
- Legitimate interests: this refers to our legitimate interests in managing our business so we can provide you with information and services in the most secure and appropriate way (e.g. to send you an information pack or marketing information about our services). We must then balance this with the interests of the people whose personal data we hold.
- Legal obligation: this is where we are required to share your personal data because of a legal or statutory decree (e.g. a request from the police).
Who we share your data with
We may transfer your data to third parties acting on our behalf for further processing in line with the purpose for which the data was originally collected. This covers areas such as service delivery, marketing, data management, identity information and technical support.
Our contracted third parties can and will only use personal data for the agreed purpose and will not:
- Sell your personal data to other third parties.
- Disclose your personal data to other third parties unless it is required by law or as stated in this privacy notice.
Sometimes we need to transfer personal data to third parties outside of the UK. For example: processing email communications through international servers so that we can deliver useful communications to clients.
Your rights
Your personal data is just that: your personal data. As such, from a legal perspective you have some fundamental rights and these are called your Data Subject Rights. In this section we will cover some of those rights in detail, and summarise the rest.
Your right of access
At any time, you can ask us for details of the personal data we hold about you. You can request this via email or in writing:
Data Protection Officer
Harbour Rock Capital Limited
Affinity House
Beaufort Court
Medway City Estate
Rochester
Kent
ME2 4FD
adviseme@harbourrockcapital.co.uk
Once we receive your request and proof of identity, we will provide you with details of the personal data we hold about you within one month (which can be extended in certain circumstances).
You also have the right to challenge the data we hold about you and, where appropriate, have it erased, rectified, restricted or objected.
Important note: At certain stages of our interactions with clients we are required by the Financial Conduct Authority (FCA) to keep personal data for a specific period.
We will only keep your data for as long as is necessary to provide our products and services to you and/or to fulfil our legal and regulatory obligations.
Your right to opt out
You have the right to opt out of marketing communications from us at any time, by any method, such as email, phone, or letter.
Communication Preferences
Even if you opt out of marketing, if you conduct business with us we will still send you communications that are necessary for us to provide you with the service you are paying for.
However, if you have a preferred way for us to contact you, such as by email, phone or post, or you would rather not receive a particular method of communication, you can let us know at any time.
At a glance: key facts
This notice covers the privacy of visitors to our website, data supplied to our mailing house for marketing on our behalf, as well as data capture networks and personal data collected by Harbour Rock Capital (as a data controller) under the United Kingdom General Data Protection Regulation (UK GDPR).
At Harbour Rock Capital, we are all committed to safeguarding your personal information, and we ensure that it is treated securely. And we are legally obliged to use your personal data in line with all laws concerning the protection of personal information, including the UK GDPR and Data Protection Act 2018. This notice is compliant with the UK GDPR.
Our Data Protection Policy sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data.
Our GDPR Statement of Compliance sets out our commitment to processing and protecting personal data in compliance with the GDPR.
We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is: Z176088.
This privacy notice was last updated on 18th September 2026.
What happens to your data when your file is closed?
We need to retain your data for six months in case you raise a complaint about the service you have received. After that we will destroy all data we hold on you in line with data protection regulations.
Due to regulatory requirements by the Financial Conduct Authority, legitimate interest and legal time limits, we currently keep data relating to and evidencing suitability of advice indefinitely. This includes all information gathered as part of our financial advice process.
In the future you may want to query the information or advice we have given you. You might want to raise any concerns direct with us, via the Financial Conduct Authority, through the Financial Ombudsman Service (FOS), or another legal route. In addition, we need to keep the information we hold on you to show we are compliant with our regulatory requirements, should the Financial Conduct Authority audit Harbour Rock Capital.
As a result, according to Financial Conduct Authority rules we must keep all the information we have on you in relation to our review and advice. And, at the moment, these rules do outweigh data protection legislation.
Please be assured that this data is stored securely, in accordance with current data protection regulations, and would only be processed for the legal and compliance purposes mentioned in the previous paragraph, and only accessed by those who have a legitimate business interest to do so.
Changes to the privacy notice
Our use of cookies
The cookie monster myth!
Cookies have developed a bad reputation over the years, portrayed as invisible, digital extensions of the big brother society. Yet, the reality is very different. Used responsibly and ethically, cookies help companies and organisations to make life online quicker and easier for people. Please read on for more information on what cookies are and how we use them.
What are cookies
Cookies are small files, or little bits of code, that are stored on your browser, computer hardware or other device when you visit websites. These files perform a variety of functions and have different lifespans: some expire as soon as you leave the website, while others may last for as long as a couple of years (unless you remove them…more on that in a moment).
How we use cookies
- To make sure our website runs smoothly while you are using it and to improve navigation. For example: You can use the back button on your browser to return to the last page you visited because of one of the cookies we use.
- To gather information on how you arrived at our website and then used it. This way we can learn more about what people want to know and in what order. For example: We can use the data we gather to change the layout or position of a webpage, to make it easier for people to find and use.
- To find out which of our online adverts and messages work. The internet is a noisy place and the less unwanted noise we create, the better. For example: We can determine which Facebook and Google ads make a connection with people and ditch the ones that don’t.
- To deliver personalised information based on what someone has previously shown an interest in, or where a client is at on their journey. For example: We can identify if you have already begun a pension review with us and tailor our website with information we think will be most useful for you.
Introducing the types of cookie that we use
The cookies we use are set when someone submits a form, logs-in, or interacts with the site in a way that goes beyond clicking or simple links. Some of these cookies are essential and our website won’t work as it should do without them. Others are non-essential and simply gather data on how people interact with our site; this helps us to improve a visitor’s experience. Let’s have a look in more detail at the different types of cookie we use.
Necessary cookies
These cookies make sure our website runs effectively. Without them our website would be slow and cumbersome and some aspects of it might not work at all.
Statistical cookies
The cookies gather anonymous data that helps us to understand how, when and why people use our website. We use this data to make our website better and easier to use.
Performance cookies
These are another set of cookies that help us to improve our website and other digital communications. For example, we can use the data gathered to monitor which of our online adverts work best, or to tailor the website for a returning visitor.
Email cookies
These cookies help us to gather all sorts of information about the emails we send to subscribers. We can look at things like: how many times an email has been opened and which links have been clicked. These cookies do not store a file on your computer.
How to block or remove cookies
When was the last time you visited a website and quickly became frustrated with it?
A website can contain all the useful information in the world but it’s next to useless if the customer journey is slow or illogical.
Cookies play a vital role in making sure our website is quick and easy for people to find and explore. We get that cookies are not for everyone, though.
If they are not for you, then it is easy to block or remove the cookies we use by changing the settings on your browser. There are plenty of sites that will help you to do this, such as allaboutcookies.org
Please remember that blocking or removing cookies could make your website journeys slow and difficult.