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We only collect personal information that is reasonably necessary for us to perform our functions. This may include:
We collect your personal information in a number of ways, including:
Your personal information may be used in a number of ways including but not limited to:
We may use your personal information for additional purposes related to the purposes listed above. We will not use your personal information other than for:
From time to time, we may contract out some of our functions such as mailing, settlement services or identification verification to external service providers.Only in those instances will we disclose relevant personal information to those providers.
We may also disclose your information to companies within the group so that products and services may be offered. Where we have obtained your approval to conduct credit checks, we may obtain personal information from or disclose personal information to credit reporting agencies.
You may request access to the personal information that we hold about you or request corrections to personal information that we hold. Subject to the limited circumstances set out below, we will endeavor to process your request in a reasonable time. In order for us to process your request we will need to verify your identity and, in some circumstances, we may need to charge an administrative fee, of which we will inform you in advance.
In the event that we refuse you access to your personal information, we will provide you with an explanation for that refusal. These reasons may include:
HOLT stores personal information in an encrypted database on our servers. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modification or disclosure.
We will collect some information from you when you visit the HOLT website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.
The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. We will record your email address if you send us an email.
HOLT explicitly reserves the right and may make changes to this Privacy Statement from time to time for any reason and will make concerted efforts to update the website in a timely manner.
If you would like more information about how we manage your personal information, please write us at email@example.com
Transacting with HOLT and usage of its platform is straightforward and we pledge to give you information that is relevant to you. At this point, our contract with you consists of our T’s & C’s, our Registration T’s & C’s and these General T’s & C’s. Please ensure you read them so you understand the terms of our agreement with you. If there’s any conﬂicting information, these General T’s & C’s take precedence.
These T’s & C’s detail the agreement between you and HOLT (‘we’/‘us’) when using our platform and applying for an account with us. By proceeding to use our website and/or platform and, whether you successfully open an account or not, you agree to these terms and conditions in their entirety.
Each condition of these T’s & C’s operates separately. If any court or competent authority decides that any of them are unlawful or unenforceable, the other unaffected terms and conditions will remain in full force and eﬀect.
Our accounts are designed to be accessed through the HOLT Platform and managed from your smartphone, tablet or computer. In some situations, you may need to do things by phone (e.g. accounts operated under a Power of Attorney).
You’ll sign up on wallet.holtfinancial.io. The platform will guide you and our support team is available 24/7 if you have any diﬃculties – you can get in touch via the Help button on the website.
Eligibility & Residence
To open a HOLT account you’ll need to be at least 18 years old and a resident of an approved jurisdiction. The HOLT Platform is a compliant transaction and financial tool and as such is only licensed and regulated to provide its services to residents in certain jurisdictions. We are continuously adding to the jurisdictions we can provide services to and if we are not yet licensed to operate in your jurisdiction we no doubt will be so very soon.
Once you’ve opened an account with HOLT, you must let us know if you intend to live outside your country of residence for any extended period of time (i.e. for a year or more). If your residence overseas will be for three years or less, you’ll be able to manage your account from outside your approved jurisdiction. If your residence overseas will be for more than three years, you will need to close your account. HOLT reserve the right to unilaterally close an account that in its sole estimation is in contravention our terms and conditions of use, including our compliance policies and procedures.
You won’t be able to manage your account from some countries and jurisdictions. If you have any questions, please check with us before you travel.
Our digital format goes a long way towards achieving full accessibility for all, but if you need these T’s & C’s supplied in another format, or if we can help you to use our service in any other way, simply contact us via the Help button, or email us at firstname.lastname@example.org.
Verifying Your Identity
When you apply to become a HOLT customer, we’ll ask you for some personal data so we’re able to verify your identity. The nature of this data will vary depending on the type of product you apply for, but will always include information like your full name, address, and date of birth.
To complete the identiﬁcation and veriﬁcation (‘ID&V’) process, we will run an electronic search with Worldcheck, and other international lists as well as a credit reference agency. There are times when we may ask you to complete ID&V again (e.g. to keep our records up to date, if you move residence).
When you apply for a HOLT account , we’ll ask you if you’re responsible for paying tax or reporting to tax authorities in a country other than your country of residence. This is so we can comply with our responsibilities under the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standards.
If you tell us about any tax responsibilities, or we believe you have any, we are obligated to provide speciﬁc information (your account number, account balance, interest earned, name and address details and tax identiﬁcation number) to the relevant authorities.
It’s your responsibility to tell us if your circumstances change, so if you become liable to pay tax or report to tax authorities in another country, please let us know straight away.
Protecting Your Data
We hold your personal data in a secure environment and use security measures to protect it from unauthorized access and ensure it is accurate and is used appropriately.
We treat the information you give us with the greatest respect and will never share it with anyone else for marketing purposes.
Examples of our use of your data are:
To complete these activities, we may need to share some or all of your data with our trusted partners, including fraud prevention, anti-money laundering and credit reference agencies (whose details we can share with you on request), law enforcement departments, regulators, government departments and the providers of our sales or servicing platforms.
Accessing Your Data
If you ever need to see details of any information we hold about you, you can submit a data subject access request by emailing email@example.com. We’ll act on your request as quickly as possible (within 30 days).
Keeping Us Informed
It’s important that we have your correct contact details at all times. So if you change your name, address, mobile number or email address, please let us know via the Help button.
If you don’t tell us that your details have changed we’ll continue to use the information we hold. We can’t be responsible if this results in conﬁdential information being misdirected. If we lose contact with you and have to try and ﬁnd you, we may charge you for any costs incurred, so please keep us up to date.
We’ll generally communicate with you through the platform and other digital channels wherever possible. There are times when regulation means we have to communicate with you in a speciﬁc way and in exceptional circumstances, we may contact you by post. We reserve the right to contact you via the postal address, telephone number or email addresses provided by you.
We’ll store important documents safely in your Vault so you can refer back to them at any time.
We won’t send you marketing communications unless you speciﬁcally permit us to.
Once you log onto the platform and accept the App T’s & C’s, you can browse information about our products. To open a HOLT account, you’ll need to register ‘Your ID’, complete the ID and verification process and meet our eligibility criteria.
When you open a HOLT account you’ll receive a sort code and account number which you can use to make electronic payments into it from other banks or building societies.
Most electronic transfers between banks and building societies are made by Faster Payments. Other ﬁnancial institutions may have diﬀerent limits, so you need to check with them to ensure they will follow your instructions to make payments into your HOLT account.
If a payment you have made from your account doesn’t complete correctly because of a bank error and we believe the error is genuine, we’ll refund you as soon as possible while we contact the other bank to recover the payment. If you think there’s been an error, you must tell us without undue delay.
If a payment you have made from your account doesn’t complete correctly because you made a mistake (e.g. you used the wrong account details) we won’t refund you, but we’ll make all reasonable eﬀorts to help recover the payment for you.
If someone else tells us they’ve accidentally made a payment into your account and we reasonably believe this has happened, we may stop any withdrawals being made from your account while we discuss next steps with you. If you agree there has been an error or you don’t respond by the deadline we give you, we will return the payment. Where the payment was made over two months earlier, we’ll always ask for your consent before returning it.
Operating your account
If you need someone else to operate your account, we may be able to register a Power of Attorney (POA) for you. If we do this, your Attorney, rather than you, will receive all of the information about your account.
At this time, we’re only able to register a POA if you’re an existing HOLT customer – i.e. if you have successfully registered Your ID, veriﬁed your identity and opened an account. For security reasons, POA administration of an account is managed via our customer support team so please email us at firstname.lastname@example.org to discuss setting up a POA for your account.
If you need any support to operate your account due to a temporary or permanent change in your circumstances, get in touch and we’ll do all we can to help.
Getting in touch
If you experience any technical diﬃculties with opening or operating the HOLT platform or your account, our customer support team is available to help 24/7.
If you need to tell us something or ask a question please contact us via the Help button or email us at email@example.com
Got a complaint?
Our aim is to get everything right the ﬁrst time, all of the time, but no one’s perfect.
If you’re unhappy with any aspect of our service or want to complain, you can tell us via the Help button or email us at firstname.lastname@example.org
Your Right to Cancel
Your right to cancel any arrangement you enter into with us will be based on the type of product you have. This is explained in detail in the specific product T’s & C’s.
Changes to these T’s & C’s
We operate in a dynamic and ever-changing regulatory environment and as such we reserve the right to change and/or amend these T’s & C’s. If we need to change these T’s & C’s, we’ll give you notice so you can consider the changes. In most cases you’ll be able to close an impacted account if you’re not happy.
We’ll generally make changes to these T’s & C’s:
Our Right to Terminate
We can end our agreement and close your account immediately if we reasonably believe you have:
Copyright & Trademarks
All of our designs, logos and materials are owned by or licensed to us and protected by copyright laws, including Holt Financial, Holt Digital Finance, Holt Marketplace and all related products and services.
HOLT does not accept responsibility or any liability for loss or damages that occur as a result of fraud or negligence by a party to this agreement or as a result of abnormal or unforeseen circumstances beyond our control, the consequences of which would have been unavoidable despite all eﬀorts to the contrary; and/or our compliance with any regulation or law in a jurisdiction of our operation or any applicable international law or convention.
Holt Digital Finance is a Cayman Island Exempted Company. These T’s & C’s are governed by the laws of the Cayman Islands and if there’s any disagreement about them, or between us about your account, we each agree that this will be dealt with by the Courts of the Cayman Islands.
Some cookies are needed to run the website. For example, when you log in, cookies help to recognize you and keep you logged in as you browse the website. We call these strictly necessary cookies. Cookies never store any of your banking details.
We also use the following types of cookies:
Analytical and performance cookies These allow us to recognize and count the number of visitors to our website, and see how visitors browse our site, so we can improve it where necessary.
Targeting cookies These allow us to see what pages and links you have visited so we can provide more relevant ads. We may share this information with other organizations for the same purpose.
Google Analytics cookies These identify and analyse website trends, but do not identify you individually.
These cookies are all “session cookies”, which means that they will end when you close your website browser.
You can turn cookies off if you prefer
Exactly how to do it depends on your browser settings. Try looking in your ‘Help’ section, or searching for ‘How to block cookies’.