Privacy policy

Hornbuckle, which is a trading name of Embark Services Limited, will collect personal information about you such as your name and address (“Personal Data”). Embark Services Limited will be the Data Controller as defined under UK Data Protection legislation and regulations.

We will only process your personal data where we have a legal basis for doing so. This includes:

  • Where you have provided positive consent to the company
  • Processing is necessary for the performance of a contract between you and the firm or to take steps to enter into a contract;
  • Processing is necessary for compliance with a legal or regulatory obligation
  • The company has a legitimate interest upon which the data may be processed. Any decision to process data on the basis of legitimate interest will be made on a case by case basis and in line with the guidance set out in UK Data Protection legislation.

We may disclose your Personal Data to other companies within the Embark Group of companies and third parties which provide services in connection with the administration of your account.

We may also share your Personal Information for legitimate business reasons or as may be required by applicable law and regulations with your Financial Adviser, third parties appointed by your Financial Adviser, third party investment managers, and product providers with whom you or your Financial Adviser instructs us to invest.

We may disclose your Personal Information to a credit reference agency in order to verify your details both during the application process and the ongoing administration of your account. This information will be used to prevent fraud and money laundering and to check your identity. Any checks performed may be recorded on your credit history.

We will disclose your Personal Information to any governmental, legal or regulatory body if required to do so by applicable law and regulation.

We may need to disclose sensitive Personal Data about you to third parties, such as information relating to your health where required to do so to give effect to an instruction from you or your Financial Adviser in respect of your account.

We may need to transfer your Personal Data to another country, in which case we will ensure that your Personal Data is afforded the same level of protection as is required under UK Data Protection legislation and regulations prior to sending your Personal Data.

We will otherwise keep your personal information confidential and never use it for any other purpose or pass your details to any third parties without your consent.

We will retain your Personal Data for no longer than is necessary to provide the services under the Terms and Conditions applicable to the account and to meet any legal or regulatory obligations that may apply.

You have a number of rights under the Data Protection laws, including:

  1. the right to request a copy of the personal information we hold on you. When you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee;
  2. the right to have personal information we hold about you transferred securely to another service provider in electronic form;
  3. the right to have any inaccurate personal information corrected;
  4. the right to have any out of date personal information deleted once there’s no business need or legal requirement for us to hold it;
  5. the right to object or restrict some processing, in limited circumstances and only when we don’t have legitimate grounds for processing your personal information;
  6. the right to object to your personal information being used to send you marketing material. We will only send you marketing material where you’ve given us your consent to do so. You can remove your consent at any time.

If you have any questions regarding how the firm uses the data it collects please contact:

The Group Data Protection officer
The Embark Group
100 Cannon Street

If you are not satisfied with any aspect of how we have managed your data you have the right to complain to the Information Commissioners Office. For further details of your rights under the UK’s data protection legislation and regulation please contact the Information Commissioner’s Office at

By signing the application form, you consent to the use of your Personal Information for the purposes and on the terms set out above. You have the right to withdraw consent at any time.

Terms of use

  • Hornbuckle does not provide investment advice. We only accept clients through a professional or financial adviser who can help them decide whether our products are right for them. Financial Advisers can be found through the FCA Register at
  • Your use of this website indicates that you accept these Terms of Use.
  • The website is provided by Embark Services Limited and any reference in this notice to ‘we’, ‘our’ or ‘us’ means Embark Services Limited.
  • We make no warranty that the website will meet your requirements.
  • The information provided is for general guidance only and nothing on these web pages constitutes financial, investment, tax or other professional advice.
  • In the event that our website contains links to other websites not operated by us, these are provided for your convenience only.  We have no control over, and accept no responsibility for, these other websites or their content, availability or functionality.  We accept no responsibility for any loss or damage which may arise from your use of (or inability to use) such other websites or their contents.

Legal and regulatory status

Embark Services Limited and Hornbuckle Mitchell Trustees Limited are wholly owned subsidiaries of Embark Group Limited.

Embark Services Limited is authorised and regulated by the Financial Conduct Authority, under FCA firm reference number 120820.
Embark Group Limited
Registered number – 03578067
VAT number – GB399632690

Embark Services Limited
Registered number – 02089815
VAT number – GB399632690

Hornbuckle Mitchell Trustees Limited
Registered number – 02741578
VAT number – Not applicable


These terms are governed by the law of England and Wales and any disputes will be subject to the exclusive jurisdiction of the Courts of England and Wales.


All contracts will be provided to you and concluded in English and all communications between us will be in English.


The products and services referred to in this website may have tax consequences for which independent professional advice should be sought.

Any reference to taxation in this website is based on our interpretation of current UK tax law and practice, which may change in the future.


Other than where required by law, we provide no warranty as to the quality or fitness for purpose of the website or that it is free of errors, viruses or bugs.  In addition we make no representation or warranties about the accuracy or the information contained on this website.  Any errors should be reported to us immediately. We have taken reasonable care to ensure that the information provided by this site is accurate at the time of publication; however, no representation or warranty, express or implied, as to the reliability, accuracy or completeness of such information is given.

To the extent permitted by law, we shall have no liability for any direct, indirect or consequential loss or damage (whatsoever or howsoever caused) suffered by you or your client arising out of or in connection with:

  • The use of this website.
  • Any delay or inability to access or use of this site.
  • Any change to this site.
  • Any suspension, restriction or withdrawal of this site.
  • The results of the use of this site.
  • The use of, or reliance upon, the information provided through this site.

including, without limitation, any loss of profits, revenue, business, goodwill or business opportunity, or any loss of data or damage to computer systems, whether in an action for breach of contract, in negligence or any other tort, under statute or otherwise.

Nothing in these Terms of Use shall exclude or restrict our liability for fraud, or for death or personal injury caused by our negligence, or any liability imposed under the provisions of the Financial Services and Market Act 2000, or any other liability which may not lawfully be excluded or limited.

You hereby agree to indemnify us and keep us fully and effectively indemnified on demand in respect of any losses, claims, liabilities, costs, damages or expenses (including legal costs and expenses) incurred or suffered by or brought against us as a result of your use or misuse of this website or any wilful default or fraud by you or any breach by you of any of the provisions of these Terms of Use.  This obligation shall survive any termination of these Terms of Use.

Web security

It is your responsibility to ensure that this website is not misused and that your computer is virus protected.


We will use reasonable endeavours to ensure that the website is available 24 hours a day 365 days a year subject to system maintenance and upgrades, but we are under no obligation to provide access to this site during those hours.  You acknowledge that the internet is not a totally reliable medium of communication and that our website may become unavailable for reasons outside of our control.  We shall have no liability to you or your client for any delay or failure to provide access to this site (or any part thereof). You acknowledge that your computer may not be fully compatible with this site and that your browser may not be supported by the Website.  In such case, the Website (or some parts or features thereof) may not display or function properly.

Intellectual property rights

The contents and material on this website belong to us and may only be downloaded for the purposes intended. You should not reproduce or distribute the contents for private or other business use without our consent.


We take all complaints seriously and will investigate any issue raised by you in relation to your own experience with us or on behalf of your client. When dealing with complaints we have a specific complaints procedure we follow in order to ensure consistency.

Risk warnings

We will assess only whether an investment can be held by a SIPP/SSAS under current HMRC tax guidelines and legislation. However, we are not responsible for the performance of the investment or service provided by the investment manager. The value of investments held within a pension scheme can fall as well as rise and clients might get back less than invested, including the loss of all funds invested. Past performance is not an indicator of future results.

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