We at Haponey Ltd t/a DataProExpert – understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our website and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our website. If you do not accept and agree with this Privacy Policy, you must stop using our website immediately.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site.

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our Site. This definition shall, where applicable, incorporate the definitions provided in the UK General Data Protection Regulation (“UK GDPR”); and Data Protection Act 2018.

Controller of your data – We/Us/Our” means: Haponey LTD based in:6 Petal Place, Coventry, CV21DY, UK with ICO registration number: ZB528665

1. What Does This Policy Cover?

This Privacy Policy applies only to your use of our website and our educational services. Our website may contain links to other websites. Please note that we provide such links for your convenience and for informational purposes only. We do not endorse or approve any of the products, services or opinions on such other websites. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

2. Data Protection Officer / EU Representative

Controller company appoint as a Data Protection Officer and EU Representative:

Agata Mazur – Polish Qualified Lawyer, email:


Mrs Agata Mazur (Polish Qualified Lawyer) with address: Street: Widok 89/80, City: Kalisz, Post code: 62-800, Country: POLAND.

3. What Data Do We Collect? 

3.1 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

3.2 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

3.3 Our cookies policy, which can be viewed from the home page, describes in details how we use cookies.

4. How Do We Use Your Data? 

4.1 All personal data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected – maximum six years from the date of the performance of the contract. 

We will comply with our obligations and safeguard your rights under the GDPR / UK GDPR at all times.

4.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you (e.g. by placing an order with us – art. 6 (1b) UK GDPR), or it is necessary for compliance with a legal obligation to which the controller is subject (art. 6 (1c) UK GDPR), or it is necessary for the purposes of our legitimate interests – for example, personal data needed to contact you, answer your questions and consult your problem via online meetings or phone conversation (art. 6 (1f) UK GDPR).

Specifically, we may use your data for the following purposes:

4.2.1 Providing and managing your access to our website;

4.2.2 Personalising and tailoring your experience on our website;

4.2.3 Supplying our service to you (please note that we require your personal data in order to enter into a contract with you);

4.2.4 Replying to emails from you.

5. How Long We Store Your Data? 

5.1 We only keep your personal data for as long as we need to use it as described above in section 4, and/or for as long as we have your permission to keep it or maximum 6 years after completing your order. Personal data collected for contact purposes will be stored no longer then 12 months from last contact with you.

5.2 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.

6. Your Rights 

6.1 As a data subject, you have the following rights under the UK GDPR, which this Policy and our use of personal data have been designed to uphold:

6.1.1 The right to be informed about our collection and use of personal data;

6.1.2 The right of access to the personal data we hold about you;

6.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete;

6.1.4 The right to be forgotten – i.e., the right to ask us to delete any personal data we hold about you;

6.1.5 The right to restrict (i.e., prevent) the processing of your personal data;

6.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

6.1.7 The right to object to us using your personal data for purposes; and

6.1.8 Rights with respect to automated decision making and profiling.

6.2 This Policy and our internal procedures applicable to employees and associates of the company – always aim to protect your personal data.

6.3 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 10 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office –

7. Do We Share Your Data? 

7.1 We may also sometimes contract with other third parties to supply goods and services to you on our behalf. These may include, IT service provider, payment processors, search engine facilities, mail service provider and sub-contractors. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

7.2 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

7.3 We may sometimes use third party data processors that are located outside the UK, but in the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR.

7.4 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

8. Your Right to Withhold Information 

8.1 You may access certain areas of our website without providing any data at all.

8.2 You may restrict our use of Cookies. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently.

9. How Can You Access Your Data? 

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details using the contact details below in section 10.

10. Contacting Us

If you have any questions about our website, please contact us by email at:

Please ensure that your query is clear, particularly if it is a request for information about the data, we hold about you.

11. Changes to Our Privacy Policy 

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up to date.

Issue date 01.01.2022 r.

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