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 website, including any data you may provide through this website, for example, when you submit your details to us through the ‘Contact Us’ tab of the website; and (ii) when we collect and process your personal data other than through this website as a consumer, customer, supplier or other business contact or as a potential consumer, customer or supplier of any of part of the group of companies in which HFD sits.
This website 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.
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
Sarah Ward, Company Secretary
Email address: firstname.lastname@example.org
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 17 May 2018.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until on or after 25 May 2018.
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.
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, 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.
• 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 website;
• submit a comment or query through our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a survey; or
• give us some feedback.
• 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.
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.
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. Data security
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.
8. Data retention
How long will you use my 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
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.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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.
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.
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.
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. 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.
What are Cookies
Types of cookies we use
Like many websites, we make use of session cookies and persistent cookies, neither of which collect any personally identifiable information.
We use session cookies, which only last for the duration of your visit, to enable us to identify that the same person is moving from page to page. Session cookies are deleted the moment you close your browser. An example of how we use session cookies is when we maintain your shopping basket when you move from page to page on our site.
Some cookies we use are persistent, in that they remain on your computer even after you leave our site. These remain on your computer after you have visited our site, meaning the site can remember your settings for when you return. Another reason we use persistent cookies is to help us record visitor trends over time which helps us monitor traffic and what parts of the website are more popular than others.
3rd Party Cookies
From time to time we will embed 3rd party content onto our site which may also use various cookies. These include sites such as Facebook and Twitter, whose cookie usage policy you can view on their own websites.
Below is a list of the main cookies we use, and what we use them for.
Google Analytics allows us to track how popular our site is and to record visitor trends over time. Google Analytics uses a cookie to help track which pages are accessed.
The cookie contains no personally identifiable information, but it does use your IP address to determine where in the world you are accessing the site from, and to track page visits within the site.
Managing your cookies
You have a number of options when it comes to receiving cookies. You can set your browser either to reject all cookies, to allow only ‘trusted’ sites to send them, or to accept only those cookies from websites you are currently using.
We recommend that you don’t block all cookies because parts of our website rely on them to work properly.