Privacy Policy


Xinfu Ltd and any of its holding companies or subsidiary companies (“we”/“us”/“our”/“Xinfu”), including but not limited to Xinfu Australia PTY Ltd, is committed to protecting and respecting your privacy in line with current legislation. This Privacy Statement is relevant to anyone who is using and product and/or service of Xinfu. It tells you what personal data is collected and what we do with that personal data.

We recommend that you print a copy of this Privacy Statement for future reference.

You should read this Privacy Statement together with our User Terms (available further up this page) carefully before using our site, products and/or services, as by using our site, products and/or services you are confirming that you accept this Privacy Statement and these User Terms and that you will comply with them. If you do not agree with anything within this Privacy Statement or these User Terms you should leave our site immediately.

About us

Xinfu is a company registered in England and Wales under company number 06803140. Our registered office address is: 40 Bloomsbury Way Lower Ground Floor London WC1A 2SE.

Our main trading address is: 8 St James Square, London SW1Y 4JU United Kingdom.

Our VAT number is: 947796060.

Xinfu is registered with the Information Commissioner's Office, registration number Z1667546


In the provision of the Xinfu service, Personal Data will be collected and used.

Personal Data means data which relates to a individual living or dead who can be identified from the data, or from the data and any other information which is in the possession of, or likely to come into the possession of, the data controller.

Sensitive Personal Data means Personal Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.

We will also refer to the Data Processor and the Data Controller.

The Data Processor means an organisation or person who processes data on behalf of, and under instruction of, the Data Controller.

The Data Controller means an organisation or person who determines the purposes for which and the manner in which any personal data are or are to be processed.

The Data Processor means any organisation or person who processes the data on behalf of the Data Controller.

Who we share your data with and why

Xinfu provides products and services that are run with our third party service providers to provide the overall service. These companies will, as necessary, process your data in order for us to fulfil the product and/or service you purchase. The Data Controller is Xinfu Limited.

How do we provide our products and services with others

This section explains the purposes to which we put your Personal Data and explains the legal basis and legitimate interests we rely upon when we do so.

“Legitimate Interests” refers to our interests in conducting and managing our business. The particular interest which we are relying on in each case is explained in more detail below. When we use your data in our legitimate interests, we make sure to balance any potential impact on you and your rights under data protection laws. Our interests do not automatically override your interests.

We will never share the Personal Data or Sensitive Personal Data with any other parties except for the purposes of fulfilling our delivery of a product or service and for the purposes of data aggregation or research.

  • To provide the Xinfu service

What Data we use: Name, Email, Date of Birth, Address, Telephone Number

How We will use Data: We will use your Personal Data to provide the service, including to manage our relationship with you, to verify your identity and eligibility to use our service and/or to contact you to provide and administer our service. Without this information, we cannot provide the Xinfu service.

  • To improve the Xinfu Service

What Data we use: Name, Email, Date of Birth, Address, Telephone Number

How we will use Data: We may use contact you for your feedback or use your information to improve the Xinfu service by creating pseudonymised reports and by contacting you to receive feedback. We can use your data in this way because we have a legitimate interest in improving and tailoring our service and keeping our customers happy.

> To communicate with our clients

What Data we use: Names, Email address

How We will use Data: We may use this data to contact the client for administrative purposes such as addressing IP infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data stored by us, or with updates on promotions and events relating to the products and services offered by us and by the third parties we work with.

> To do what we are required to do by law

What Data we use: Name, Email, Date of Birth, Address, Telephone Number

How We will use Data: We may be required to retain or use your data if we have a legal duty or obligation to do so. This may be in the context of an employer and retaining certain employee data for a certain period of time, or it may be in the context of providing law enforcement agencies with data to aid with legal proceedings.

 > To recruit and/or employ individuals

What Data we use: Name, Email, Address, Phone Number, CV, References, Date of birth, NI Number

How We will use Data: We may use your Data to recruit and/or employ individuals. This is required in order to fulfil contractual obligations such as payroll, processing tax, proving eligibility to work and being ‘fit and proper’ for the role the individual is being engaged in.


We may only keep your personal data for as long as it is required for one of the reasons detailed in the above section.

How long we keep the data is determined by the period we need to keep it for in line with fulfilling the service and our legal obligations.

We typically retain personal data for approximately 7 years from the point the data is no longer used however in some cases, such as legal requirements, we may be required to keep it longer.

When data is no longer required for its purpose, we ensure data is securely and irrevocably deleted from our system. 


We rely on consent and lawful basis for processing in order to fulfill the products and services we offer and also so we can contact you directly about the status of your product/service.

You can ask us to stop using your Data at any time, however in doing so we will be unable to continue providing the service.

In order to request that we stop using your data, you can send us an email to stating that you wish for us to stop using your data immediately.


It is entirely optional to provide consent for us to collect and process your data, however where you do not provide the Data we need in order to provide the requested Xinfu service or to fulfil a legal requirement, we will not be able to fulfil the service requested.


You may contact us at any time via email or post to query anything that may have come up from reading this statement.

Address: Xinfu UK Ltd, Att: Operations, The Clubhouse 8 St James Square, London SW1Y 4JU



We can be contacted at the addresses above for one or more of the following reasons:

  1. To ask Us to fix Personal Data about You that is wrong or incomplete, or delete Personal Data about You.

  2. To tell Us that You no longer consent to Us using Personal Data about You and to ask Us to stop. This would not invalidate Our use of the Personal Data prior to the withdrawal of consent.

  3. To tell Us to stop using Your Personal Data for direct marketing purposes.

  4. To ask Us to send You the Personal Data We have about You. This is sometimes called a "subject access request"

On or after 25 May 2018, We can also be contacted at the address above for the following reasons:

  1. To ask Us to provide You with the Personal Data You have provided to Us. We will provide the Personal Data in a CSV formatted document so that another organisation's software can understand that Personal Data. This is sometimes called a "data portability" right.

  2. To ask Us not to use Personal Data about You in a way that allows Our computer systems to make decisions about You.

  3. To request that We restrict use of Your Personal Data or to object to its use (including objecting to data used in Our "legitimate interests").

Sometimes We will not be able to stop using Your Personal Data when You ask Us to (e.g. where We need to use it because the law requires Us to do so).


You have the right to complain about how We treat Your Personal Data to the Information Commissioner's Office (the "ICO"). The ICO can be contacted at:


We may update this Privacy Statement from time to time. We will notify You of the changes where required by law to do so.