Privacy
Introduction
This is the privacy notice for Manx Tomkinson on
the go app. Manx Tomkinson on the go 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 Your
Manx Tomkinson on the go 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) 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
website.
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.
Third-party
links
This website may include links
to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for their privacy statements. When you leave our website, we encourage you to
read the privacy notice of every website you visit.
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 website, 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 website 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
website 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
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 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.