PRIVACY NOTICE & COOKIE POLICY

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

Registered office

UK, 54 The Boxhill, Coventry, CV3 1ES

EU – Representative: POLAND, Widok 89/80, 62-800 KALISZ 

Contact details

Director: Agata Mazur Polish Qualified Lawyer

email: info@dataproexpert.com

EU-Representative:

Mrs Agata Mazur (Polish Qualified Lawyer) with address:

street: Widok 89/80

City: Kalisz

post code: 62-800

Country: POLAND

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.

Technical information

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.

Our cookies policy, which can be viewed from the home page of each of our web sites, describes in detail how we use cookies.


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.

Place

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.

Retention time

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 info@dataproexpert.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
    As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
  • 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:
  1. 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:
  1. 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.

Changes to this privacy policy

The Company reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Company.

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.

Complaints

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/.


Cookie Policy 

Issue Date: 10/11/2020

INTRODUCTION

Our website may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit this website, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customize the Site and improve your experience.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.

USE OF COOKIES

A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.

TYPES OF COOKIES

The following types of cookies may be used when you visit the Site:

Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

Analytics Cookies

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our Cookies

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

Personalization Cookies

Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

Site Management Cookies

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

Third-Party Cookies

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

CONTROL OF COOKIES

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.

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.

PRIVACY POLICY

For more information about how we use information collected by cookies and other tracking technologies, please refer to our Privacy Policy posted on the Site. This Cookie Policy is part of and is incorporated into our Privacy Policy. By using the Site, you agree to be bound by this Cookie Policy and our Privacy Policy.

CONTACT US

If you have questions or comments about this Cookie Policy, please contact us at:

info@dataproexpert.com