Privacy policy - Harbour Litigation Funding

Harbour values your Privacy and is committed to protecting your Personal Data.

This Privacy Notice sets out how we collect and use your personal data in line with the UK General Data Protection Regulation and the Data Protection Act 2018 (the “Data Protection Laws”), your rights and how the law protects you.

This Notice covers Processing related to the initial stages of our engagement with you as a potential party to one of the Harbour Group products, prior to the formation of any contractual relationship. Once a contract is created between you and the relevant Legal Entity of the Harbour Group, you will be receiving other Fair Processing Notices.

It also covers processing of personal data if you are a visitor to our website, attend one of our events, send us general queries or correspondence, or are a supplier or employee of a supplier to Harbour and visitors to our premises.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We may update our Privacy Notice from time to time. This version was last updated on 7 March 2025.

1. Who we are and important information

Controller and contact details

The Data Controller for the purposes of this Privacy Notice is Harbour Litigation Funding Limited (“Harbour“, “the Company“, “we“, “us” or “our“).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice on behalf of Harbour. If you have any questions about this Privacy Notice, including any requests to exercise your data privacy rights, please contact the data privacy manager using the details below.

Full name of legal entity: Harbour Litigation Funding Ltd

Email address: info@harbourlf.com

Postal address: 4^th Floor, 8 Waterloo Place, London, SW1Y 4BE, United Kingdom.

Links to other websites

Our website may contain links to other websites of interest, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these other websites and cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. Such sites are not governed by this Privacy Notice. We recommend you exercise caution and read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information relating to an identified or identifiable individual (a “data subject“). It does not include data that relates to an individual who cannot be identified (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data including name, job title, date of birth, country of birth, domicile, nationality, photograph and passport number
Contact Data including postal address (this may be your home address if you have provided this to us), email address and telephone number, which we may obtain from publicly available sources such as your organisation’s website
Personalisation Data including your interests, preferences and feedback
Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
Usage Data including how you use and interact with our website
Visitor Data including meetings with our employees and visits to our premises
Marketing and Communications Data including your preferences in receiving marketing from us and your communications preferences

In addition, we may need to process special category personal data. Special category data, such as data relating to disabilities or other healthcare data, may be processed if you register to attend an event or similar and where we need to make reasonable adjustments to accommodate you at such events or on our premises. This may include information about your health for the purpose of identifying and being considerate of any disabilities or dietary requirements.

We may also collect and use aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

If you fail to provide personal data

Where we need to collect your personal data by law, or for the purpose of entering into a contract with you, and you fail to provide that data when requested, we may not be able to go ahead with our engagement. In this case, we may have to cease our discussions with you, but we will notify you if this is the case at the time.

How do I update my personal data?

It is important that the personal data we hold about you is accurate and current. If any of the personal data that you have provided to us changes, such as your email address, or if you become aware that we have any inaccurate personal data about you, please contact us at info@harbourlf.com.

3. How is your personal data collected?

We may collect personal data about you in a number of circumstances, including through:

Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- seek to invest into one of the Harbour Funds
- browse, make an enquiry or otherwise interact on our website
- attend a seminar
- sign up to receive information from us
- offer to provide or provide services to us

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources: In some circumstances, we may collect personal data about you from a third party source. For example, we may collect Identity, Contact, Publicly Available and Legal Data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from publicly available records.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Entering into a contract: where at your request we need to take steps to enter into a contract with you.
Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legal duty: where we need to comply with a legal obligation.

Where we use personal data for our “legitimate interests“, we have determined, acting reasonably and considering the circumstances, that our legitimate interests are not overridden by your interests, rights, and freedoms, because: (a) we process your information only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your information in this way.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. We have identified the legal bases we rely upon for each purpose of processing in the table below.

Purposes for which we will use your personal data

We have set out below a list of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may rely on more than one legal basis for a particular activity depending on the specific use of your data. We often rely on legitimate interests where we use data in a manner that is complementary to but not necessary for performing a contract or a legal duty. Please contact us if you need more information about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose	Lawful basis	Legitimate interests
Providing our services
Based on your investment needs, to put you in contact with the relevant legal entity of the Harbour Group To provide other services requested by you or your organisation	Legitimate interest Legitimate interest	Developing our relationship with you Developing our relationship with you and managing any further needs you may have
Finance
Transactions with suppliers Other transactions with related parties, such as ATE insurance providers, experts, solicitors, investment advisors and entities that own funds we advise.	Legitimate interest Legitimate Interest	To communicate with the supplier regarding transactions, validate ID and settle payments To communicate with the related party regarding transactions and fulfil a business purpose e.g. recharging shared services, providing advisory services.
Providing you with a better service
To improve our services and communications Conducting Customer surveys Responding to complaints and queries you submit to us	Responding to complaints and queries you submit to us All other situations – legitimate interest Legitimate interest Where we are fulfilling our requirements for FCA regulation – Legal duty All other situations – legitimate interest	Ensuring that we provide the best possible service Developing and improving our products and services Developing future business initiatives Ensuring that any complaints or enquires that you have are resolved quickly and efficiently
Business management
Purchaser and supplier administration Aggregating data such that it cannot be used to identify you for a number of purposes such as statistical analysis and providing an understanding of user engagement with various features on our website	Legitimate interest Legitimate interest	For the purposes of day-to-day purchaser and supplier administration Understanding how our clients interact with our business and services
Complying with our regulatory and legal obligations
To comply with our legal and regulatory obligations and requests, in the UK and elsewhere in the world, including reporting to and/or being audited by national and international regulatory bodies To comply with requests from law enforcement, court orders and exercises and/or defend our legal rights	Legal duty Legal duty
Security
To protect the security of and managing access to our IT and communication systems, online platforms, websites, offices and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities	Where we are complying with our regulatory obligations – Legal duty All other situations -Legitimate interest	Ensuring the security of all data held by us
Marketing & Events
To promote our products and services to you Keeping you up to date on the latest news, announcements, events and other information which we feel would be of interest to you Collecting information about you to personalise our communication and interaction with you (for example, by way of newsletter tracking or website analytics) Organising and hosting events	Legitimate interest Where we use tracking technologies – Consent Where we do not use tracking technologies – Legitimate interest Legitimate interest	Contacting you to promote our services and opportunities that you may be interested in Improving the effectiveness of our communications Developing our relationship with you and promoting our services to you

Purpose	Legal basis	Legitimate interests	Condition for processing special category data
Processing special categories of personal data and/or criminal offences data
To identify and be considerate of any disabilities or special dietary requirements you may have when attending an event or seminar To comply with our regulatory and legal obligations, particularly our screening or identity verification obligations	Legitimate interest Legitimate interest	Our legitimate interest in ensuring you are appropriately and safely catered for at HLF events N/A	Your explicit consent when you provide us with this information The processing is necessary to comply with our regulatory requirements and in the substantial public interest, relating to unlawful acts and dishonesty under Paragraph 12 of Schedule 1 to the Data Protection Act 2018

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, obtained investment from us, referred potential claimants to us or otherwise provided us with your details and, in each case, you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at info@harbourlf.com or by clicking the ‘unsubscribe’ link on all electronic marketing communications.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for a different purpose.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@harbourlf.com.

5. Who we share your personal data with

We may share your personal data with:

other Harbour entities who are based in the United Kingdom, British Virgin Islands, Cayman Islands, Germany and the United States on a confidential basis where required for the purpose of administration, billing and other business purposes
external professional advisers on a need to know basis including lawyers, consultants, bankers, insurers, auditors and other experts based in the United Kingdom, British Virgin Islands, Cayman Islands, Germany, the United States, Australia, Bermuda, Brazil, Canada, Hong Kong, Isle of Man, Jersey, New Zealand, St Kitts & Nevis, the Netherlands. (“Countries of Operation“) who provide consultancy, banking, legal, insurance, accounting and other services
courts, law enforcement authorities, regulators or attorneys or other parties based in our Countries of Operation who require reporting of processing activities in certain circumstances
external service providers in our Countries of Operation who provide IT, system administration, PR, property management, hospitality and marketing services and who Harbour have instructed to process personal data on our behalf and in accordance with our instructions only.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you provide personal data to us about someone else (such as one of your directors or employees, someone with whom you have business dealings or a party to legal proceedings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice.

6. International transfers

Harbour Litigation Funding Limited is part of the Harbour Group, therefore, we can share your personal data with the entities within Group. This will involve transferring your data outside of the United Kingdom or the European Economic Area (EEA). Where we make such transfers, we will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the Data Protection Laws or other relevant laws, such as ensuring service providers use specific contracts approved by the UK Secretary of State or the European Commission which give personal data the same protection it has in Europe.

The table below identifies the basis on which these transfers are made in accordance with the Data Protection Laws Where the basis column refers to adequacy, this means that the UK Secretary of State has assessed the laws of that jurisdiction and considers that they provide an ‘adequate’ level of data protection and personal data may be transferred to such countries without putting in place any additional safeguards. Where we send data to a jurisdiction which does not enjoy an adequacy decision from the UK Secretary of State, we will implement the ‘standard contractual clauses’, a set of standard form agreements issued by UK Secretary of State that governs the transfer to ensure the data is sufficiently secured while in that country. We will also, where appropriate, carry out a risk assessment of the laws and practices of the destination country to identify any further technical and organisational measures that need to be put in place to ensure that your personal data is fully protected when in that country.

We typically and regularly share data with entities in the following countries:

Country	Basis of transfer
Australia Bermuda Brazil British Virgin Islands Canada Cayman Islands Germany Hong Kong Isle of Man Ireland Jersey New Zealand St Kitts & Nevis The Netherlands The United States	Standard contractual clauses Standard contractual clauses Standard contractual clauses Standard contractual clauses Adequacy Standard contractual clauses Adequacy Standard contractual clauses Adequacy Adequacy Adequacy Adequacy Standard contractual clauses Adequacy Standard contractual clauses

Given the global nature of our business, it is possible that we will occasionally share data with entities in other countries not listed here. In such cases, we will do so lawfully and in line with the Data Protection Laws to ensure your data enjoys the same level of protection as it would be subject to in the UK or EEA.

Please contact us at info@harbourlf.com if you want further information on the specific mechanism used by us while transferring your personal data out of the UK or EEA.

7. Data security

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

Please contact us should you require any further information about the specific length of time that we retain your personal data for.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you to be corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully objected to the processing of your data, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data if:
- you want us to establish the data’s accuracy;
- use of the data is unlawful but you do not want us to erase it;
- you need us to hold the data although we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to do any of the above please contact us at info@harbourlf.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113 – ICO website: https://www.ico.org.uk

We would, however, like to address your concerns before you approach the ICO so please contact us in the first instance.