PRIVACY POLICY
____________________________________________________________
CLAUSE
1. Important
information and who we are
2. The
data we collect about you
3. How
is your personal data collected?
4. How
we use your personal data
5. Disclosures
of your personal data
6. International
transfers
7. Your
legal rights
8. Glossary
Introduction
This is the privacy notice
for MyHeadlam app. MyHeadlam is a customer app developed by HFD Limited.
HFD Limited (HFD or the Company)
respects your privacy and is committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data when
you use the MyHeadlam app and will tell you about your privacy rights and how
the law protects you.
1. Important information and who
we are
Purpose of this privacy notice
This privacy notice aims to give you
information on how HFD collects and processes your personal data through (i)
your use of this app, including any data you may provide through this app, and
(ii) when we collect and process your personal data other than through this app
as a customer.
This app is not intended for
children and we do not knowingly collect data relating to children.
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. This privacy notice supplements the other notices and is not
intended to override them.
Controller
HFD has a number of different
business units. This privacy notice is issued on behalf of HFD so when we
mention HFD or the Company, "we", "us" or
"our" in this privacy notice, we are referring to the relevant
business unit of HFD responsible for processing your data. HFD Limited is the
controller and responsible for this app.
Our Company Secretary will oversee
questions in relation to this privacy notice. If you have any questions about
this privacy notice, please contact the Company Secretary using the details set
out below.
Our Contact details
Full name of legal entity: HFD
Limited
Karen Atterbury, Company Secretary
Email address:
headlamgroup@headlam.com
Postal address: PO Box 1 Gorsey
Lane, Coleshill, Birmingham, B46 1JU
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 www.ico.org.uk. We would,
however, appreciate the chance to deal with your concerns before you approach
the ICO so please contact
us in
the first instance.
Changes to the privacy notice and
your duty to inform us of changes
This notice was last updated on 12
December 2019.
It is important that the personal
data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal
information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed
(anonymous data).
We may collect, use, store and
transfer ("process") different kinds of personal data about you which
we have grouped together as follows:
Identity Data includes
first name, maiden name, last name, username or similar identifier, marital
status, title, date of birth and gender.
Contact Data includes
email address and telephone numbers.
Technical Data includes
internet protocol (IP) address, your login data, operating system and other
technology on the devices you use to access this app.
Profile Data includes
your username and password, your personal or professional interests,
preferences, feedback and survey responses, your contact history, purchase
history and saved items; data which we may obtain from you to enable us to
enable us to undertake credit or other financial reference checks on you and
online data obtained from accounts which you may link to us e.g. Facebook, or
relating to your professional online presence e.g. LinkedIn.
Usage Data includes
information about how you use our app, products and services.
Marketing and
Communications Data includes your preferences in receiving marketing
from us and our third parties and your communication preferences.
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose. 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 app 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.
We do not collect any Special
Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your
health and genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.
3. How is your personal data
collected?
We use different methods to collect
data from and about you 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:
create an account on our app;
subscribe to our service or
publications;
request marketing to be sent to
you;
enter a survey; or
give us some feedback.
Automated technologies or
interactions. As you interact with our app, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect
this personal data by using cookies, and other similar technologies. Please see
our cookie
policy for
further details. We also collect Identity Data and Usage Data through our door
entry systems and reception logs, CCTV and access control systems, and may also
collect Profile Data through our communications systems and email
Third parties or publicly
available sources. We may receive personal data about you from various
third parties and public sources as set out below:
Technical Data from the following
parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
Contact Data from providers of
technical services.
Data relating to your payment
details from a third party such as your bank or building society, with your
knowledge and approval.
Identity and Contact Data from
data brokers or aggregators.
Identity and Contact Data from
publicly availably sources such as Companies House and the Electoral Register
based inside the EU.
Identity and Contact Data from
sanctions screening providers, credit reference agencies and customer due
diligence providers.
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:
Where we need to perform the
contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a
legal or regulatory obligation.
Generally, we do not rely on consent
as a legal basis for processing your personal data other than in relation to
sending third party direct marketing communications and some direct marketing
messages which we may send to you via email or text message (see below
"Direct Marketing Communications"). You have the right to withdraw
consent to marketing at any time by contacting us.
Purposes for which we will use
your personal data
We have set out below, in a table
format, a description of all the ways we plan to 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 process your
personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your personal data
where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To manage our relationship with you which will include: (a) To provide our products and services to you (b) Notifying you about changes to our terms or privacy notice (c) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers/third parties use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our app, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our app updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Direct Marketing Communications
We may use your personal data to
send you updates (by email, text message, telephone or post) about our products
and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in
processing your personal data for direct marketing purposes. This means that we
usually do not need your consent to send your promotional communications.
However, where consent is needed, we will ask for this consent separately and
clearly.
We will get your express opt-in
consent before we share your personal data with any company outside of the
group of companies in which HFD sits for direct marketing purposes.
We will always treat your personal
data with the utmost respect and never sell or share it with other
organisations outside of the group of companies in which HFD sits for direct
marketing purposes. We may ask you to confirm or update your direct marketing
preferences if you instruct us to provide further products or services in the
future, or if there are changes in the law, regulation, or the structure of our
business.
Opting out
You can ask us or third parties to
stop sending you marketing messages at any time by logging into the app and
checking or unchecking relevant boxes to adjust your marketing preferences or
by following the opt-out links on any marketing message sent to you or by
contacting us at any time.
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 you wish to get an explanation as to how the processing
for the new purpose is compatible with the original purpose, please contact us.
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.
Please note that we may process your
personal data without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
5. Disclosures of your personal
data
We may have to share your personal
data with the parties set out below for the purposes set out in the table in
paragraph 4 above.
External Third Parties as set out
in the [Glossary].
Third parties to whom we may
choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a
change happens to our business, then the new owners may use your personal data
in the same way as set out in this privacy notice.
We require all third parties to
respect the security of your personal data and to treat it in accordance with
the law for specified purposes.
6. International transfers
We do not transfer your personal
data outside the European Economic Area.
7. Your legal rights
Under certain circumstances, you
have rights under data protection laws in relation to your personal data.
You have the right to:
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 the personal data that we hold
about you. This enables you to have any incomplete or inaccurate data we hold
about you corrected, though 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. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to
object to processing (see below), 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. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
You also have the absolute right to object where we are processing your
personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables
you to ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data's accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate
grounds to use it.
Request the 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 withdraw 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 exercise any of the
rights set out above, please contact us.
No fee usually required
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 may refuse to comply with your request in these
circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate
requests within one month. Occasionally it may 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.
8. Glossary
LAWFUL BASIS Privacy
Legitimate Interest means the interest of our business
in conducting and managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative)
and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is
necessary for the performance of a contract to which you are a party or to take
steps at your request before entering into such a contract.
Comply with a legal or regulatory
obligation means
processing your personal data where it is necessary for compliance with a legal
or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
Service providers acting as
processors based in the UK who provide IT and system administration services.
Professional advisers acting as
processors or joint controllers including lawyers, bankers, brokers, auditors,
debt collection agencies and insurers based in the EEA who provide consultancy,
banking, stockbroking, legal, insurance and accounting services.
HM Revenue & Customs,
regulators, law enforcement agencies and other authorities to comply with our
legal and regulatory obligations.