Call Recording Notice

Hove Capital Limited ("we", "us", "our") records telephone calls placed to and from our business. This notice sets out why we record calls, how those recordings are kept, the rights you have in relation to recorded calls, and how to reach us with any questions.

We are committed to being transparent about our call recording practices and to complying with every piece of applicable legislation.

The reasons we record telephone calls are as follows:

• Regulatory compliance: Because we operate in the financial services sector, we are obliged to record certain calls under the rules laid down by the Financial Conduct Authority (FCA) and in line with MiFID II (Markets in Financial Instruments Directive) requirements. Those rules require firms to record telephone conversations that relate, or may relate, to transactions in financial instruments.
• Quality assurance: To track and enhance the quality of the service we give to our clients and partners.
• Training: To assist the training and development of our staff, which helps us keep our service standards high.
• Dispute resolution: To provide an accurate record of communications should a disagreement or complaint arise.
• Security: To help prevent and identify fraud, unauthorised access, and other security concerns.

Our approach to call recording complies with the legislation and regulatory requirements listed below:

• 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 — obligations around recording communications that relate to client orders and transactions
• Regulation of Investigatory Powers Act 2000 (RIPA) together with the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000

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

When a call is recorded, the following information may be captured:

• The audio of the telephone conversation
• The date and time the call took place
• The telephone numbers of each party
• How long the call lasted
• The name of the staff member taking part in the call

Every caller will be told at the start of the call that the conversation is being recorded.

Call recordings are kept in line with our regulatory obligations:

• Regulatory calls (those relating to financial transactions or orders): Kept for a minimum of 5 years, and up to 7 years where the FCA requires it.
• Non-regulatory calls (general business calls): Kept for up to 12 months, unless needed for ongoing business purposes or to resolve a dispute.

Once the relevant retention period has passed, recordings are securely destroyed in accordance with our data retention policy.

The UK GDPR gives you the following rights in respect of your personal data held within call recordings:

• Right of access: You may request a copy of any call recording in which you are a participant.
• Right to rectification: If a recorded call contains factual inaccuracies, you may request that supplementary notes or corrections are added to the record.
• Right to erasure: You may request that recordings be deleted, subject to our regulatory obligations. We may be unable to remove recordings that we are legally required to retain.
• Right to object: You may object to the recording of calls. Where recording is a regulatory requirement, please be aware that we may be unable to proceed with the call without recording it.

To exercise any of these rights, please reach out to our Data Protection Officer at dpo@hove.capital.

If recording is not a regulatory requirement for a particular call, you are welcome to ask that the call is not recorded. We will take reasonable steps to accommodate such a request.

Where we are legally obliged to record calls (for instance, calls concerning financial transactions under FCA rules), no opt-out can be provided. If you would prefer not to be recorded in those situations, we may be able to offer alternative channels of communication such as email or written correspondence.

If you would like to discuss opting out of recording, please let the staff member know at the start of the call.

The security of call recordings is something we take seriously. Recordings are:

• Held on secure, access-controlled systems
• Encrypted both while in transit and while at rest
• Available only to authorised personnel who need access for legitimate business purposes
• Reviewed and audited for security on a regular basis

Appropriate technical and organisational measures are in place to safeguard recordings against unauthorised access, loss, destruction, or damage.

Should you have any queries about our call recording practices, or if you would like to exercise your rights, please get in touch:

• Data Protection Officer: dpo@hove.capital
• General enquiries: contact@hove.capital
• Telephone: 01273 937117
• Address: Curtis House, 34 Third Avenue, Hove, BN3 2PD

Hove Capital Limited is registered in England under company number 13049782.

You may also make a complaint to the Information Commissioner's Office (ICO) at ico.org.uk.