We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This privacy notice will tell you how we look after your personal data and about your privacy rights. It supplements any other notices and is not intended to override them.
We have tried to be brief and clear. We are happy to provide any additional information or explanation.
WHO WE ARE
The name of our brand/company, and the Data Controller, is HD, and our registered office address is 43 Allison Bank, Geoffrey Watling Way, Norwich, Norfolk. The Data Protection Champion (“DPC”) is responsible for ensuring compliance with policy. That post is held by Benjamin Race, who may be contacted by email@example.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns first.
WHAT DATA IS COLLECTED
We will typically collect the following information from customers and prospective customers:
• name and if applicable job title
• contact information including telephone contact details and email address
• demographic information such as postcode, preferences and interests
• other information relevant to customer surveys and/or offers, and relevant to the products or services being provided
It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.
HOW WE COLLECT YOUR PERSONAL DATA
You may give us data orally or by filling in forms or by corresponding with us by post, phone, email or otherwise, for example when you:
• enter into a contract with us or contact us about doing so;
• contact us about any contract we have with you;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us some feedback.
We may also receive personal data about you from third parties and public sources, including other customers when they interact with us.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to.
We have set out below how and why we plan to use your personal data.
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST:
To register you with our business
(a) Performance of a contract with you
To perform any contract with you including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Addressing any breach
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for our legitimate interests (to ensure compliance with contract terms)
To manage our relationship with you which will include:
(b) Notifying you about changes to our business which are relevant to you
(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)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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)
To make suggestions and recommendations to existing and past customers about goods or services that may be of interest
Necessary for our legitimate interests (to develop and grow our business)
Asking existing and past customers to partake in a review, prize draw, competition or complete a survey
Necessary for our legitimate interests (to develop and grow our business)
To deliver relevant website content and advertisements to existing and past customers and measure or understand the effectiveness of the advertising we provide
Necessary for our legitimate interests (to study how people use our business, to develop and grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, relationships and experiences
Necessary for our legitimate interests (to define types of people for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To provide information to prospective customers about products and services of ours and other companies in our group which may be of interest
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This may include information on products or services offered by other companies within our group.
If you have purchased goods or services from us in the past and/or are an existing customer, we may use your personal data to send you marketing communications on matters of interest, unless you have opted out of receiving that marketing. You may opt out of receiving this information at any time.
For prospective customers, we will seek your opt-in consent before we use your personal data to provide you with any information about products or services from this company or others in the group. You can unsubscribe at any time by emailing firstname.lastname@example.org
In all cases, we will seek express opt in consent before we use your personal data for any other marketing purpose or share it with any third party for marketing purposes.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
CHANGE OF PURPOSE
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.
VISITORS TO OUR WEBSITE
If we want to collect personally identifiable information through our website, we will be up front about this.
When someone visits our website, we may use a third-party service to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you do not provide personal data to us and this would prevent us from performing the contract we have or are trying to enter into with you, or place us in breach of the law, we may have to cancel our contract. We will notify you if this is the case.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third parties to help us run our business or carry out our obligations to you, in all cases to allow us to perform a contract with you, and in order to comply with our legal obligations.
Third parties comprise the following:
• Other companies in the group
• Utility companies
• Sub-contractors undertaking work on our behalf
• Service providers for IT and system administration
• Our professional advisers including lawyers, bankers, auditors and insurers
• HM Revenue & Customs, regulators and other authorities
We may also share your personal data with any 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. 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.
We do not transfer your data outside the European Economic Area.
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.
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.
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
You can ask us about the retention periods for different aspects of your personal data by contacting our DPC.
In some circumstances we may 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.
YOUR LEGAL RIGHTS
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. 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.
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.
We do not knowingly collect data relating to children.
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.
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.
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.
What are cookies?
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.
There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our website is performing or even allow us to recommend content we believe will be most relevant to you.
Certain cookies contain personal information – for example, if you click “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user’s general location.
What sort of cookies does HD use?
Generally, our cookies perform up to three different functions:
1. Essential cookies
Some cookies are essential for the operation of our website. For example, some cookies allow us to identify authenticated users to ensure they can access the member’s only pages. If a member opts to disable these cookies, they will not be able to access all of the content that is entitled them to.
2. Performance Cookies
We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages.
3. Functionality Cookies
We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your customisation preferences, such as font-sizes.
We also use or allow third parties to serve cookies that fall into the three categories above. For example, like many companies, we use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking and improving site functionality.
Can a website block cookies?
As we’ve explained above, cookies help you to get the most out of our websites.
However, if you do wish to disable our cookies then please follow the instructions below for a main selection of browsers. The instructions detailed below were correct at time of writing.
Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.
Internet Explorer 7, 8 and 9
- Open Internet Explorer, click on tools and then choose Internet Options.
- Select the Privacy tab and then click the ‘Advanced’ button.
- Check the ‘Override automatic cookie handling’ checkbox, select your custom options, click Ok and then Ok again.
- Open Google Chrome, click on the spanner icon (settings) in the top right of the page and click the ‘Show advanced settings’ link at the bottom of the page.
- Under Privacy, click on ‘Content settings...’ and under Cookies, select your preferences and then press Ok.
- The close the settings page, simply close the tab it was opened in.
- Open Firefox, click on the orange Firefox button in the top left of the page, select options and then select options.
- Select the ‘Privacy’ tab and then select ‘Use custom settings for history’. This will reveal further options.
- Select your custom cookie options starting from ‘Accept cookies from sites’ and below and then click Ok.
- If your browser is not listed above, perform a Google search for cookie settings for your browser to find to relevant information.