Privacy Policy

  1. This Privacy Policy applies between you, as the user of this Website, and HMCI Limited, the owner and operator of this Website. HMCI Limited takes the privacy and security of your personal information seriously. This Privacy Policy explains how we collect, use, store and protect any Data provided to us, or collected by us, in connection with your use of the Website.

    Please read this Privacy Policy carefully.

Scope of this Privacy Policy

  1. This Privacy Policy applies only to the activities of HMCI Limited and users in relation to this Website. It does not
    apply to any third-party websites that may be accessed through this Website, including any links to social media
    platforms or external resources.
  2. For the purposes of applicable Data Protection Laws, HMCI Limited is the data controller. This means that HMCI
    Limited determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

  1. We may collect the following Data, which may include personal Data, from you:

a. name;

  • date of birth;
  • job title;
  • profession;
  • contact information such as email addresses and telephone numbers;
  • financial information such as credit or debit card numbers;

in each case, in accordance with this Privacy Policy.

How We Collect Data

  1. We may collect Data in the following ways:
  1. Data is provided to us by you; and
  2. Data is collected automatically when you use the Website.

Data That is Given to Us by You

Data That is Given to Us by You

  1. HMCI Limited may collect your Data in a number of ways, including:
  1. when you contact us through the Website, by telephone, post, email or any other means;
  2. when you register with us or request our services;
  3. when you complete surveys or provide feedback, where applicable;
  4. when you interact with us through social media or other online channels;
  5. when you make payments to us, whether through the Website or otherwise;
  6. when you ask us to contact you or provide information about our services;
  7. when you use our services.

in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

  1. Where you access the Website, certain Data may be collected automatically. This may include your IP address, the date, time and frequency of your visits, and information about how you use and interact with Website content. This helps us improve the Website, its content and navigation.

Our Use of Data

  1. Any or all of the above Data may be required by us from time to time in order to provide our services and to maintain and improve your experience when using our Website. Data may be used by us for the following purposes:
    in each case, in accordance with this Privacy Policy.
  2. We may use your Data for the above purposes where it is necessary for our legitimate interests, provided that your rights and interests do not override those interests. You have the right to object in certain circumstances, as explained in the section headed “Your rights” below.
  3. Where you register with us or request our services, the legal basis for processing your Data may include the performance of a contract between you and us, or taking steps at your request before entering into such a contract.

Who We Share Data With

  1. We may share your Data with the following categories of recipients where necessary and lawful:
  1. our employees, agents and professional advisers, where necessary to provide our services, obtain professional advice, manage our business and comply with our legal and professional obligations;
  2. third-party service providers who process personal data on our behalf, including providers of IT, software, cloud hosting, payment, administration and other support services;
  3. third-party payment providers who process payments made to us, where applicable;
  4. relevant authorities, including HM Revenue & Customs, Companies House, anti-money laundering supervisory bodies, law enforcement agencies, regulatory authorities and other public bodies, where disclosure is required or permitted by law for tax compliance, statutory filing obligations, professional and regulatory compliance, anti-money laundering checks, fraud and crime prevention, the collection of taxes and duties, or responding to lawful requests for information.

in each case, in accordance with this Privacy Policy.

Keeping Data Secure

  1. We use appropriate technical and organisational measures to safeguard your Data, including:
    a. access controls, including passwords and user names where applicable;
    b. storing Data on secure servers; and
    c. using encryption technologies, such as SSL, where payment or other sensitive details are transmitted through the Website.
  2. Our technical and organisational measures include procedures for dealing with suspected data breaches. If you suspect any misuse, loss of, or unauthorised access to your Data, please contact us immediately by email at office@hamillmcilwaine.com.
  3. For further guidance on protecting your information, computers and devices against fraud, identity theft, viruses and other online risks, you may wish to refer to Get Safe Online, which is supported by HM Government and leading businesses.

Data Retention

  1. Unless a longer retention period is required or permitted by law, regulation or professional obligations, we will hold your Data only for as long as is necessary to fulfil the purposes set out in this Privacy Policy.
    By way of general guidance, our typical retention periods are as follows, unless a longer or shorter period is required by law, regulation, professional standards, contractual obligations, insurance requirements, dispute resolution, or another legitimate business reason:
  • client engagement records, correspondence and working papers will normally be retained for at least six years after the end of the relevant engagement, client relationship, accounting period or tax year, as appropriate;
  • tax, accounting, VAT, payroll and statutory filing records will normally be retained for at least six years, or longer where required by HM Revenue & Customs, Companies House, professional requirements or applicable law;
  • anti-money laundering and client due diligence records will normally be retained for five years after the end of the business relationship or the completion of the relevant transaction, unless a longer period is required or permitted by law;
  • records relating to disputes, complaints, professional indemnity matters or potential claims may be retained for longer where necessary to establish, exercise or defend legal rights;
  • website enquiries and general correspondence from non-clients will normally be retained only for as long as necessary to respond to the enquiry and manage any resulting relationship;
  • records of service communications, contact preferences and consent records may be retained for as long as necessary to manage our relationship with you, evidence your preferences or withdrawal of consent, and comply with our legal and professional obligations;
  • backup, archive and disaster recovery copies may be retained for limited periods in accordance with our backup and business continuity procedures.
  • Where Data is deleted from active systems, copies may remain on backup or archival media for a limited period where required for legal, tax, regulatory, security or business continuity purposes.

Your Rights

  1. You have the following rights in relation to your Data:
    a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
    c. Right to erase – the right to request that we delete or remove your Data from our systems.
    d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
    e. Right to data portability – the right to request that we move, copy or transfer your Data.
    f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
  2. To make an enquiry, exercise any of your rights set out above, or withdraw consent where consent is our legal basis for processing your Data, please contact us by email at office@hamillmcilwaine.com.
  3. If you are not satisfied with how we handle a complaint relating to your Data, you may be able to refer the matter to the relevant data protection authority. In the UK, this is the Information Commissioner’s Office.
  4. It is important that the Data we hold about you is accurate and up to date. Please let us know if your Data changes while we hold it.

Links to Other Websites

  1. This Website may, from time to time, include links to other websites. We do not control those websites and are not responsible for their content or privacy practices. This Privacy Policy does not apply to your use of third-party websites, and you should read the privacy policy or privacy notice of any website you visit.

Changes of Business Ownership and Control

  1. HMCI Limited may, from time to time, expand, reorganise or transfer all or part of its business. Where relevant, Data provided by users may be transferred as part of that process, and the new owner or controller may use the Data for the purposes for which it was originally supplied, in accordance with this Privacy Policy.
  2. We may also disclose Data to a prospective purchaser or transferee of our business, or any relevant part of it, where appropriate and lawful.
  3. In these circumstances, we will take reasonable steps to ensure that your privacy continues to be protected.

General

  1. You may not transfer any of your rights under this Privacy Policy to another person. We may transfer our rights under this Privacy Policy where we reasonably believe that your rights will not be adversely affected.
  2. If any court or competent authority finds that any provision of this Privacy Policy, or part of any provision, is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed deleted. The validity and enforceability of the remaining provisions will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by either party in exercising any right or remedy will be treated as a waiver of that, or any other, right or remedy.
  4. This Privacy Policy will be governed by and interpreted in accordance with the law of Northern Ireland. Any disputes arising in connection with this Privacy Policy will be subject to the exclusive jurisdiction of the courts of Northern Ireland.

Changes to This Privacy Policy

  1. HMCI Limited may update this Privacy Policy from time to time, including where required by law or to reflect changes in our services, Website or data protection practices. Any updates will be posted on the Website, and the revised Privacy Policy will apply from the date it is published.

If you have any questions about this Privacy Policy or how we handle your Data, please contact us by email at office@hamillmcilwaine.com.

This Privacy Policy was created on 1 June 2026.