Privacy Policy

Hawker Wealth Management Ltd

Last updated: April, 2026

1. Introduction

Hawker Wealth Management Ltd ("we", "us", "our") is committed to protecting your personal information and respecting your privacy. Hawker Wealth Management Ltd is authorised and regulated by the Financial Conduct Authority (FCA).

2. What Personal Information We Collect

We may collect and process the following categories of personal data:

  • Identity Data – name, date of birth, gender, nationality, marital status, and identification documents (passport, driver's licence, etc.)

  • Contact Data – postal address, email address, and telephone numbers

  • Financial Data – income, bank account details, investment holdings, assets and liabilities, tax information, financial objectives, and risk tolerance

  • Professional Data – employment details, source of wealth, business ownership interests, and occupation

  • Family Data – information about dependants, beneficiaries, and next of kin where relevant to financial planning

  • Special Category Data – where necessary for providing our services, we may collect health information (for example, for estate planning, protection advice or capacity assessments), information about criminal convictions (for regulatory compliance), or other sensitive personal data. We will only process this data with your explicit consent or where otherwise permitted by law

  • Technical Data – IP address, browser type, device information, and usage data collected from our website or online portals

  • Marketing & Communication Data – your preferences for receiving marketing or regulatory updates from us

3. How We Collect Your Information

We collect your data in the following ways:

  • Directly from you – when you complete forms, open an account, attend meetings, respond to questionnaires, or contact us by email, phone, or post

  • From third parties – such as credit reference agencies, platform providers, wealth planning companies, fund managers, pension providers, insurance companies, product providers, or public databases

  • Automatically – when you visit our website (via cookies or analytics tools, where you have consented)

4. How We Use Your Information

We use your personal data to:

  • Provide wealth management and financial advisory services, including investment recommendations and portfolio management

  • Conduct suitability assessments and risk profiling

  • Administer your accounts and investments

  • Conduct identity verification, credit checks, and anti-money laundering (AML) checks

  • Comply with our legal and regulatory obligations under FCA rules, HMRC requirements, and other applicable legislation

  • Manage our business operations and maintain internal records

  • Communicate with you about your portfolio, service updates, or our services

  • Send you relevant updates, newsletters, or marketing materials (only if you have opted in)

  • Conduct analysis to improve our services and client experience

5. Automated Decision-Making and Profiling

We use automated processing and profiling in certain circumstances, including:

  • Risk profiling – to assess your attitude to investment risk and determine suitable investment strategies

  • Suitability assessments – to match investment recommendations to your financial objectives and circumstances

  • Portfolio monitoring – to identify when portfolio rebalancing may be required

These automated processes help us provide appropriate and timely advice. However, you have the right not to be subject to decisions based solely on automated processing where these significantly affect you. Our automated assessments are subject to human review and oversight, and you can request manual review of any automated decision by contacting us.

6. Legal Bases for Processing

We process your personal data only when permitted by law. The main legal bases we rely on are:

  • Contractual necessity – processing is required to provide you with financial services and fulfil our contractual obligations to you

  • Legal obligation – compliance with FCA rules, AML regulations, tax reporting requirements (including FATCA and CRS), and other legal duties

  • Legitimate interests – maintaining client relationships, improving services, preventing fraud, and managing business operations. When relying on legitimate interests, we have balanced our interests against your rights and freedoms and are satisfied that our processing is proportionate and does not override your interests

  • Consent – for marketing communications and where required for processing special category data (such as health information). You may withdraw consent at any time by contacting us

7. Who We Share Your Information With

We may share your information with:

  • Regulators and authorities – including the FCA, HMRC, law enforcement, and other regulatory bodies where legally required

  • Platform providers – investment platforms where your assets are held or traded

  • Custodians, fund managers and product providers – to facilitate transactions and account administration

  • Wealth planning companies and other intermediaries – where you have engaged third parties to work alongside us in your financial planning

  • Professional advisers – such as auditors, legal counsel, and compliance consultants

  • IT and cloud service providers – who host or manage our systems under strict confidentiality agreements

We do not sell or rent your personal data to third parties for marketing purposes.

8. International Transfers

If we transfer your personal data outside the UK, we ensure that appropriate safeguards are in place, such as:

  • Transfers to countries recognised by the UK Government as providing adequate protection, or

  • Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO), or

  • Other legally approved transfer mechanisms

We will inform you of any international transfers where required by law.

9. Data Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or misuse, including:

  • Encryption of data in transit and at rest

  • Firewalls and secure access controls

  • Regular security audits and penetration testing

  • Staff training on data protection and information security

  • Restricted access to personal data on a need-to-know basis

  • Secure disposal of data when no longer required

In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the ICO within 72 hours where legally required.

10. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined above and to meet legal, regulatory, and reporting obligations.

Typically, we keep client records for at least six years after the end of our business relationship, in line with FCA requirements. Certain records may be retained for longer periods where required by law or where we have a legitimate interest in doing so (for example, to defend potential legal claims).

When data is no longer required, it is securely deleted or anonymised.

11. Your Rights

Under data protection law, you have the right to:

  • Access your personal data – you can request a copy of the personal data we hold about you (known as a "subject access request")

  • Request correction of inaccurate or incomplete data

  • Request deletion of your data ("right to be forgotten"), subject to our legal and regulatory obligations

  • Object to or restrict processing – in certain circumstances, you can ask us to stop or limit processing

  • Request data portability – to receive your data in a structured, commonly used format or have it transferred to another controller

  • Withdraw consent – where processing is based on consent, you can withdraw it at any time (though this will not affect the lawfulness of processing before withdrawal)

  • Object to automated decision-making – you can request human intervention in automated decisions that significantly affect you

 

 

To exercise your rights, please contact us using the details below. We will respond to requests within one month, though this may be extended by up to two months for complex requests. We will inform you of any extension and the reasons for it.

We may need to verify your identity before processing certain requests to protect your personal data.

12. Cookies and Website Tracking

Our website uses cookies and similar technologies to enhance user experience, analyse site traffic, and improve functionality. You can manage or disable cookies through your browser settings, though this may affect your ability to use certain features of our website.

13. How to Contact Us

If you have any questions or concerns about this Privacy Policy or your personal data, or wish to exercise any of your rights, please contact:

Data Protection Officer (DPO)
Hawker Wealth Management Ltd
Email: info@hawkerwealth.co.uk
Telephone: +44 (0)203 954 2550

We aim to respond to all enquiries within 5 working days.

14. Complaints

If you are unhappy with how we handle your personal data, please contact us in the first instance using the details above. We take complaints seriously and will investigate your concerns promptly.

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

Website: https://ico.org.uk/concerns
Telephone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by direct communication. The "Last updated" date at the top of this policy indicates when it was last revised.