Call Recording Notice

Hove Capital Limited ("we", "us", "our") records telephone calls made to and from our business. This notice explains why we record calls, how recordings are stored, your rights in relation to recorded calls, and how to contact us with any queries.

We are committed to transparency about our call recording practices and to ensuring compliance with all applicable legislation.

We record telephone calls for the following purposes:

• Regulatory compliance: As a company operating in the financial services sector, we are required to record certain calls under the rules set by the Financial Conduct Authority (FCA) and in accordance with MiFID II (Markets in Financial Instruments Directive) requirements. These regulations require firms to record telephone conversations that relate to, or may relate to, transactions in financial instruments.
• Quality assurance: To monitor and improve the quality of service we provide to our clients and partners.
• Training: To support the training and development of our staff, helping us maintain high standards of service.
• Dispute resolution: To provide an accurate record of communications in the event of a disagreement or complaint.
• Security: To help prevent and detect fraud, unauthorised access, or other security concerns.

Our call recording practices comply with the following legislation and regulatory requirements:

• UK GDPR (UK General Data Protection Regulation) and the Data Protection Act 2018
• FCA Handbook (SYSC 10A) — recording of telephone conversations and electronic communications
• MiFID II — requirements for recording communications relating to client orders and transactions
• Regulation of Investigatory Powers Act 2000 (RIPA) and the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000

The lawful basis for processing your personal data through call recording is our legitimate interest in regulatory compliance, quality assurance, and staff training (Article 6(1)(f) UK GDPR), and compliance with a legal obligation to which we are subject (Article 6(1)(c) UK GDPR).

The following information may be captured when calls are recorded:

• The audio content of the telephone conversation
• The date and time of the call
• The telephone numbers of both parties
• The duration of the call
• The name of the staff member involved in the call

All callers will be informed at the start of the call that the conversation is being recorded.

Call recordings are retained in accordance with our regulatory obligations:

• Regulatory calls (relating to financial transactions or orders): Retained for a minimum of 5 years, and up to 7 years where required by the FCA.
• Non-regulatory calls (general business calls): Retained for up to 12 months, unless required for ongoing business purposes or dispute resolution.

After the applicable retention period, recordings are securely deleted in accordance with our data retention policy.

Under the UK GDPR, you have the following rights in relation to your personal data contained in call recordings:

• Right of access: You can request a copy of any call recordings in which you are a participant.
• Right to rectification: Where factual inaccuracies arise from a recorded call, you can request that supplementary notes or corrections be added to the record.
• Right to erasure: You can request deletion of recordings, subject to our regulatory obligations. We may be unable to delete recordings that we are legally required to retain.
• Right to object: You have the right to object to the recording of calls. Please note that where recording is a regulatory requirement, we may be unable to continue the call without recording.

To exercise any of these rights, please contact our Data Protection Officer at [email protected].

Where call recording is not a regulatory requirement, you may request that a call is not recorded. In such cases, we will make reasonable efforts to accommodate your request.

However, where we are legally obligated to record calls (for example, calls relating to financial transactions under FCA rules), we are unable to offer an opt-out. If you do not wish to be recorded in such circumstances, we may be able to offer alternative communication methods such as email or written correspondence.

Please inform the staff member at the start of the call if you wish to discuss opting out of recording.

We take the security of call recordings seriously. Recordings are:

• Stored on secure, access-controlled systems
• Encrypted both in transit and at rest
• Accessible only to authorised personnel who require access for legitimate business purposes
• Subject to regular security reviews and audits

We implement appropriate technical and organisational measures to protect recordings against unauthorised access, loss, destruction, or damage.

If you have any questions about our call recording practices or wish to exercise your rights, please contact us:

• Data Protection Officer: [email protected]
• General enquiries: [email protected]
• Telephone: 01273 937117
• Address: Curtis House, 34 Third Avenue, Hove, BN3 2PD

Hove Capital Limited, registered in England, company number 13049782.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.