Who we are HRG (UK) Limited is a company incorporated in England and Wales (registered number 02527817) whose registered office is at Mercury House, 8 Sandy Way, Grange Park, Northampton, NN4 5EJ.
Our Legal Obligations We will at all times only collect, process and use your personal information in accordance with the Data Protection Legislation.
What we collect When you us this website or contact us by post, telephone, fax, e-mail or via the Contact page on this website, we may collect, process, store and use some of the personal information which you provide to us.
The personal information which we may collect includes:
- Information which you provide to us by filling in your details on our Contact page such as your name, email address and any further personal information which you provide in your message. We would ask that you do not include in your message any information in relation to your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, any trade union membership or any information in relation to your health, sex life, sexual orientation or any criminal convictions or offences (“Special Category Information”);
- Information which you provide to us when you sign up to receive our newsletter such as your name and email address;
- If you contact us we may keep a record of that correspondence;
- Any information which you provide if you complete surveys that we use for market research or with a view to the improvement of our services and products (although for the avoidance of any doubt you do not have to provide this information), which may include your name, address, email address, phone number and other contact details as well as details of your demographic such as your post code and age;
- any information which you provide in order to enter any competition which we may run from time to time (although for the avoidance of any doubt you do not have to enter any such competition) which may include your name, address, email address, phone number and other contact details as well as details of your demographic such as your post code and age;
- details of services which you engage us to perform and of any contractual agreements we may have in place with you or which we are in discussions with you about including your name, job title, employer, email address and telephone number;
- details of your visits to our website including, but not limited to traffic data, location data, weblogs and other communication data, and details of any resources or pages that you access.
Log files and cookies In addition we may collect information about your computer and your browsing activities including where available your IP address, operating system, browser type and details of the pages which you have visited to analyse trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
- a) estimate our audience size and usage pattern;
- b) store information about your preferences, and so allow us to customise our site according to your individual interests;
- c) speed up search; and
- d) recognise you when you return to our site.
What we do with the information we gather We require this information to understand your needs and provide you with a better service. We may use the personal information which we hold about you in particular for the following reasons:
- Internal record keeping as is in our legitimate interests to do so;
- To respond to any enquiry which you may make using our Contact page as is in our legitimate interests to do;
- To provide you with information, products or services that you request from us prior to entering into any contract with us;
- To send you our newsletter by email where you have specifically signed up to receive the newsletter and where you have therefore consented to receive this;
- To contact you in relation to any products or services we have agreed to supply to you, or in relation to any contract which we may have with you, so that we can fulfil our contractual obligations to you;
- To improve our products and services in accordance with our legitimate interests.
- To send you promotional emails about new products, services or special offers which we think you may find interesting where you have expressly consented to receiving such communications or where the emails relate to products and services similar to those which you have previously purchased from us and where it is in our legitimate interests to do so.
- To send you information by post in relation to new products, services or special offers which we think might be of interest to you and where it is in our legitimate interests to do so.
- To call you by telephone to discuss your particular query, requirements and/or needs where you have requested that we do so or where it is in our legitimate interests to do so.
- To contact you by email, telephone, fax or email for market research purposes or for the purpose of research and improvement in relation to our products and services where it is our legitimate interests to do (for the avoidance of any doubt these communications will not include any form of advertising);
- To customise the website according to your interests, and to ensure that the content on the website is presented in the most effective manner for you and your computer, in accordance with our legitimate interests.
- To process your entry into any competition which we run which you may have entered and to notify you if you have won any such competition as is in our legitimate interests to do so.
For the purposes of the above our ‘legitimate interests’ include promotion of our business, marketing and the maintenance of the goodwill and reputation of HRG which includes the provision of excellent customer service and care.
If you fail to provide personal information Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Who do we share your information with? We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, as defined in section 1159 of the Companies Act 2006 where we have a legitimate interest in doing so such as where a decision has been made to consolidate support services or where required by such companies professional advisers in the performance of their services.
We may disclose your personal information to third parties in the following circumstances:
- a) to mailing houses who send out information, brochures and other marketing materials on our behalf;
- b) to our customers in the event that we run a promotional competition on their behalf which you enter and which you win. Please note only the personal information of the winner of any such competition will be forwarded to our customer;
- c) to third parties, which may include our customers in order to allow them to supply you with any prize which you may win as a result of entering any competition which we have operated.
- b) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such businesses or assets as part of the sale or purchase process and to allow this transaction to proceed as is in our legitimate interest;
- c) if HRG or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets in order to allow the transaction to proceed and as is in our legitimate interest; and
For the avoidance of any doubt, we will not share your personal information with any third party for their marketing or promotion purposes without first obtaining your express consent to do so.
Security We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place appropriate technical and organisational measures to safeguard and secure the information we collect. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the internet.
International Transfers We do not normally transfer your personal information outside the European Economic Area.
Occasionally we are required to work with external third parties based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we 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:
- the transfer of your personal data is to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission; or
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
- where we use providers based in the US, we may transfer data to them 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.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Links to other websites Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Retaining your personal information We shall keep your personal information only for as long as is necessary for the purpose for which it was collected. Where your information was provided to allow us to perform a contract with you we shall retain that information for 7 years for tax purposes and for the purposes of any legal claim. Where your personal information is provided for the purposes of receiving our newsletters or sending you promotional emails about new products, services or special offers where you have requested such communications or have expressly consented to receiving such communications we shall continue to process it in this manner until such time as you notify us that you no longer wish to receive these or opt-out of any such communications. Where you have provided your personal information in order to enter any competition which we have run, until such time as a winner has been determined. Where you have won the competition we shall retain your personal information for a period of 7 years thereafter for the purposes of any legal challenge,, where you were unsuccessful your personal information will be deleted once the winner has been announced. In all other circumstances your personal information shall be retained for no more than 12 months.
Changing your mind Where you have given us your consent for direct marketing or have expressly signed up to receive our newsletters or other promotional materials you can opt out of receiving such communications at any time by:
- following the unsubscribe link in all such emails; or
- by calling us on 01604 703200; or
- emailing us at firstname.lastname@example.org.
Similarly, if you receive any marketing emails from us as a result of having made previous purchases from us of similar goods or services and no longer wish to be contacted in this way please let us know either by email to the address above, by following the unsubscribe link which is included in all such communications or by telephoning us on the above number.
Your rights You have the right to contact us in order to find out what information we hold about you, to request that we rectify or erase any information that we hold about you or, in certain circumstances, to ask that we restrict the manner in which we process your information. Please note, in accordance with the Data Protection Legislation we may be unable to erase your information in certain circumstances, for example if it is still required for the purpose for which you provided it to us, if we have a legal obligation to retain it or if we have an overriding legitimate ground to continue processing your information. If we are unable to erase your data in accordance with a request which you have made we will notify you of this and of the reasons. Similarly if we are unable to restrict the processing of your information in a manner requested we will contact you to explain why that is the case. You also have a right to data portability.
If any of your information changes or is incorrect, or you wish to exercise any of the other rights set out above, you can request a change by sending us an email to email@example.com by telephoning us on 01604 703200. Alternatively you can ask that we correct, update or remove your personal information at your personal profile page.
If you are unhappy with the way in which we have collected or processed your personal information or have any other complaint in relation to our handling of your personal information you can make a complaint to the Information Commissioner, further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.
Notification of Changes Please be aware we may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 09 May 2018.
If at any point we wish to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify you by email. You will have a choice as to whether or not we use your information in this different manner.