Haatch Privacy Policy

Introduction

The purpose of this policy is to provide you with the required information in relation to the providing us with personal data. The General Data Protection Regulation (“GDPR”) governs the controlling and processing of personal data which is essentially information about individuals, and also gives those individuals certain rights in respect to that information.

Please read this notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this notice.

Information we collect about you

• We are committed to safeguarding your privacy.
• This policy applies where we are acting as a data controller with respect to
  your personal data; in other words, where we determine the purposes and
  means of the processing of that personal data. When using our website you
  are agreeing to this policy, you consent to our use of cookies in accordance
  with the terms of this policy.

Data collected will be processed fairly and lawfully and will only be processed where we comply with Article 6(1) of the GDPR. The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:

• Consent: Where you have given consent we can collect and process your data for one or more specific purposes.
• Contractual obligations: In certain circumstances, we may need to process your personal data to provide the services under our contract with you.
• Legal compliance: If the law requires us to, we may need to collect and process your data.
• Legitimate interest: In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

In this policy, “we”, “us” and “our” refer to our Data Protection Officer Fred Soneya. For more
information about us, see Section 13.

How we use your personal data

We use information about you in the following ways:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

• We may process data about your use of our website (“usage data”). The usage data may include your IP address, browser type and version, operating system, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
• We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
• We may process information contained in any enquiry you submit to us regarding services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is our legitimate interests.
• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.
• We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
• We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person.
• Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

• We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
• We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
• In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Retaining and deleting personal data

• This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
• Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) personal data will be retained for a minimum period of 5 years and a maximum of 7 years.

• Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

• We may update this policy from time to time by publishing a new version on our website.
• You should check this page occasionally to ensure you are happy with any changes to this policy.
• We may notify you of changes to this policy by email or through the private messaging system on our website.

Your rights

You have a right to learn and have access to what personal information is held by us and can ask us for details. When we receive such a request we will endeavour to provide you with your information without delay and at the latest within one month of receipt. We may extend the period of compliance by a further two months where requests are complex or numerous. In such instances we will inform you within one month of the receipt of the request and explain why the extension is necessary.

You will have the right to obtain, on request, confirmation as to whether your personal data is being processed, together with the following information:

• The purpose of processing your data;
• Information about the recipients of your data;
• Recipients or categories of recipient to whom the personal data will be disclosed (in particular third countries or international organisations);
• The right to lodge a complaint with a data protection authority;
• In cases of automated processing, details of profiling;
• Information about the sources of data.

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) Information must be provided to you within one month at no cost to you. However, we have the right to refuse or charge a reasonable fee when a request is manifestly unfounded or excessive, particularly if it is repetitive; and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

Under GDPR, you also have the following rights:

• Right to be informed;
• Right to rectification;
• Right to be forgotten (erasure);
• Right to restrict processing;
• Right to data portability;
• Right to object;
• The right not to be subject to automated decision-making, including profiling.

You have the right to withdraw consent at any time. This must be provided in writing.

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

About cookies

• A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
• Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies used by our service providers

• Our service providers use cookies and those cookies may be stored on your
  computer when you visit our website.
• We use Google Analytics to analyse the use of our website. Google Analytics gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gid.
• We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Our details

• This website is owned and operated by Haatch
• We are registered in England and Wales under registration number 08900522, and our registered office is at The Hub, Blackfriars Street, Stamford, Lincolnshire, PE9 2BW
• Our principal place of business is at The Hub, Blackfriars Street, Stamford,
  Lincolnshire, PE9 2BW

You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using hello@haatch.com.

Data protection officer

Our data protection officer’s contact details are: Fred Soneya, fred@haatch.com

Complaints

Haatch believe that all clients deserve a high-quality service. If you are unhappy with our service you are entitled to express your dissatisfaction with any member of staff or contact us in writing. We undertake to deal with your complaint fairly and effectively. We will act in accordance with the rules and regulations set out by the Financial Conduct Authority (FCA).You should address your complaint as follows:

The Compliance Officer

Haatch

The Hub, Blackfriars Street, Stamford, PE9 2BW

Email: hello@haatch.com

The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren’t able to resolve themselves. To contact the Financial Ombudsman Service please visit www.financial-ombudsman.org.uk.