(last updated 24 May 2018 - Please check back regularly to keep informed of updates to this Policy).
HighSpeed Office Limited 50 Leman Street London E1 8HQ
Email address: email@example.com
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 keep us informed if your personal data changes during your relationship with us.
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, 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.
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.
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.
Third parties: hSo may receive personal (technical) data about you from various third parties and public sources: analytics providers (e.g. Google based outside the EU); advertising networks based inside the EU; and search information providers based inside the EU; Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU; Identity and Contact Data from data brokers or aggregators based inside the EU; Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register; Identity and Contact Data from channel partners to whom you have provided such personal data.
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); 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.
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.
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.
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 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, 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, Web site hosting providers, partners, online community platform provider, members of our partner programs; 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; professional advisers including lawyers, bankers, auditors and insurers based in the UK and/or EEA; and HM Revenue & Customs, regulators and other authorities in the UK and/or EEA; 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.
Third parties that we may share your personal data with could be based outside the EEA and their processing of your personal data will involve a transfer of data outside the EEA.
Where hSo need to transfer your personal data out of the EEA, 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 European Commission (see European Commission: Adequacy of the protection of personal data in non-EU countries); 2. hSo may use specific contract terms (only with certain service providers) approved by the European Commission which give personal data the same protection it has in Europe (see European Commission: Model contracts for the transfer of personal data to third countries); 3. hSo may transfer data to providers based in the US if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US (see European Commission: EU-US Privacy Shield). Email firstname.lastname@example.org for further information on the methods used by hSo when transferring your personal data out of the EEA.
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.
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 email@example.com.
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;
If you wish to exercise your legal rights below, please contact hSo as follows firstname.lastname@example.org. 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;
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 (https://ico.org.uk/for-the-public/personal-information/) gives the format for requests.