Privacy Notice | Hopehead

Privacy Notice.

Introduction

Hopehead Limited is a company registered in England and Wales under company number 11890803 and whose registered office is at 42 Brook Street, London, W1K 5DB (“Hopehead”, “we”, “our” or “us”). We are registered with the Information Commissioner's Office (registration number ZA533302).

We understand the importance of protecting personal information and are committed to complying with the General Data Protection Regulation 2016/679 (GDPR). This privacy notice lets data subjects know what happens to any personal data that we process about them.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Our services involve us carrying out research and investigations, compiling and analysing data containing personal information and producing an analysis or report based on that result. We are therefore a data controller in respect of the personal data we collect. A data controller is the person or body who determines the purposes and means of processing personal data.

To the extent that we collect or process personal data, this privacy notice explains how we look after such personal data, and the privacy rights and legal protections of data subjects.

Purpose of this Privacy Notice

This privacy notice aims to give data subjects information on how we collect and process personal data:

through data subject’s use of our website, including any data a data subject may provide through our website;
when a person purchases our services or contacts us in respect of our services through the website or in person; and
when we gather data either directly or as provided to us by third parties with whom we deal as part of our business activity in order to provide our services.

Contact Details

Our full details are: Hopehead Limited, 42 Brook Street, London, W1K 5DB. Contact us by email at: info@hopehead.co.uk

A data subject has the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before any approach the ICO so please contact us in the first instance.

Website Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections through our website may allow third parties to collect or share data about a data subject. We do not control these third-party websites and are not responsible for their privacy statements.

The Data We Collect

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 may collect, use, store and transfer different kinds of personal data about data subjects which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes a data subject’s email address, home address and telephone numbers.
Business Data includes a data subject’s business profile, history, qualifications, interests including social media accounts (such as linked in) and professional memberships or associations.
Private Data includes information on family, interests, personal social media accounts, involvement in charities or other interests or membership
Financial Data for receiving and making payments and includes bank account and payment card details.
Transaction Data includes details of services a data subject has received from the Company and third parties.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices uses to access our website.
Profile Data includes preferences, feedback and survey responses.
Usage Data includes information about how a data subject uses our website.
Marketing and Communications Data includes a data subject’s preferences in receiving marketing from us and any communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from the personal data of data subjects but is not considered personal data in law as this data does not directly or indirectly reveal a data subject’s identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with other personal data so that it can directly or indirectly identify a data subject, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also collect any Special Categories of Personal Data about data subjects (this includes details about a data subject’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). This Special Category data is subject to even stricter rules than apply to standard personal data. We will only process such Special Category data where:

a data subject has given explicit consent to the processing of his or her personal data for one or more specific purposes; or
the processing relates to personal data which are manifestly made public by the data subject.

How is Personal Data Collected?

We use different methods to collect data from and about a data subject including through:

Direct interactions. A data subject may give us Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, electronic media or otherwise. This includes personal data provided when a data subject requests information about our services including proposals and quotations.

Automated technologies or interactions. As a data subject interacts with our website, we may automatically collect Technical Data about their equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We may obtain directly or receive personal data about data subject’s from various third parties and public sources as such as Identity and Contact Data from publicly available sources including from the world wide web, Companies House within this jurisdiction and in any country we are researching on behalf of our clients as part of our business activity.

Technical Data from the following parties:

analytics providers such as Google; and
search information providers and credit providers.

How We Use Personal Data

We will only use a data subject’s personal data when the law allows us to. Most commonly, we will use a data subject’s personal data in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into with a data subject.
where it is necessary for our legitimate interests (or those of a third party) and the interests and fundamental rights of a data subject do not override those interests. Our legitimate interests are in conducting our legitimate business activity or promoting or furthering our services.
where we need to comply with a legal or regulatory obligation.

Purposes for Which We Will Use Personal Data

We have set out below, in a table format, a description of all the ways we plan to use the personal data we process, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process personal data for more than one lawful basis depending on the specific purpose for which we are using a data subject’s data. Please contact us if for more details about the specific legal basis we are relying on to process if required.

To register new clients

Types of data: Identity; Contact

Lawful basis for processing: Performance of a contract with a data subject

To manage our relationship with clients

Types of data: Identity; Contact; Profile; Financial; Transaction; Technical; Marketing and Communications

Lawful basis for processing: Performance of a contract with a data subject; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to monitor our services and client relations and to promote our services to existing clients)

To provide services to our clients

Types of data: Identity; Contact; Business Data; Private Data

Lawful basis for processing: Necessary for our legitimate interests (to provide research to clients for their business activities)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Types of data: Identity; Contact; Technical

Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, client relationships and experiences

Types of data: Technical; Usage

Lawful basis for processing: Necessary for our legitimate interests (to define types of client for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Marketing

We strive to provide choices regarding certain personal data uses, particularly around marketing.

We may provide marketing communications where an individual signs up for such communications and, in each case, has not opted out of receiving that marketing.

Opting Out

An individual can ask us to stop sending marketing messages at any time by following the opt-out links on any marketing message sent to them or by contacting us at any time.

Browsers can be set to refuse all or some browser cookies, or to provide an alert when websites set or access cookies. If cookies are disabled or refused, some parts of our website may become inaccessible or not function properly. A cookie is an element of data that a website can send to a browser which may then be stored on that system. It does not contain confidential information such as home addresses, telephone numbers or credit card details.

Change of Purpose

We will only use a data subject’s personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process the personal data of a data subject without their knowledge or consent, where this is required or permitted by law.

Disclosures of Personal Data

We may have to share a data subject’s personal data with the parties set out below for the purposes set out in the table in paragraph 11 above.

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use a data subject’s personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of the personal data we supply to them and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data we supply for their own purposes and only permit them to process such personal data for specified purposes and in accordance with our instructions.

International Transfers

Where appropriate for certain client matters, we may use service providers located outside the EEA. For example a matter we are advising on may require input from local experts. When we transfer personal data to such service providers it will usually be on an ad hoc basis, and in accordance with instructions from our clients.

Where the recipient is located in a country which has not been deemed by the European Commission to have adequate laws in place to protect it, we transfer the personal data using one of the following measures:

where we use certain service providers on a recurring basis, we will seek to incorporate into our agreements with them such Standard Contractual Clauses approved by the European Commission, which give personal data the same protection it has within the EEA. For more information on Standard Contractual Clauses, see European Commission: Standard Contractual Clauses.
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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Data Security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those clients, employees, agents, contractors and other third parties who have a business need to know. They will only process such personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify data subjects and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may anonymise the personal data we hold (so that it can no longer be associated with an individual) in which case we may use this information indefinitely without further notice to the data subject.

Data Subjects’ Legal Rights

Under certain circumstances, a data subject has rights under data protection laws in relation to their personal data.

No fee usually required

A data subject will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if we receive a request which is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with such a request in these circumstances.

What we may need

We may need to request specific information from a data subject exercising their rights to help us confirm their identity and ensure their right to access their personal data (or to exercise any of their 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 the requesting data subject to ask for further information in relation to their request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if a request is particularly complex or there are a number of requests. In this case, we will notify the data subject and keep them updated.

GLOSSARY

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give our clients the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on data subjects (both positive and negative) and their rights before we process their personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on a data subject (unless we have their consent or are otherwise required or permitted to by law). Further information about how we assess our legitimate interests against any potential impact on data subjects in respect of specific activities can be obtained by contacting us.

Performance of Contract means processing the personal data where it is necessary for the performance of a contract or any necessary steps prior to entry into such contract.

Comply with a legal or regulatory obligation means processing personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties

Our clients for whom we are providing our research services.
Our consultants who act as subcontractors for some of our research services.
Service providers acting as processors based inside EEA who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.

DATA SUBJECT LEGAL RIGHTS

Data subjects have the right to:

Request access to their personal data (commonly known as a "data subject access request"). This enables them to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
Request correction of the personal data that we hold about them. This enables a data subject to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data the data subject provides to us.
Request erasure of their personal data. This enables a data subject to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Data subjects also have the right to ask us to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal data to comply with law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to a data subject where relevant, if applicable, at the time of their request.
Object to processing of their personal data where we are relying on a legitimate interest (or those of a third party) and there is something about a data subject’s particular situation which makes them want to object to processing on this ground as it impacts on their fundamental rights and freedoms. They also have the right to object where we are processing their personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which override such rights and freedoms.
Request restriction of processing of their personal data. This enables them to ask us to suspend the processing of their personal data in the following scenarios: (a) if they want us to establish the data's accuracy; (b) where our use of the data is unlawful but they do not want us to erase it; (c) where they need us to hold the data even if we no longer require it as they need it to establish, exercise or defend legal claims; or (d) they have objected to our use of their data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of their personal data to them or to a third party. We will provide to them, or a third party they have chosen, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which a data subject initially provided consent for us to use or where we used the information to perform a contract with them.
Withdraw consent at any time where we are relying on consent to process personal data. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn.