Privacy Policy

(Privacy policy last updated 15 July 2024 - Please check back regularly to stay informed of updates to this policy).

Introduction

• This Privacy Policy is made by the hSo Group consisting of all the entities listed here and are the controller and responsible for your personal data (collectively referred to as “hSo”, “Company”, “we”, “us” or “our” in this privacy policy).
• If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact hSo using the details set out below. Incidentally, you do have the right to make a complaint at any time to the relevant supervisory authority. For data protection issues in the UK this is the Information Commissioner's Office (ico.org.uk), in Kenya this is the Office of the Data Protection Commissioner (www.odpc.go.ke). However, we are here as the first port of call to deal with your concerns before the supervisory authority. Please contact us in the first instance. Our contact details are:

HighSpeed Office Limited
50 Leman Street
London
E1 8HQ
Email address: DataProtectionOffice@hso.co.uk

Preface

At hSo your privacy is important to us and we are committed to regulatory compliance in protecting your personal data. “you” and “your” (and other similar terms) refer to our customers, individuals associated with our customers, contacts, suppliers, job applicants, staff and visitors to any hSo website. How we look after your personal data and tell you about your privacy rights and also how the law protects you are set out as follows;

Please read this privacy policy together with any other notice or reissue hSo may provide on specific occasions to be aware of how and why your data is used. This policy governs where hSo is a Data Controller of your information i.e. we determine how your information is processed, therefore not where we process that data on behalf of another third party Data Controller who will publish their own privacy policy in the circumstances. For example, hSo websites may have links to third-party websites, plug-ins and applications and clicking on those links may allow third parties to collect or share data about you. Websites include social media features (Facebook 'Like' and ‘Share’ buttons and widgets and interactive mini-programs) and media features may collect information about you, e.g. your IP address, webpages you are visiting and may set a cookie to enable the feature. The company facilitating the feature is responsible for issue of a separate governing privacy policy.

YOUR PERSONAL DATA MUST BE ACCURATE AND CURRENT

Please keep us informed if your personal data changes during your relationship with us.

DATA WE COLLECT ABOUT YOU

Contact Data: postal addresses, email address and telephone numbers.
Financial Data: bank account and payment card details. In relation to staff data, e.g. Pensions, PHI, Group Life, HMRC, payroll bureau etc
Identity Data: first name, maiden name, last name, username, marital status, title, date of birth and gender.
Transaction Data: details about payments to and from you and other details of products and services purchased.
Technical Data: internet protocol (IP) address and credentials, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and or other technology on devices you may use to access our websites.
Profile Data: username and password, interests, preferences, feedback and survey responses.
Usage Data: includes information about how you use our website, products and services, IT application usage information, operating software and applications installed, usage times and data transferred.
Marketing and Communications Data: your preferences to receive marketing from hSo and hSo third parties. hSo also collect, use and share Aggregated Data such as statistical or demographic data for any purpose (e.g. our Usage Data aggregated to calculate the percentage of users accessing a specific website). Aggregated Data although derived from personal data but is not deemed to be personal data. This data does not reveal your identity.

Special Categories of Personal Data: hSo do not collect this category of data about you (race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric, with the exception of criminal convictions or offences in relation to staff.

Data Minimisation

We are committed to the principle of data minimisation, ensuring that we collect and process only the personal data that is necessary for the specific purposes outlined in this privacy policy. This means that we:

Limit Collection: Collect only the data that is strictly necessary for the purposes for which it is processed. Before collecting any personal data, we carefully evaluate the purpose of the data collection and ensure that we are not collecting more data than is required to achieve that purpose.

Purpose Specification: Clearly define the purpose for which personal data is being collected and processed. We ensure that the data collected is relevant and limited to what is necessary in relation to the purposes for which it is processed.

Data Review: Regularly review the data we hold to ensure it is accurate, relevant, and necessary. We conduct periodic audits to identify and securely delete any data that is no longer needed for the purposes for which it was collected.

Data Subject Rights: Respect the rights of data subjects to access, correct, and delete their personal data. We provide clear mechanisms for data subjects to exercise these rights and ensure that any unnecessary data is promptly corrected or deleted upon request.

Training and Awareness: Train our employees on the principles of data minimization and the importance of collecting only the data that is necessary. Our staff are aware of their responsibilities in relation to data minimisation and are equipped to apply these principles in their daily work.

Technical Measures: Implement technical measures to ensure that our systems and processes are designed to collect only the necessary data. This includes using data minimisation techniques such as anonymisation and pseudonymisation where appropriate.

We are committed to protecting the privacy of our data subjects by only collecting and retaining the data that is absolutely necessary for our legitimate business purposes.

HOW hSo IS COLLECTING YOUR DATA

Interactions with hSo: where you directly give us personal data; via forms, corresponding with us by post, phone, email, apply for our products or services; create an register/account on our website; subscribe to our service or publications; request marketing to be sent; enter a competition, promotion or survey; or give us some feedback register for an event or download; or to apply for a job/receive employment.

Service interactions: interactions with our Services/Products, may result in personal information being collected; unique device ID’s, device IP addresses, login username and password, security question answers and user location.

Interactions with our Partners: personal data submitted to hSo channel partners (reseller, wholesale etc.) passed through to hSo to provide a product/service for your usage, we retain that data. Further, hSo will collect personal data from our partners where you have expressed an interest in our products/services or company.

Automated interactions/technologies: as you interact with our website, hSo automatically collect Technical Data about your equipment, browsing actions by using cookies, server logs and other similar technologies. hSo will also receive data about you if you visit other websites employing our (third parties) cookies. Please see our cookie policy for further details.

Third parties: hSo may receive personal (including technical) data about you from various third parties and public sources, both inside and outside the UK. These third parties may include:

Technology and Security Providers: Entities that offer endpoint management systems, access control systems, and network analytics services.

Advertising and Marketing Networks: Providers of advertising services and marketing analytics to help us understand user interactions and preferences.

Search Information Providers: Organisations that offer search information services.

Service Providers: Companies providing technical, payment, and delivery services.

Data Brokers and Aggregators: Businesses that collect and aggregate identity and contact data.

Hosting and Form Providers: Providers of website hosting and web form services.

Call Tracking Services: Companies that offer call back and call tracking services.

Public Sources: Publicly available sources such as corporate registries and electoral rolls.

Channel Partners: Partners with whom you have interacted or shared your personal data.

Additionally, hSo may share personal data about you with various third parties and public sources based outside the UK, including but not limited to:

Email Service Providers: Entities that manage and facilitate email communications.

Online Community Platforms: Providers of platforms for online communities and interactions.

Marketing Automation Providers: Companies that offer automated marketing solutions to streamline marketing activities.

THE PURPOSE AND HOW hSo USE YOUR PERSONAL DATA:

To perform the contract we are about to/have entered into with you; necessary for our legitimate interests (or that of an hSo third party), where your interests/ fundamental rights do not override those interests; comply with a legal or regulatory obligation; assess your suitability for employment in processing your application; send you materials that you request such as brochures etc.; register you for an event; analytical purposes (understand how visitors to our websites move around and what content they access in order to market content to specific users); network analytics (detect and mitigate DDoS attacks and other SaaS monitoring services); customer support and training; solicit feedback; supporting testimonials you have provided or marketing activity you agreed to participate in; marketing communications; identify devices used in conjunction with our products and services; enforce security features within our products and services; and in order verify identity.

WHERE hSo CHANGE THE OF PURPOSE OF USE:

hSo may only use your personal data for the purposes for which we collected it, save for where we reasonably consider that we need to use it for another reason and that reason is in turn compatible with the original purpose. You should contact hSo where you need an explanation how the new purpose is compatible with the original purpose. hSo need to use your personal data for an unrelated purpose we will notify you and hSo will explain the legal basis which allows us to do so. However, we may process your personal data without your knowledge or consent, in accordance with this policy where required or permitted by law.

OUR LAWFUL BASIS FOR COLLECTION OF YOUR PERSONAL DATA:

hSo ensure we have a lawful basis for collection of personal data, either; A. hSo need it to perform a contract we are about to or have entered into, with you; B. hSo need to comply with a legal or regulatory obligation; C. necessary for hSo legitimate interests, i.e. prevent fraud, keeping our records updated and to study how customers use our products/services /websites, keep our website updated and relevant, define customers for our products and services, develop and grow our business, inform our marketing strategy, develop our products/services, running the hSo business, provision of administration and services, network security, assess whether to enter into a contract with you; or D. where you have given consent.

MARKETING

• hSo provide you with choices regarding particular personal data uses in connection with marketing and advertising. You may request removal of your details from our marketing systems or update your marketing preferences at any time by contacting us. hSo will only retain your personal data for non-marketing purposes if continue to have a lawful basis for doing so. hSo will endeavour to respond to your request within less than one month.
• For promotions or offers related to marketing, hSo use your personal data to take a view on what we think you may want or need, or what may be of interest to you. This is how hSo decide which products, services and offers may be relevant for you. You will also receive marketing communications from hSo if you have requested information from us or purchased goods or services from us or if you provided us with your details when registered for an event, webinar or download and you have not opted out of receiving that marketing.
• In relation to third party marketing, hSo will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
• Your browser may be set to refuse all or some browser cookies, or to alert you when websites set or access cookies. Note where you disable or refuse cookies some parts of this website may become inaccessible.

SHARING OF YOUR PERSONAL DATA

Entities within the hSo group, listed here, are granted access to the data stored in our systems, in order to provide services and technical support for our products and services. We share your information as necessary in the ways outlined in this Privacy Policy on a need to know basis and only to those parties who implement appropriate confidentiality and security measures. We communicate and enforce our privacy and security guidelines within the hSo group.

As a matter of course, hSo reserve the right to use or disclose information provided if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and or to comply with a judicial proceeding, court order, legal process or other regulatory or governmental authority; provided that unless prohibited by law, hSo will use its reasonable efforts to give you notice to enable you to seek a protective order or take other appropriate action.

In the ordinary course of business, hSo may need to disclose or share your personal data with certain parties whom have arrangement with hSo and its affiliates, for the purposes set out under this policy; customer relationship management software providers, with credit-checking agencies for credit control reasons; marketing automation platform providers, email platforms, electronic signature service providers, Web site hosting providers, partners, online community platform provider, members of our partner programs; ZTNA functions and systems providers, network analytics providers, human resources information system provider and our background check service providers; analytics providers; customer reference management software provider; payment processing providers; enterprise resource management software provider; survey tool service providers, calendar scheduling tool providers and learning management system software provider; domain registrars, licencing providers, hardware and software providers, monitoring tool providers, products and services providers, cloud platform providers, transformation service providers and distribution service providers; professional advisers including lawyers, bankers, auditors and insurers based in the UK or utside the UK where relevant; and HM Revenue & Customs, regulators and other authorities in the UK or outside the UK where relevant; business and channel partners where you specifically opt in to such sharing via an information request or an event registration form, or you attend a hSo event and have your attendee badge scanned by a business/channel partner. Where you do not wish for your information to be shared in this way, you may choose not to opt in via information request or event registration forms.

If you choose to share your information with channel/business partners as above, your information will be subject to the channel/business partners' individual privacy statements. hSo require all third parties to respect the security of your personal data and to treat it in accordance with the law. hSo do not allow 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 hSo’ instructions.

hSo may choose to sell, transfer, or merge parts of our business or our assets, or we may seek to acquire other businesses or merge with them. This data may be shared under the terms of this policy.

TRANSFERS OF DATA OUTSIDE THE UK

We may store or transfer some or all of your personal data in countries that are outside the UK. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK.

Some group companies of which we are part are based outside the UK and we may share and transfer your personal data outside of the UK with these companies. Other third parties that we may share your personal data with could be based outside the UK and their processing of your personal data will involve a transfer of data outside the UK.

Where hSo need to transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. only to transfer your personal data to countries deemed to provide adequate levels of protection for personal data by the UK (known as an ‘adequacy' regulation) and to US organisations certified to the UK Extension to the EU-US Data Privacy Framework further to article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here (see a Guide to International transfers | ICO);

2. there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you;

3. a specific exception applies under relevant data protection law;

4. hSo may transfer data to countries within the group of companies of which we are part based outside of the UK, and it may transfer data into the US or other territories using International Data Transfer Agreement (IDTA) and the International Data Transfer Addendum to the European Commission's Standard Contractual Clauses for International Data Transfers (Addendum) in compliance with article 46 of the UK GDPR when making restricted transfers;

DATA SECURITY

hSo have appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Further, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know, whom will only process your personal data on our instructions and they are subject to a duty of confidentiality.

hSo have 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.

RETENTION OF PERSONAL DATA

hSo will only retain your personal data for as long as necessary to fulfil the purposes it was collected (including for the purposes of satisfying any legal, accounting, or reporting requirements). hSo may also 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.

Under certain circumstances you can ask us to delete your data. Contact DataProtectionOffice@hso.co.uk.

In order to determine the appropriate retention period hSo applies to keep 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. hSo retain;

• information on unsuccessful employment applications for six (6) months in case another alternative role becomes available that we think you may be suitable for;
• information on successful employment applications for six (6) months in order for management to process such applications i.e. criminal convictions or offences and background screening checks;
• prospective customer data for which we obtained explicit consent for we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed;
• usage data indefinitely as this is always relevant to product/service development;
• basic personal data and financial information about our customers for the duration of your business relationship with us and thereafter as required for legal and audit purposes;
• testimonials until withdrawn at your request; and
• personal information linked to service support requests indefinitely because historical data about service issues is always relevant to service development.

YOUR LEGAL RIGHTS

If you wish to exercise your legal rights below, please contact hSo as follows DataProtectionOffice@hso.co.uk. There is generally no fee payable to access your personal data (or to exercise any of the other rights below) save where we charge a reasonable fee, where your request is clearly unfounded, repetitive or excessive. hSo may refuse to comply with your request, where we will provide a written explanation of why to the individual, informing them of their right to complain to the supervisory authority without undue delay and at the latest within one month.

You have the right to;

• Request Access to your personal data (known as a data “subject access request”(“SARs”)), which will enable you to receive a copy of the personal data hSo hold about you and to check that we are lawfully processing it.
• Request Correction of the personal data that hSo hold about you, which will enable you to have any incomplete or inaccurate data we hold about you corrected (we may need to verify the accuracy of the new data you provide to us).
• Request Erasure of your personal data, which enables you to ask hSo to delete or remove personal data where there is no good reason for hSo to continuing to process it. In addition, you may 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, as below, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. hSo may not always be able to comply with your request of erasure for specific legal reasons of which you will be notified at the time of your request.
• Object to Processing of your personal data where we are relying on a legitimate interest (or those of our third party) and there is something about your particular situation which makes you feel it necessary to object to processing on this ground where you feel it impacts on your fundamental rights and freedoms. Further, you also have the right to object where we are processing your personal data for direct marketing purposes, where in certain instances 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 which enables you to ask hSo to suspend the processing of your personal data in the following cases, (i) where you want us to establish the data’s accuracy; (ii) where hSo’ use of the data is unlawful but you do not want us to erase it (iii) where you need hSo to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to hSo’ use of your data but in order to use it hSo need to verify whether we have overriding legitimate grounds.
• Request the Transfer of your personal data to you or to a third party. hSo will provide to you, or a third party you have nominated and verified, your personal data in a structured machine-readable format. This right only applies to automated information which you initially provided consent for hSo to use, or where hSo used the information to perform a contract with you.
• Withdraw Consent where hSo are relying on consent to process your personal data (this will not affect the lawfulness of any processing carried out prior to withdraw consent). hSo will advise you at the time you withdraw your consent if we are not able to provide certain products or services to you as a result of such withdrawal.

CONFIRMATION OF YOUR IDENTITY:

hSo may need to request specific information from you to confirm your identity and verify 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. As a courtesy, hSo may also contact you to ask for further information in relation to your request in order to speed up our response. The hSo Subject Access Request Form available here gives the format for requests.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in future will be posted on this page.

GOOGLE AND THIRD PARTY RELATED DISCLOSURE (NOT PART OF THE PRIVACY POLICY)

We advertise some of our services via Google and use some third parties to provide products and services to you. If we use third parties or if you click on one of our ads or visit web pages that make use of any Google service, we may share some of your data with the firms listed here. Any sharing would be in accordance with our privacy policy.