In this document (“Privacy & Data Policy”) Fifty High Street Limited (“Hole & Corner” / “We”), as otherwise identified in its website, explains how Hole & Corner uses data and handles privacy and why and how Hole & Corner collects and uses information. We also cover the choices available to you in accordance with your rights as a data subject and its obligations. This document reflects policy as from 25 May 2018. “You” means anyone reading this document, who may be a customer (or customer), prospective customer, a business interaction party, or visitor to the website.
Hole & Corner is a UK business providing a broad range of print and digital publishing services, specifically in respect of the periodical magazine Hole & Corner, as well retail services and specific services to customers with whom it enters into contracts as such within its sectors of activity. In referring to “Services” or Hole & Corner’s activities we are referring to our day-to-day business in those sectors, including in meeting the needs of Hole & Corner’s existing and prospective customers, those it communicates and interacts with for its business purposes, or because those parties have expressed interest in our business, and the need for maintenance of books and records.
Hole & Corner complies with requirements of privacy and confidentiality, and with applicable data protection legislation, including, previously, the Data Protection Act 1998 (“DPA”) and now the EU General Data Protection Regulation, or GDPR, effective 25 May 2018.
Hole & Corner determines data management practices and safeguards according to the above stated purposes and is controller of all relevant information along with GDPR compliant data processors. Hole & Corner’s guiding principle is only to use information fairly and for the bona fide purposes of its business doing so at all times with regard to the consent obtained from you and your instructions in relation to the use of information.
Information which Hole & Corner may hold or retain
- Customer Data
– Information which you supply to Hole & Corner in the exercise of your choice to do so for the purposes of enquiry or contract, which may include certain information which Hole & Corner requests, which may be compulsory or not. In general, compulsory information is oriented towards establishing a proper basis for contractual relations, for example, as to customer or contact identity, address (necessary for financial processing and also delivery), usual contact information, including email and at least one active telephone number, and necessary age particulars, and non-compulsory information is oriented to Hole & Corner’s better understanding customer needs and preferences including, where the customer wishes it, marketing communications – all of this is “Customer Data”.
– You should be aware that all businesses may be required in specified circumstances to report to the police or other relevant authorities’ activities regarded to be criminal, otherwise unlawful or potentially so, including in relation to so-called identify fraud, and that your rights and Hole & Corner’s obligations to you in respect of Customer Data or otherwise, may be subject to and overridden by public interest and our obligation to comply with the investigations and enquiries of proper authorities.
– Hole & Corner will only hold Customer Data which you provide with your consent. Hole & Corner may reasonably assume consent on a continuing basis where you engage Hole & Corner or subscribe to one or other of its Services or publications and the relevant contract has not been terminated.
– In respect of marketing Hole & Corner believes that many people may be interested in information about Hole & Corner’s activities, products and Services, and other related information, whether a customer of Hole & Corner or not. Accordingly, we offer the opportunity to sign up to receive newsletters from us as well as other communications in respect of material which we believe may be of interest to you. Such marketing activities by us are always subject to your explicit consent and you may at any time unsubscribe from our mailings altogether or modify your preferences. We do not provide your personal information to external organisations (businesses other than Hole & Corner) for their own marketing purposes without your explicit consent.
– For the purposes of the proper running and administration of Hole & Corner’s business, including accounting, we may handle, including via a data processor, the following “Other Information”:
- Information relating to work undertaken specific to a customer, e.g. time/task recording;
- Financial information relating to retainer, invoicing and payment. Hole & Corner may collect and store billing address and credit card information but only in compliance with applicable legislation or regulation and with your permission;
- Information relating to visits to Hole & Corner’s web services and other activities connected with the Services. This may include information about how you are accessing and using the Hole & Corner’s website and the Services, including past work, administrative and support communications, including in respect of any complaints, and how you engage with features, content, and any links, and what integrations and embeds you use (in so far as Hole & Corner operates them);
- Contact information, including any you elect to share with us by way of any application (e.g. by way of so-called “sharing”);
- Log data. This is information compiled, for example, whenever you visit a website, or your mobile app sends and receives data as you use it. This log data may include your so-called Internet Protocol address, the address of the web page or pages you visited before accessing Hole & Corner’s Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data. This list is not exhaustive;
- Geo-location information. Precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location;
- Third-party data. Hole & Corner may also receive information from our trading partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed;
- In respect of Other Information, Hole & Corner will always respect such rights as you may exercise to block, restrict or manage information as set out above, including by way of settings in your relevant device/s.
– You should be able to clear and reset your browsing history and cookies within your own devices settings. This may require you to re-confirm agreements as to cookies and our website terms and conditions next time you visit the Hole & Corner website.
How we use your information
Hole & Corner uses your information to provide, maintain and improve the Services and in protecting, enhancing and administering its business.
- Customer Data
Hole & Corner accesses and makes reasonable use of Customer Data in accordance with the terms of a customer’s consent and instructions, and applicable terms and conditions, in order to (a) provide, maintain and improve the Services, (b) address service, security, technical issues or in accordance with a customer’s request for assistance or support, or in addressing any grievance or complaint (c) comply with the law or any lawful data request or instruction and (d) to service any matter arising from Hole & Corner’s terms and conditions from time to time in accordance with them. This Hole & Corner does in accordance with its statutory and contractual security and confidentiality obligations.
- Other Information
Hole & Corner uses Other Information for the following purposes, to:
– improve and better understand its business and the Services, including through selective surveys and other research to analyse and understand how Hole & Corner Services are being used and our products seen in terms of quality and customer satisfaction;
– To communicate with you and other parties by for example:
- Responding to your requests, if you contact Hole & Corner with a problem, query or question, Hole & Corner will use available information, including any you give, to respond;
- Sending emails and messages. Hole & Corner may send you Services and administrative emails and messages. Hole & Corner may also contact you to inform you about changes in the Services, its Service offerings, and important notices related to the Service and the website, such as in relation to security, fraud and data breach. These emails and messages are an essential part of the Services and our mutual interests and you may not opt-out of them other than by terminating Hole & Corner’s contract. Hole & Corner occasionally may send emails about new product features or other news about its business. You may opt out of these at any time if you are a person;
– Manage billing and account systems and records. Hole & Corner uses account data, including typical products and services supply and project management software packages to administer accounts, customer projects and to keep track of billing and payments;
– Conduct marketing exercises – you may opt out of these at any time;
– Investigate and prevent abuse and security breaches;
– This policy is not intended to place any limits on what we do with data that is aggregated and/or de- identified so it is no longer associated with an identifiable customer or other data subject – in other words information which is a general nature and not specific to your identity or Customer Data.
- Customer Data
Subject to retaining information necessary to maintain an active customer account, Hole & Corner will always respect your wishes in relation to Customer Data. Hole & Corner has only basic and simple records, so there is no self-management of your customer profile. You may always elect to close your account or advise Hole & Corner by email, telephone or through the ‘CONTACT’ page as to your particular requests or instructions.
- Other Methods for Choice
Many browsers have functions which provide you with privacy, security and control tools, for example in relation to cookies and other aspects of data storage. Your mobile device will include a broad range of settings options for you tailor what the device and your use of it may reveal to other parties, for example, location data and notifications. These controls are not within our remit or control and are matters of your preferred use of options available to you in your particular devices operating systems and installed apps. If we offer any mobile device app, it will be subject to this Privacy & Data Policy.
- Other information
If you have any questions about our use of Other Information you may contact Hole & Corner at any time with your enquiry.
Sharing and Disclosure
On occasion information described in this Privacy & Data Policy may be shared by Hole & Corner.
- Customer Data
Hole & Corner may share Customer Data in accordance with any agreement with any customer and the customer’s instructions, and this may be with third party service providers and agents. Hole & Corner may engage third party companies or individuals to process Customer Data on its behalf. Hole & Corner may combine with other businesses and partners in conducting business and delivering services. Hole & Corner may for the purposes of its business and in servicing customers integrate elements into its platforms and customer resources, which may include integrations added by a customer or by someone else with the customer’s consent.
Hole & Corner does not assume responsibility for and has no liability in respect of the use of third parties of information which is not gathered directly from Hole & Corner or which is provided by the choice of the customer or other relevant business partner.
- Other Information
Hole & Corner may share Other Information in the lawful operation of its business and other legitimate purposes, and for purposes of assessment and review of quality control and performance indicators and in order to resolve any issue or controversy that arises between Hole & Corner and a customer or otherwise in connection with or because of our business. Hole & Corner may use third parties to process and analyse Other Information.
- Other Disclosures
Below are examples of when Hole & Corner may otherwise disclose Customer Data and Other Information which may occur:
– During changes to Hole & Corner’s business structure, for example if it engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets, financing, acquisition of all or a portion of its business, a similar transaction or proceeding, or steps in contemplation of such activities (including so-called “due diligence”);
– To comply with applicable laws and regulations or to confirm to any code of practice or conduct to which the firm is subject, including in relation to proper and valid requests for disclosure, or the requirements of a court order or police or other authority’s investigation;
– To enforce Hole & Corner’s rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of Hole & Corner or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud;
– In the case of aggregated or de-identified information, then for any purpose. For example, Hole & Corner may share aggregated or de-identified information for bona fide business or research purposes.
General Policies / Further information
Hole & Corner takes security seriously and has appropriate and up to date systems to protect information you provide to us from loss, misuse, and unauthorised access or disclosure and ensures the same is the case with its own service providers. These systems take into account the sensitivity of the information we collect, process and store, and the current state of available technology having regard to the nature, size and scale of Hole & Corner’s business from time to time. Details of Hole & Corner’s prevailing security practices may be requested at any time by any party entitled to make such a request.
Hole & Corner will only enter into customer relations with persons over the age of 18 at the relevant point of contract, unless the lawful parent/s or guardian/s with appropriate authority confirm otherwise and provide all required GDPR-compliant consents. For this reason, Hole & Corner will neither hold nor process any information relating to such persons other than on the same basis. In the event that Hole & Corner discovers that any account has been opened with it in breach of this policy, Hole & Corner will take appropriate steps, including in respect of safeguarding and closure of the account.
- Changes to this Privacy & Data Policy
Hole & Corner may change this Privacy and Data Policy from time to time, and if it does so it will post any changes on this page. If you use the Services or deal with Hole & Corner after those changes are in effect, you will be deemed to have agreed to and accepted the revised policy.
- More questions?
Please also feel free to contact Hole & Corner if you have any questions about this Privacy & Data Policy or Hole & Corner’s associated practices.
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Senior Data Manager contact: firstname.lastname@example.org