Privacy Policy

HFA Holdings Limited cares about your privacy and is committed to maintaining the trust and confidence of visitors to our website and subscribers to our newsletter. For this reason, we collect and use personal data only as it might be needed for us deliver to you our website and services.

Our Privacy Policy is intended to describe to you how and what data we collect, how and why we use your personal data, and your individual rights.

We ask you to read this Privacy Policy to ensure you are happy with the way that HFA Holdings Limited will process your data.

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR).

Who are we?

HFA Holdings Limited is company registered in the British Virgin Islands (referred to as “HFA”, “we”, “our” or “us” in this policy).  Our registered office is at Nerine Chambers, Road Town, Tortola, British Virgin Islands.

What personal information do we collect and process?

When you make contact with HFA we receive and process personal information as provided by you when you complete a contact form on our website or when you contact us by email.

The personal information we collect may include your name, address, email address, telephone number, IP address, and information regarding what pages you access on this website and when.

We only collect and process the information needed to effectively provide our services to you, and for contact and communication purposes.

How is your personal information used?

We use your personal data or information to effectively operate the business and provide you with a quality service. We may use your information:

  • To answer enquiries that you raise.
  • To deliver access to the Fan Club to you.
  • To keep you informed, if you have opted-in to receive communications.

We believe that all these purposes are justified on the basis of our legitimate interests in running and promoting the business. The exception is for sending email marketing, which we carry out on the basis of consent.

Who we share your personal information with

We do not sell or rent your personal data or information to any third party or share your information with third parties for their own marketing purposes.

We will disclose your data or information if required by law, for example by a court order or for the prevention of fraud or other crime.

We may pass your information on to third party service providers or subcontractors for the purposes of completing a task or providing services to you on our behalf. However, we disclose only the personal information necessary to deliver that service and have a contract in place that requires them to keep your information secure and not to use it for other purposes.

Where your personal information is stored

Your information is stored on dedicated hardware provided by our web hosting company and the data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). This will typically occur when service providers are located outside the EEA.

We will always take steps to ensure that such transfers comply with applicable privacy laws and we will take all reasonable precautions to ensure that your personal information is treated securely and in accordance with this privacy policy. However, you should be aware that countries outside the EEA may not offer the same level of protection for personal information as the United Kingdom.

Our standard practice will be to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers.

How long we keep your personal information

We will not retain your data for longer than necessary for the purposes set out in this policy.

We are required by law to keep some information for a minimum period of time e.g. financial information for tax purposes.

Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 7 (seven) years. Where there is no legal requirement we will retain personal information for only as long as necessary to deliver our services and respond to any subsequent communications. Our standard policy is to delete personal information two years after ceasing to supply our service.

You are able to update, amend or request deletion of your personal information at any time by contacting us.

When do we collect your information on this website?

Website browsing
When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.

We collect information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, entry and exit points and the number of page views). We do this to find out things such as the number of visitors to the various parts of the site.

Website forms
Our website has forms built using Elegant Themes. When you use our contact form the information submitted is sent to us via email so that we can correspond with you.

Mailing list
When you subscribe to our newsletter we collect your email address and name so that we can correspond with you. Your personal data will be stored in MailChimp, the application we use to send our newsletters. You can request to be removed anytime by clicking ‘unsubscribe’ in any newsletter/mailout or by contacting us.


Like most websites the HFA website uses cookies to collect information. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Your rights in respect of the personal information we hold

We fully support and facilitate the ability of people to exercise their rights in respect of the personal information supplied to others.

You have certain rights over the processing of your personal information by us. These are:

  • The right to be informed, which is what this privacy policy is for.
  • The right to access the data we hold about you.
  • The right to object to direct marketing.
  • The right to object to processing carried out on the basis of legitimate interests.
  • The right to erasure (in some circumstances).
  • The right to data portability.
  • The right to have your data rectified if it is inaccurate.
  • The right to have your data restricted or blocked from processing.

We ask for your consent to send you direct marketing information, and will always provide you with the opportunity to amend your preferences or to opt-out of receiving future marketing communications from us.

How you can update your information

The accuracy of your information is important to us. If you change your contact details or if you want to update any of the information we hold on you, please contact us.

How you can access your personal information

You have the right to ask for a copy of the personal information we hold relating to you. To do this please contact us.

We will respond to as soon as possible, and in any event, within thirty (30) days of verifying the request. To protect the confidentiality of your personal information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Keeping your data secure

When you give us personal information we take steps to ensure that it’s treated securely and strive to protect it on our internal systems.

HFA data is primarily stored in the UK. Off site backups are taken at regular intervals but are kept for no more than 90 days, these are kept within the EU.

Our hosting providers store HFA project data, produce and keep rotational off-site backups for no more than 90 days. If we receive a specific request to delete an individual’s personal data we will remove the information if appropriate. Our back up cycles are 90 days, so the individuals details will be fully purged from our system after the 90 days has expired.

Contacting us via email
We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government standards. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Links to Other Web Sites

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

The UK Supervisory Authority

We would encourage you to contact us if you are unhappy about our processing of your personal information and we will do our very best to resolve the issue. If you are unhappy with the way we are using your personal information you can also complain to the Information Commissioners Office (ICO) using one of the methods below:

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
Telephone: 0303 123 1113

Do you have a question, concern or complaint?

If you have any questions, concerns or complaints about our Privacy Policy, you may contact our Compliance Officer at

We will respond to all requests, inquiries or concerns as soon as possible, and in any event, within thirty (30) days.

Changes to this Privacy Policy

We keep our Privacy Policy under regular review. This Privacy Policy was last updated on 16/08/2019.


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