Privacy and Cookies Policy

Introduction

HH Global respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important information and who we are
Purpose of this privacy notice

This privacy notice aims to give you information on how HH Global collects and processes your personal data through your use of this website, including any data you may provide through this website. This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

HH Global applies the UK GDPR as a global privacy standard together with global data protection law in the countries where it operates. In countries where the UK GDPR conflicts with local law, local law that meets internationally accepted privacy principles will take precedence.

Data Controller

HH Global is made up of different legal entities. This privacy notice is issued on behalf of the HH Global Group so when we mention “HH Global”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the HH Global Group responsible for processing your data. HH Global Ltd is the data controller.

If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the data protection department using the details set out below.

Contact details

Our full details are:

HH Global Ltd
Data.Protection@hhglobal.com
Grove House, Guildford Road, Leatherhead, KT22 9DF, United Kingdom.

+44 208 770 7300

You have the right to make a complaint at any time to your supervisory authority – e.g. the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so, please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you such as the details listed below:

• First name;
• Last name;
• Job title;
• Company;
• Email address;
• Location, as detected by IP address;
• Telephone number; and
• Which topic you are interested in contacting us about in a freeform message field.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. How is your personal data collected?

• Direct interactions. You may give us your personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and it is not disproportionate to your interests and fundamental rights.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. However, where we do, you have the right to withdraw consent to marketing at any time by contacting us at Data.Protection@hhglobal.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate (having undertaken legitimate interest assessments).

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us

We may use your identity, contact, technical, usage and profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the HH Global Group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at Data.Protection@hhglobal.com.

Cookies
Cookies are small text files that can be used by websites to make a user’s experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Why we use cookies

Necessary
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Preferences
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Statistics
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Unclassified
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

We do not use the information captured for any other purpose. 

How do I control what cookies are used? 

You can change your cookie preferences at any time by visiting the HH Global website and selecting “Cookie Settings” option at the bottom of the website. 

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out more about how to manage cookies on the Information Commissioner’s Office website. 

You can opt out of being tracked by Google Analytics across all websites by visiting this page on Google. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

All exports of data from within the European Economic Area (EEA) to non-EEA countries (referred to in GDPR as ‘third countries’) are unlawful unless there is an appropriate ‘level of protection for the fundamental rights of the data subjects. Transferring personal data outside of the EEA is prohibited unless one or more of the specified safeguards, or exceptions, apply:

An Adequacy Decision

The European Commission can and does assess third countries, and territories and/or specific sectors within third countries to assess whether there is an appropriate level of protection for the rights and freedoms of natural persons. In these instances, no authorisation is required.

Countries that are members of the EEA but not of the EU are accepted as having met the conditions for an adequacy decision.

A list of countries that currently satisfy the adequacy requirements of the Commission is published in the Official Journal of the European Union.

https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-transfers-a-guide/#:~:text=In%20August%202021%2C%20the%20UK,%2C%20Indonesia%2C%20Kenya%20and%20Singapore.

Where an adequacy decision is not in place, we will put adequate safeguards in place to ensure that your personal information remains protected in a manner that is consistent with how it would be protected under UK and EU data protection laws. for example, by agreeing standard contractual clauses adopted by the European Commission/ UK Government and undertaking a risk assessment in relation to the importing country.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at Data.Protection@hhglobal.com or complete the following webform.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Privacy Notice for U.S. Residents

For U.S. residents, click here to read our Privacy Notice for U.S. Residents.

 

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our cookie bar on our website allows you to accept all or deny all cookies as well as allowing for user preferences to be made on the use of cookies beyond essential. You can read more about how we use cookies, and how to delete or reject them, on this Cookies page.

Cookies used on this website

Necessary (4)