The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.
Issue Date: 01/01/2021
Name of company
HAPONEY LTD – UK Company
UK, 54 The Boxhill, Coventry, CV3 1ES
EU – Representative: POLAND, Widok 89/80, 62-800 KALISZ
Director: Agata Mazur Polish Qualified Lawyer
Mrs Agata Mazur (Polish Qualified Lawyer) with address:
street: Widok 89/80
post code: 62-800
Collection of personal data
We collect personal data (name and surname, email address, phone number) from you for one or more of the following purposes:
- To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
- To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
- To ensure the security and safe operation of our websites and underlying business infrastructure.
- To manage any communication between you and us.
In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
- Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
- Your login information, browser type and version, time zone setting, browser plug-in types and versions.
- Operating system and platform.
- Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through, and from our site.
Methods of processing
The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Company.
The updated list of these parties may be requested from the Company at any time.
Legal basis of processing
The Company may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Company is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
The Data is processed at the Company operating offices and in any other places where the parties involved in the processing are located.
All of our websites and web applications are hosted in the EU and US and are accessed only by our EU-based staff.
- In all these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected.
- Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU-US Privacy Shield Framework.
- We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
- Unless we specifically state otherwise, all the CSPs that we use utilise EU-located processing facilities.
Personal data will be processed – Maximum six years from the date of the performance of the contract.
If we collected your personla data as a free member of any of our website – until you are using our website free service, not longer the Six months after your user account is left unused.
Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights.
If you wish to exercise any of these rights, please email email@example.com
To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
- The right to be informed
- The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
- The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- a) The accuracy of the personal data is contested.
b) Processing of the personal data is unlawful.
c) We no longer need the personal data for processing but the personal data is required for part of a legal process.
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
- The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
- The right to object
You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research; or
- Processing involves automated decision-making and profiling.
It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Company shall collect new consent from the User, where required.
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the UK, this is the ICO (Information Commissioner’s Office), which is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.
Issue Date: 10/11/2020
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CONTROL OF COOKIES
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OTHER TRACKING TECHNOLOGIES
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.