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PRIVACY AND COOKIES POLICY

Introduction

Welcome to the HH Global Ltd Privacy and Cookie Policy 

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 when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This policy describes how we treat personal information we collect from you or that you provide to us.

By visiting this website or otherwise interacting with us, you will be subject to (and as legally permitted are accepting and consenting to) the practices described in this policy.

For the purposes of international data protection laws, various HH Global entities may be the data controller and the contact information for these entities is located here.

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 controller and responsible for this website. 

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 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 ICO so please contact us in the first instance. 

We collect information from and about you.

Contact and account information. For example, we might collect your name and street address. We might also collect your phone number or email.

Payment and billing information. For example, we may collect your credit card number and zip code/postcode when you purchase products or services.

Submitted information. If you post content or complete a survey, we will collect the information you provide to us.

If you use our websites, we may collect technical information including your:

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.

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. 

We use information as disclosed and described here

Our legal basis for processing under European law. European legislation requires us to identify a lawful basis for everything we do with your information (as described above). When European law applies, our basis for processing your information is typically to perform a contract with you or our customer. We also process information based on consent.

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:

Generally HH Global 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. 

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 

We collect information in different ways.

We collect information you give to us. For example, we collect information if you register for an account or make a purchase. We might also collect information if you post a comment, make a request, or complete a survey.

We collect information about you passively. We use tracking tools like browser cookies and web beacons to distinguish you from other users of our site and to help us to improve our site and services.

We get information about you from other sources. 

Third parties we work with may give us contact information about you. These third parties might include business partners and service providers and may also include advertising and analytics providers. Social media platforms may also give us contact information about you.

We combine information. 

We may combine information that we have collected offline with information we collect online, or, combine information we get from a third party with information we already have.

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. 

We use information as otherwise permitted by law.

European legislation requires us to identify a lawful basis for everything we do with your information (as described above). When European law applies, our basis for processing your information is typically to perform a contract with you or our customer. We also process information based on consent.

We will share your information with others.

We will share your information within the HH Global family of companies. This includes contact and account information with our current and future subsidiaries, affiliates, and our parent company and its subsidiaries.

We will share your information with vendors who perform services on our behalf for a business purpose. For example, we share information with vendors who help us manage our online account registration process or who fulfill your purchases.  We also share information with third parties like advertisers and advertising networks that assist us in marketing and advertising our products or services. We may also share contact and site usage information with analytics and search engine providers.

We may share your information if we think we have to in order to comply with the law or to protect ourselves, our customers or others. For example, we may share information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. We might also share your information in order to enforce our Terms of Use and other agreements, and to protect the rights of others. We might also share information when we are investigating potential fraud.

We may share your information with any successor to all or part of our business. For example, if part or all of our business or assets are sold, we may disclose our customer list as part of that transaction. Where legally required we will give you prior notice and if you have the legal right to do so, allow you to object.

We may share information for other reasons we may describe to you as permitted by law.

You have certain choices about how we use your information.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us and select the unsubscribe link. You can also exercise this right at any time by contacting us. Don’t worry, even if you opt out of getting marketing messages, we will still be sure to send you responses to information you have requested.  

You can control certain cookies and tracking tools. To learn how to manage how we – and our vendors – use cookies and other tracking tools, please see below under the heading of 'Cookies'.

California Consumer Privacy Act

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

We use standard security measures.​

HH Global is ISO 27001:2013 certified and takes commercially reasonable measures to protect your data. HH Global also requires our service providers to adopt such measures. However, the Internet is not 100% secure. Any transmission of your data to our site is at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

HH Global keeps personal information as long as it is necessary or relevant for the purpose for which it was collected and in compliance with our data retention policies. We also keep information as otherwise required by law.

We process information both in and outside of the United States.​

Information we collect from you may be transferred to, or stored at, a destination in the United States or another destination outside of the European Economic Area (“EEA”). This might include HH Global entities located outside of the EEA. It may be processed by staff operating in these locations who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. When your information is transferred from inside the EEA to a third party outside the EEA, we put in place appropriate safeguards to protect your information.  Those safeguards may include standard data protection clauses approved by the European Commission and available on their website at EUR-Lex.

We may link to third party sites or services we do not control.

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.

Our site may also serve third party ads or content that contains third party cookies or tracking technologies. We do not control the use of those technologies.

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal 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 our Data Protection Team 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. 

Your legal rights

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

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. 

If you wish to exercise any of the rights set out above, please contact our Data Protection Team.

What we will do if there is an update to this policy.

From time to time we may change our privacy practices. Please check our site periodically for updates.

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.

COOKIES

We use common tracking technologies.

We collect personal information about users over time and across different websites. Information is collected when you visit one of our websites or utilize our services. We also have third parties that collect personal information this way. To collect information, we use several common tracking tools, including browser cookies, web beacons, flash cookies, and similar technologies. Our vendors may also use these tools.

By continuing to browse the site, you are agreeing to our use of cookies and other tracking technologies.

What are Cookies?

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We may use the following cookies:

Please note that third parties (such as advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

We use tracking technologies for a variety of reasons.

We use tracking tools:

How do we gather relevant information about you

To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. 

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.

The Cookies we set 

This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

When you submit data to us through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.

Third Party Cookies 

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

For more information on Google Analytics cookies, see the official Google Analytics page.

We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Twitter and YouTube, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

You can control certain cookies.

Your browser may give you the ability to control certain cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop.

How do we gather relevant information about you for interest-based advertising?

To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your purchases or browsing behaviors. These activities may be viewed on our platforms or the platforms of others.

We work with third parties who help gather this information. These third parties might link your name or email address to other information they collect.  This might include past purchases made offline or online, and online usage information.

​​Some ads may be served based on tracking.

We may work with online advertising companies to show you relevant and useful ads. This may include ads served on our own websites or apps. This may also include our ads served on other companies’ sites. 

These ads may be based on information collected by us or third parties (for example, when you register for a site). These ads may also be based on your activities on our websites or on third party sites (also known as “online behavioural advertising”).

You can opt-out of online behavioral advertising.

The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. To opt out of having your online activities tracked for behavioral advertising purposes, click here. Choices you make are both browser and device-specific.