This policy explains how Horizons Community Limited (“Horizons”, “we”, “us”) collects, uses and protects personal information about our members, applicants, guests, speakers, partners and visitors to horizons.org. Horizons is a private membership network for next-generation family office principals and founders. Discretion matters to our members and to us, and we never sell personal information.

1. Who we are

Horizons Community Limited is a company registered in England and Wales (company number 10600381). Our office is at 33 Glasshouse Street, London W1B 5RT. We are the controller of the personal information described in this policy, and we are registered with the Information Commissioner’s Office (ICO).

If you have a question about this policy or your information, please contact  Victoria Imerelli, Chief Operating Officer, at victoria@horizons.org.

2. Who this policy covers

• Members and former members
• People who apply for membership, or who are referred or introduced to us
• Guests at our Gatherings, Forums and other events
• Speakers, hosts and partners, and the people we deal with at our suppliers
• People who contact us or subscribe to our updates
• Visitors to horizons.org

If you apply to work with us, we use your application only to assess it, and we keep it for six months after a decision.

3. What we collect

Information you give us

• Contact details: your name, email address, phone and WhatsApp numbers, postal address, and an assistant’s contact details if you give them to us.
• Application and profile: your date of birth, nationality and country of residence; your business or employer and your role; the source of your own or your family’s wealth and your family background; who referred you and which members you know; your interests; a short biography; and links to your LinkedIn or Instagram profiles.
• Membership and payments: your membership type and dates, invoices, how you pay and, where relevant, the company we invoice. Card and direct debit payments are handled by our payment providers, and we do not hold your full card details.
• Events: your bookings and attendance, dietary and access requirements, travel and hotel details for Forums and, where an official host requires it for security, identity details such as passport information.
• Communications: your emails and messages to us, and your survey responses and feedback.

Information we create or receive from others

• Notes from our conversations with you, and a record of the events you attend.
• An illustrated sketch of each member, which we use in invitations and in the member app.
• Information from the person who referred or introduced you, and from public sources such as company registers, LinkedIn and the press.
• The results of sanctions and politically exposed person (PEP) checks, which we carry out on members, guests and suppliers.

When you visit our website

Our website host keeps standard server logs, such as IP address and browser type, for security. horizons.org uses only essential cookies, and we do not use analytics or advertising cookies.

4. How we use your information

We use your information for the following purposes, each with a lawful basis under UK data protection law.

• To provide the membership, events, Forums and member app you have signed up for, and to take payments. Our lawful basis is the contract between us.
• To assess applications and referrals, keep in touch, suggest introductions and events that match your interests, improve what we offer and keep our systems secure. Our lawful basis is our legitimate interest in running a trusted, carefully curated network. We weigh this against your interests, and you can object at any time.
• To screen members, guests and suppliers against sanctions lists, identify politically exposed persons, and keep financial records. Our lawful bases are our legal obligations and our legitimate interests.
• To send our updates to people who are not members or former members, and to use photographs of you in our publicity. Our lawful basis is your consent, which you can withdraw at any time.

Dietary and access requirements can reveal information about your health or religion. We collect them only with your explicit consent and share them only with the venue or host that needs them.

We do not make decisions about you based solely on automated processing.

5. Who can see your information

• Other members. The member app includes a directory where members can see your name, city and country, biography, interests, work and social profiles. You choose whether your email address and phone number are shown. Your date of birth and postal address are never shown to other members.
• Fellow attendees. People attending an event or Forum may receive a list of attendees and short profiles, for example in a Forum agenda pack.
• Venues, hosts and speakers. We share guest lists, short profiles and dietary requirements so that they can host you. For official visits, hosts such as embassies or government offices may need identity details for security clearance. When we arrange speakers, hosts and access for the membership, we may also share a short, confidential summary of members’ backgrounds, with a director’s approval.
• Member benefit partners. Partners may ask us to confirm that you are a member, and we may give some partners a list of member names so that they can apply member benefits. Partners may not use this information for their own marketing.
• Service providers who work for us. These include our CRM, our events and email platform, our application form and survey tools, our payment and accounting providers, our cloud storage and communication tools, our illustrator and the developer of our member app. They act only on our instructions.
• Professional advisers and authorities. We share information with our accountants and lawyers where needed, and with authorities or regulators where the law requires it.

We never sell your information.

6. International transfers

Some of our service providers store information outside the UK, mainly in the EU and the US. Where they do, we rely on UK adequacy regulations or on contract terms approved by the ICO.

When you join a Forum abroad, we share the details needed to run it, such as your name, short profile, dietary requirements and, for official visits, identity details, with hosts, venues and officials in that country. Some of these countries do not have data protection laws equivalent to the UK’s. We do this because it is necessary to deliver the Forum you have booked, we share only what is needed, and we will tell you before we do.

7. How long we keep your information

• Member records and invoices: for the length of your membership and six years after it ends, for accounting and legal reasons.
• Your member app profile: removed when your membership ends.
• Former members: we keep your contact details so that we can stay in touch, until you ask us to stop or after two years without engagement.
• Applications and introductions that do not go ahead: two years from the decision or our last contact.
• Sanctions and PEP screening records: six years after the membership or relationship ends.
• Event bookings: two years after the event. Dietary and access requirements are deleted sooner, once they are no longer needed.
• Enquiries and correspondence: two years from our last contact.

8. Your rights

You have the right to:

• ask for a copy of the personal information we hold about you;
• ask us to correct information that is wrong or incomplete;
• ask us to delete your information, or to restrict how we use it;
• object to our use of your information based on legitimate interests, and object at any time to direct marketing;
• ask for information you gave us in a portable format; and
• withdraw your consent at any time, where we rely on it.

To make a request, email victoria@horizons.org. There is no charge, and we will reply within one month. We may need to confirm your identity first.

If you are unhappy with how we have handled your information, please tell us so that we can put it right. You can also complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

9. How we protect your information

We keep personal information in approved cloud services, with individual accounts protected by 2-step verification. Access to sensitive records is limited to the people who need it, and everyone on our team reads our data protection policy when they join.

10. Cookies

horizons.org uses only the cookies that are strictly necessary for the site to work. These do not need your consent, so you will not see a cookie banner. If we ever add other cookies, such as analytics, we will ask for your consent first.

11. Changes to this policy

We review this policy at least once a year. If we make significant changes, we will update this page and let members know.

Horizons Community Limited, registered in England and Wales, company number 10600381. 33 Glasshouse Street, London W1B 5RT.