This Policy explains what information we gather about you, how we use that information, what we use that information for and who we may share that information with. It also sets out your rights in relation to any information that we may hold about you.
This Policy applies to information that we collect about visitors to www.hambroperks.com and any other sites maintained by the HP Group that link to this Policy (together, “the HP Sites”). Each HP Group company is a separate legal entity and complies with the relevant local laws and regulations to ensure the protection of your personal information. Members of the HP Group include Hambro Perks Services Limited, Hambro Perks Asset Management Limited and Hambro Perks Advisory LLP.
1. Who we are
Hambro Perks Limited is the controller and responsible for www.hambroperks.com; and, Hambro Perks Asset Management Limited is the responsible for eis.hambroperks.com and any personal information you share on eis.hambroperks.com will be controlled and processed by Hambro Perks Asset Management Limited.
2. Third party links
3. The Information 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 use different methods to collect data from and about you including through direct interactions. For example, you may provide us with your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
You can browse the HP Sites without entering any personal information. However, if you choose to request information about the HP Group or any of the products or services we offer, you will be asked to provide us with personal information through a request form. Information we collect may include: your name, email address, telephone number and, in the case of determining your eligibility to receive promotional information, confirmation of your status as an authorised or exempt person under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.
We endeavour to only collect the minimum amount of information necessary to fulfil your request. However, some of the information that we ask you to provide is mandatory and if you do not provide it, we may not be able to grant you access to certain areas of the HP Sites or provide you with certain materials.
4.Cookies and other information-gathering technologies
5. How we will use the information about you
When you provide personal information to us, we may use it for any of the purposes described in this Policy or as stated at the point of collection, including, but not limited to:
- where it is necessary for our/your legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- to administer and manage the HP Sites, including to confirm and authenticate your identity and prevent unauthorised access to some areas of the HP Sites;
- to continue to improve the user experience on the HP Sites;
- to conduct benchmarking and data analytics, for example, determining the usage of the HP Sites and sorting and analysing your data for this purpose;
- to conduct quality and risk management assessments including the use of data analytics;
- where we need to comply with a legal/regulatory obligation; and/or
- any other purposes for which you have provided your personal information to the HP Group (we will notify you if this is the case at the time).
We only collect personal information in accordance with applicable law and this Policy and we do not, through any of the HP Sites, collect your personal information for sale to third parties or for consumer marketing purposes.
6. Security of your personal information
We adhere to highly stringent security measures to protect your personal information from misuse, loss or alteration. Only persons who have agreed to protect and keep confidential your personal information in line with this Policy and our practices relating to data protection and confidentiality have access to your personal information you provide to us.
We take all appropriate measures to protect personal information; however, as any transfer of data over the internet is not completely secure we cannot guarantee absolutely the security of data transmitted to us over the internet. 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.
7. Data retention
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, governance 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 of our relationship with you.
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, having regard to the applicable legal, regulatory, tax, accounting, governance or other requirements.
In some circumstances you can ask us to delete your data (see section12 (Your legal rights) below).
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.
8. Access to your information and updating and correcting your information
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to firstname.lastname@example.org or send a letter to 8 Greencoat Place, London SW1P 1PL. We do not normally charge for this; however, we may make a small charge for this if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by sending us an email or writing a letter to us at the addresses provided above. You may ask us, or we may ask you, to correct information you or we think is inaccurate or incomplete and you may also ask us to remove information which is inaccurate.
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 aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.
9. Transfer of personal information
When necessary, your personal information may be transferred to and stored outside of the United Kingdom. This includes countries outside of the European Economic Area (“EEA”) which may not have local laws which specifically provide protection for personal information. Where your personal information is collected within the EEA and transferred out of the EEA, it will only be transferred where: the recipient is located in a country which provides an adequate level of protection; and/or, an agreement is in place which includes contractual clauses that are of a standard approved by the European Commission for the purposes of transferring personal information outside of the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Third party affiliates
In accordance with this Policy, where it is necessary to do so for the purposes set out in this Policy, we may transfer or disclose the personal data we collect to members of the HP Group, their subsidiaries and affiliates, subcontractors and to their third party contractors and their subsidiaries and affiliates. This may be necessary for administrative, security, storage and management purposes and to process the information for the reason it has been submitted.
10. Applicable law
The terms of this Policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction.
11. Changes to this Policy
We keep this Policy under regular review. Every time you wish to use the HP Sites, please check these terms to ensure you understand the terms that apply at that time.
12. 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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- 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.
10. Contact us
We welcome your views about the HP Sites and this Policy. If you would like to contact us with any queries or comments please send an email to email@example.com or send a letter to 8 Greencoat Place, London SW1P 1PL.