1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data.
Various companies within the Hurstwood and Crystal Group of Companies is the data controller and we are responsible for your personal data (referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).
Our email address is info@hurstwoodholdings.com and our postal address is 40 Peter Street, Manchester, M2 5GP.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you could contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing info@hurstwoodholdings.com.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are :
• Where we need to perform the contract between us
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email.
Purposes for processing your personal data
Set out below is a description of the ways we may use your personal data and the legal grounds on which we will process such data if we do so. We have also explained what our legitimate interests are where relevant.
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 email info@hurstwoodholdings.com 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.
Marketing communications
You will receive marketing communications from us if you have:
(a) Requested information from us or purchased goods or services from us; or
(b) If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
(c) In each case, you have not opted out of receiving that marketing.
We may use personal information we collect from you, such as age, gender, interests. In order to understand your behaviour and provide you with the best content and service possible, this is called Remarketing.
The second process we use is to target our advertisements based on all the information we have collected, through the use of automated cookies.
You can opt out of Cookies at any time by visiting your browser settings.
You can ask us to stop sending you marketing communications at any time by clicking on the unsubscribe option contained within those emails. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a purchase, experience or other transactions.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
3. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:
• Service providers who provide IT and system administration services
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
4. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA)
5. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of breach where we are legally required to do so.
6. DATA RETENTION
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 unauthorized use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• 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
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email info@hurstwoodholdings.com.
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.
We may need to request specific information from you to help us confirm your identify 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.
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.