Holden Jones Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.holdenjones.com and www.holdenjones.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of OurSite;|
|“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. Details of the Cookies used by OurSite are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2. Information About Us
Our Site is owned and operated by Holden Jones Limited, a limited company registered in England under company number 03094909.
Registered address: Sienna Court, Broadway, Maidenhead, Berkshire, SL6 1NJ.
Data Protection Officer: Emma Donnison.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by usis inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that wehold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we arerelying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information aboutour use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data wehold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about ouruse of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. Wewould welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
|Data Collected||How We Collect the Data|
|Identity Information including name, title.||By form submission.|
|Contact information including address, email address, telephone number.||By form submission.|
|Business information including business name, job title, profession.||By form submission.|
|Technical information including IP address, browser type and version, operating system.||By cookie.|
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how wemay use your personal data, and our lawful bases for doing so:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with ourobligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long [We] OR [I] Keep It|
|Identity Information including name, title, date of birth, gender.||seven years.|
|Contact information including address, email address, telephone number.||seven years.|
|Business information including business name, job title, profession.||seven years.|
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
10. How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, whenyou submit personal data via Our]Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from uswhich you may do by unsubscribing using the links provided in our emails).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Can I Withhold Information?
You may access certain areas ofOur Site without providing any personal data at all.However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask usfor details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
14. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Emma Donnison)
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.