HALEBURY PRIVACY STATEMENT

Halebury Ventures Limited (“we”/”us”/”our”) are committed to protecting and respecting your privacy. We endeavour to tell you what information about you we have collected, why we have collected it and what we will do with it. You can always contact us with questions about our use of your personal information at the details below in Contact Us.

This statement (together with Terms of Use and any other documents referred to on it) sets out the basis on which we collect any personal data from you, why we collect it, who we share it with, how we use it and how we protect it.  We want you to understand clearly our views and practices regarding your personal data and how we will treat it, so please read the following carefully.

Identity of the data controller –  for the purpose of the Data Protection Act 1998 and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679 and other related regulations (“GDPR”) as enacted into UK law, the data controller is Halebury Ventures Limited, a company registered in England and Wales with number 4797938 of registered office: WeWork – The Cursitor, 38 Chancery Lane, WC2A 1EN.

1. WHAT INFORMATION WE COLLECT

We may collect and process the following information about you:

1.1 Personal data we collect directly from you:

  • Information that you provide by filling in forms on our site www.halebury.com (“our site”). This includes information provided at the time of registering to use our site, or enquiring about our services, posting material or requesting further services. We may also ask you for information when you register for events that we or our partners host and when you register for our newsletters or when you report a problem with our site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of transactions you carry out through our site and of the fulfilment of your orders.
  • Details of your visits to our site, social media platforms, on landing pages and over the telephone including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

When we collect personal data directly from you through our website, on social media platforms, on landing pages and over the telephone we use the data you provide for the following purposes:

  • To fulfil our contract with you or your employer to provide you with services you have requested, and in particular:
    • to issue credentials, including passwords to allow you to access and operate your account
    • to contact you about your subscription and to provide customer support services to you
    • to carry out credit checks, to invoice you or your employer for any services you subscribe to and to collect payments due
  • For our own legitimate interests in:
    • maintaining our own records and databases
    • monitoring use of our products and services to ensure usage is in accordance with our terms and conditions of use
    • informing our business customers and potential customers about our products and services

1.2 Other sources of personal data:

We also receive personal data from other sources which include:

  • Service providers that help determine your location based on your IP address in order to customise certain products to your location
  • Publicly available sources
  • Information generated by your usage of our products and services
  • Information generated by the use of cookies on our website. You can read our Cookies Statement below. This information may include information about your computer, including where available your IP address, operating system and browser type and for system administration.. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

The data we collect in this way may include the following:

  • Name and contact data, including first and last name, email address, work postal address and similar contact data
  • Demographic, including country, city and preferred language

We use this personal data for the following purposes:

  • For our own legitimate interests in monitoring usage of our services and improving the service provided to our customers
  • Subject to your consent to receive this information, informing prospective customers about our products and services
  • To carry out our obligations arising from any contracts entered into between you and us
  • To ensure that content from our site is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may interest you
  • To allow you to participate in interactive features of our service, when you choose to do so
  • To notify you about changes to our service
  • To contact you with information about our products, services or events electronically from time to time


If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data (the registration form), click unsubscribe on the relevant material or contact us to request no further information on our products, services or events be sent to you.  See Contact Us below.

COOKIES STATEMENT

We use cookies on this site. A cookie is a piece of stored data on the system of a visitor to a site. Cookies help us improve your access, identify repeat visitors to this site and can also enable us to track and target interests of our site visitors to enhance their experience on our site.

The cookies we use are: Google Analytics, which tracks how many people visit our site, what they do, how they got to our website, which pages they visit and the technology they are using to view our site but all of that information is anonymous and we cannot access contact or personal details of individual users; and Twitter, which helps our website know which tweet we are showing on our website to make sure you are seeing our latest tweet in the feed on the website. It does not allow us to identify people or collect personal data.

You can disable or remove any cookies stored on your computer but these may prevent our website from functioning properly.

We do not sell our use our cookie data for third party marketing.

2. WHO HAS ACCESS TO AND WITH WHOM WILL WE SHARE YOUR INFORMATION

2.1 We do not sell your personal information to third party companies.

2.2  Who has access to your personal data?

We transfer personal data to the following categories of recipients:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
  • Companies whom we appoint under contract to host our services
  • Companies or individuals whom we appoint to provide services to us which include processing personal data
  • Actual or potential business partners who need access to personal data to evaluate or carry out a business relationship or to conclude a transaction with us
  • Entities with whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use http://www.halebury.com/terms/ and other agreements; or to protect the rights, property, or safety of Halebury, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

2.3  Transfers to other countries

Some of our processors are located in countries outside the European Economic Area (EEA).  Currently these countries are the USA and Canada.

2.4 Security and Safeguards

  • All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Where you make payment via a third party, you will be subject to the terms and conditions and privacy statement of that third party.
  • The safeguards we have put in place to ensure that our contractors and other third parties keep your personal data secure and confidential and use it only as authorised by us are as follows:
    • We require all third parties to whom we disclose personal data to enter into a contract with us that includes confidentiality obligations.
    • We carry out such due diligence as is reasonably necessary in relation to the technical and organisation measures used by our suppliers to ensure that personal data is processed securely.
    • We use data processors located outside the EEA only after taking such steps as are required to ensure that personal data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or are in countries deemed by the EU to offer an adequate level of data protection or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov and to learn more about the countries deemed adequate, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

2.5. Retention period for personal data

We retain personal data for as long as your account or contract for services is live with us or for the period needed to provide you our services or to comply with our legal obligations, resolve disputes and enforce our agreements. After that time, unless there is a need to retain that data for purposes connected with protecting our interests or those of third parties we will erase all data other than that needed to comply with our statutory obligations.

3. YOUR RIGHTS

3.1 You have the following rights in relation to your personal data:

  • Our use of your email address for marketing purposes is subject to your consent and you have the right at any time to withdraw that consent by using the ‘unsubscribe’ button at the bottom of one of our marketing emails or contacting us at the Contact Us details below.
  • You have the right to update and correct the personal information we hold about you. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data or object to continued processing where it is excessive or no longer required for the purpose for which it was collected. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You may also have the right to data portability. You can contact us at the Contact Us details below.
  • If you have a complaint about the way in which we use your personal information you have the right to complain to the Information Commissioner, www.ico.org.uk

3.2 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy statements and that we do not accept any responsibility or liability for these statements. Please check these statements before you submit any personal data to these websites.

4. CHANGES TO OUR PRIVACY STATEMENT

This Privacy Statement will be updated from time to time to reflect changes in our business.

5. CONTACT US

If you have any questions about anything in this Privacy Statement please contact us at the below email, mail or telephone number.

Email:              privacy@halebury.com
Mail:                WeWork – The Cursitor, 38 Chancery Lane, WC2A 1ENTelephone:       +44 (0) 207 127 2500

Last revised: 16 May 2018

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