Privacy Policy
This Privacy Policy is issued by HN06 Limited, a company registered in England and Wales under company number 14229120 (“HN06”, “we”, “our”, “us”, etc.).
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We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.
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This website is not intended for children and we do not knowingly collect data relating to children.
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It is important that you read this Privacy Policy.
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1. Important information and who we are
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HN06 is the controller and responsible for your personal data.
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If you have any questions about this Privacy Policy or our data protection practices, please contact us:
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Email address: hn06@hn06.co.uk
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Registered office: Ashcombe House, 5 The Crescent, Leatherhead, Surrey, England, KT22 8DY
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Telephone number: +44 (0)113 539 8755, +44 (0)113 539 8754
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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 policy/notice of every website you visit.
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Without your personal data it may not be possible for us to provide services to you or the organisation you represent.
2. What personal data do we collect about you?
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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).
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We may collect, use, store and transfer different kinds of personal data about you as follows:
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Identity Data includes but is not limited to first name, last name, job title, employer
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Contact Data includes but is not limited to address, telephone number, email address
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Financial Data includes but is not limited to billing details
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Transaction Data includes but is not limited to details of services purchased from us
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Technical Data includes but is not limited to internet protocol (“IP”) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
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Profile Data includes but is not limited to your interests, preferences and feedback
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Usage Data includes but is not limited to information about how you use our website and services
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Marketing and Communications Data includes but is not limited to your marketing preferences and your communication preferences
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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
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 do we collect personal data about you?
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We use different methods to collect data about you, including but not limited to:
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Direct interactions: you may give us your personal data by filling in forms or by communicating with us by phone, email, web conferencing or otherwise
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Automated technologies or interactions: as you interact with our website, we will automatically collect Technical Data using cookies and other similar technologies (see our cookies policy for further details)
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Third parties or publicly available sources: we will receive personal data about you from various third parties and public sources such as analytics providers (e.g. Wix Analytics based outside the UK), business networks (e.g. LinkedIn based outside the UK), identity and contact data from publicly available sources (e.g. Companies House based inside the UK).
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We rarely require your explicit consent to process your personal data. Where this is necessary, we will seek your consent before processing your personal data.
4. How do we use your data?
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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:
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Where necessary to perform the contract we are about to enter into or have entered into with you
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Where necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
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Where we need to comply with a legal obligation
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Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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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.
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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.
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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.
Purposes
The purposes for which we collect personal data include but are not limited to the following:
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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To register you or the organisation you represent as a new customer | Identity, Contact | Performance of a contract with you |
To process and deliver services to you or the organisation you represent including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us | Identity,
Contact, Financial, Transaction, Marketing and Communications | (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you or the organisation you represent which could include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to provide a testimonial or complete a survey | Identity, Contact, Profile, Usage, 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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity, Contact, Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security); (b) Necessary to comply with a legal obligation |
To deliver relevant website content and marketing to you and measure or understand the effectiveness of the marketing we serve to you | Identity, Contact, Profile, Usage, Marketing and Communications, Technical | Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical, Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | Identity, Contact, Profile, Usage, Marketing and Communications, Technical | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can tell us your preferences via the contact methods provided at the start of this Privacy Policy.
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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
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You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Cookies
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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.
5. How will we share your personal data?
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We may need to share your personal data with external third parties. These organisations include but are not limited to:
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Suppliers such as IT support services, payment providers, administration providers, marketing agencies
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Government bodies and regulatory bodies such as HMRC, fraud prevention agencies
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Our advisors such as lawyers, accountants, auditors, insurance companies
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Our bankers
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Credit reference agencies
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Email platforms
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Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets
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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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We do not sell or trade any of the personal information you have provided to us.
6. Do we transfer your personal data internationally?
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We do not transfer your personal data outside the UK.
7. What security do we have to protect your personal data?
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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. How long will we use your personal data for?
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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
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In some circumstances you can ask us to delete your data: see What are your legal rights? below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. What are your legal rights?
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Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to:
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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.
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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.
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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.
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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 that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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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:
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If you want us to establish the data's accuracy
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Where our use of the data is unlawful but you do not want us to erase it
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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
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​​You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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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.
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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.
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If you wish to exercise any of the rights set out above, please contact us.
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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 could refuse to comply with your request in these circumstances.
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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.
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We try to respond to all legitimate requests within one month. Occasionally it could 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.
You also have the right to complain at any time to the Information Commissioner's Office, the UK regulator for data protection issues (www.ico.org.uk).
Policy
Privacy Policy
Revision
1
Creation Date
19 September 2022
Revision Date
19 September 2022
Approved by
Board
Classification
HN06 Public