1. Introduction

1.1 This Marketing Communications Policy (“Policy”) explains how HY10 Global Limited, a company registered in England and Wales with registered office at 16-17 Portland Street, London, England, W1W 8BP, authorised and regulated by the Financial Conduct Authority under the Electronic Money Regulations 2011 (Firm Reference Number 1004355) (“HY10”, “we”, “us”, “our”), communicates with its customers and prospective customers for marketing purposes.

1.2 Certain lifestyle and concierge services referenced in our marketing are provided by Orbital Mobile Limited, trading as HY10 Lifestyle (“HY10 Lifestyle”), a separate legal entity which is not authorised or regulated by the Financial Conduct Authority. Where HY10 Lifestyle sends its own marketing communications, it does so as a separate data controller under its own privacy notice, and this Policy applies to it only to the extent expressly stated.

1.3 This Policy should be read together with our Privacy Policy, Terms of Use, and Cookie Policy, each available at hy10.uk. In the event of any inconsistency between this Policy and our Privacy Policy in respect of the processing of personal data, the Privacy Policy shall prevail.

2. Definitions

2.1 “Marketing Communications” means any communication intended to promote HY10’s or HY10 Lifestyle’s products, services, brand, or events, sent by email, SMS, push notification, in-app message, telephone, post, or via targeted advertising on third-party platforms. It excludes Service Communications.

2.2 “Service Communications” means communications we are required or entitled to send you in connection with the operation, security, or administration of your account, or to comply with a legal or regulatory obligation, including but not limited to statements, security alerts, and notices of changes to your Agreement with us. Service Communications are not Marketing Communications and you cannot opt out of them while you hold an account with us.

2.3 “You” means an existing customer, prospective customer, or website visitor of HY10, as the context requires.

3. Legal basis for processing

3.1 Where we are required by the Privacy and Electronic Communications Regulations 2003 to obtain your consent before sending Marketing Communications by electronic means (email or SMS) to an individual, we will only do so where you have given your prior, freely given, specific, and informed consent, or where a narrow soft opt-in exemption applies in respect of similar products or services to existing customers who have not opted out.

3.2 In all other cases, we process your personal data for the purpose of sending Marketing Communications on the basis of our legitimate interests under Article 6(1)(f) UK GDPR in promoting our business to existing and prospective customers, having balanced that interest against your rights and freedoms, including your right to object at any time.

3.3 We do not make any decision that produces a legal or similarly significant effect on you based solely on automated processing of your data for marketing purposes.

4. Channels

We may send Marketing Communications via the following channels, where you have not opted out and, where required, have consented:

• Email
• SMS
• Push notifications and in-app messaging
• Telephone
• Post
• Targeted or retargeted advertising on social media and third-party platforms

4.2 Where we use information about your interactions with our website or Services to display relevant advertisements on third-party platforms, this is subject to your cookie and advertising preferences, as set out in our Cookie Policy.

5. Personalisation and profiling

5.1 We may use information relating to your account activity, products and services used, interactions with previous communications, and stated preferences to determine which Marketing Communications are likely to be relevant to you.

5.2 You may object to this profiling at any time without affecting your ability to receive non-personalised Marketing Communications, and without affecting the operation of your account.

6. Sharing your data with third parties

6.1 We will not disclose your personal data to any third party outside the HY10 group of companies for that third party’s own marketing purposes without first obtaining your express opt-in consent.

6.2 HY10 and HY10 Lifestyle may share limited personal data between them (such as name and contact details) strictly where necessary to fulfil a joint product or offer you have requested. Each entity’s marketing preferences are otherwise managed and recorded separately.

6.3 We may engage third-party service providers (for example, email delivery platforms or CRM providers) to send Marketing Communications on our behalf, acting as processors under our instruction and subject to appropriate data processing agreements.

6.4 We may send you information about offers, benefits, or events from selected HY10 partners where these form part of your HY10 membership or we believe they may be relevant to you. Unless you have separately consented, we do not provide your personal data to those partners for their own marketing purposes.

7. Your rights

You have the right to:

• Withdraw consent to Marketing Communications at any time, free of charge
• Object to processing of your data for direct marketing purposes, including profiling to the extent it relates to direct marketing
• Request access to, correction of, or erasure of your personal data, subject to applicable law
• Lodge a complaint with the Information Commissioner’s Office

You may exercise these rights by using the unsubscribe link in any Marketing Communication, updating your preferences in your account, or contacting Customer Services using the details in our Privacy Policy.

8. How to opt out

8.1 You can opt out of some or all channels of Marketing Communications at any time, without affecting Service Communications, by: (a) selecting the unsubscribe or preference link in any Marketing Communication; (b) amending your communication preferences within your account; or (c) contacting Customer Services directly.

8.2 We will action opt-out requests as soon as reasonably practicable and, where legally required, without undue delay.

9. Retention

We retain records of your marketing preferences and consents for as long as your account remains open and for a reasonable period thereafter, to enable us to demonstrate compliance with applicable law and to honour any opt-out you have given us.

10. Preference Centre

10.1 You can choose which types of Marketing Communications you wish to receive, for example product updates, lifestyle experiences, events, or partner offers, through your communication preference centre in your account settings.

11. Types of Marketing Communications

11.1 Marketing Communications may include invitations to HY10 events, partner events, member experiences, product launches, and educational content, in addition to the communications described elsewhere in this Policy.

12. Eligibility

Our Services and Marketing Communications are directed exclusively at individuals who meet HY10’s eligibility and onboarding criteria. We do not knowingly collect data for marketing purposes from, or direct Marketing Communications at, any individual who does not meet those criteria.

13. Changes to this Policy

We may amend this Policy from time to time to reflect changes in law, regulation, or our business practices. Material changes will be notified to you in advance in accordance with your Agreement with us. The version published on hy10.uk is the version in force.

14. Governing law and complaints

14.1 This Policy is governed by the laws of England and Wales.

14.2 If you have a concern about how we handle your data for marketing purposes, please contact us in the first instance. Complaints relating to HY10 Global’s regulated activities may also be referred to the Financial Ombudsman Service. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), although we encourage you to contact us first so that we can try to resolve your concerns.