BACKGROUND
This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. 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 Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
As of 25 May 2018, the EU General Data Protection Regulation 2016/679 (GDPR) has taken effect for the protection of natural persons against the processing of personal data and the free circulation of such data. The New General Regulation replaced the Directive 95/46/EU which was applied via law 138(I)/2001.
More information may be obtained from the European Commission’s relevant website here.
Our role as service providers include the obligation to secure that, personal data of yours and of any third parties such as employees, contractors, clients, principals and other individuals and contracting parties related to you, which has come or may come into our possession and which may also contain sensitive data, is processed in accordance with relevant Regulation and/or other laws in force.
Such processing may relate to agreements entered between us as service providers and yourselves, to the provision of services by us as service providers and intermediate service providers, to the adherence with laws, regulations and directives, KYC (know-your-client) procedures, the manner of operation and management of our business, including business development, account management, internal financial reporting, IT and/or marketing processing, legal due diligence or disclosure of information clients, to banks, legal or other associates of ours who may offer services to you, to international organizations whether in the United Kingdom or any other European Union or other third countries.
Unless otherwise instructed by you we consider that we may process, collect, store, disclose, copy and transfer personal data, relating to you and/or your employees, contractors, clients, principals and other individuals and contracting parties of relevance to you in the same manner without the need for a separate consent on each occasion and at each time, such consent considered as duly given. Collection of such data may be made from you, any authorised by you person, any agencies who carry out investigations on our behalf, other public domain information sources such as the internet etc. Please be informed that we may not follow any instructions by you prohibiting the processing, collection, storage, disclosure, copying and transferring of personal data, relating to you and/or your employees, contractors, clients and other individuals of relevance to you, in the event that any other law/regulations in force imposes upon us any contrary obligation. For all intents and purposes the provisions of any laws/regulations in force which may provide otherwise, shall override any of your instructions.
When you provide personal data to us about third parties such as employees, contractors, clients, principals and other individuals and contracting parties etc, you shall be considered as having provided the data, with due and received authority to have done so as their agent and as having obtained any required consents.
All correspondence files and records (other than statutory corporate records) and all information and data held by us on our computers/servers are the sole property of ours and you shall have no right of access thereto or control there over, however you shall be free to request by written instructions, details of your personal information data held by us, you may demand the correction of any wrong or inaccurate information in our data records and ask for any copies of data maintained by us which you or any authorized representative of yours have furnished us with.
The maintenance, use storage, use etc. of personal data shall be kept by us to the extent and as long as the relevant law/s or any regulation/s provide. Should any law require the keeping and maintenance of certain date for a longer period of time we undertake to arbitrarily or on your request remove from our data system upon the lapse of the period provided by the GDPR, data relating to you which may be irrelevant or unnecessary for keeping for the purposes of compliance with any such law/s or regulation/s.
We are providing you herein below with the following information in addition to the above information which include the purposes of processing of personal data the legal basis for doing so, the recipients of personal data, our legitimate interests and transfer of such data. As a data subject you may address any concern of yours on a matter relating to your data protection rights to the company’s Data Protection Officer below.
Data Protection Officer (DPO): Mr. Thomas Stieger
Contact details of DPO: [email protected]
Any complaints you may have with regards to any violation of your rights under the GDPR may be lodged with the relevant supervisory authority whose details are as follows:
ICO – Information Commissioner’s Office
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: +44 303 123 1113, Fax: +44 1625 545860
Email: [email protected]
https://ico.org.uk/
If you should wish to have your name and address removed from our specific purposes mailing list, you should provide us with clear instructions in this respect or click on the unsubscribe link in any of such mailings. However, in such a case we shall not be held liable and you hereby relieve us of any liability with respect to any information of essence which may not reach you.
We remain at your disposal for any clarification on the above, whilst we assure you that our firm is aiming to be duly compliant with the GDPR and other laws/regulations/directives in force.
1. DEFINITIONS AND INTERPRETATIONS
| “Account” | means an account required to access and/or use certain areas and features of Our Site; |
| “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 Our Site are set out in section 12, below; |
| “Our Site” | means this website, www.hessgroupinternational.com |
| “UK and EU Cookie Law” | means the relevant parts of the EU General Data Protection Regulation 2016/679 (GDPR); |
| “We/Us/Our” | means HESS GROUP INTERNATIONAL LTD, a limited company registered in the United Kingdom with registration number 13011547, whose registered address is 45 King William Street, London, United Kingdom, EC4R 9AN. |
2. INFORMATION ABOUT US
3. SCOPE – WHAT DOES THIS POLICY COVER?
4. WHAT DATA WE COLLECT?
• your full name;
• business/company name;
• your job title and/or profession;
• IP address (automatically collected);
• operating system (automatically collected);
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences and interests;
• web browser type and version (automatically collected);
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
5. HOW DO WE USE YOUR DATA?
We use your data to provide the best possible products and services to you. This includes:
• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying Our services to you;
• Personalising and tailoring Our products and services for you;
• Responding to communications from you;
• Supplying you with email alerts, newsletters and announcements that you have subscribed to automatically by providing us with your details (you may unsubscribe or opt-out at any time by clicking the “Unsubscribe” button at the bottom of any promotional email;
• Market research;
• Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone and text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the EU General Data Protection Regulation 2016/679 (GDPR).
6. HOW AND WHERE DO WE STORE YOUR DATA?
Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the EU General Data Protection Regulation 2016/679 (GDPR). Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.
Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
• Strong 2048-Bit SSL Extended Validation Certificate Encryption by Comodo.
• We use Alphabet’s (Google) email services, which are highly secured.
• We follow strict internal procedures when handling any sensitive data.
Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. DO WE SHARE YOUR DATA?
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the 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.
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 information. 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.
In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. WHAT HAPPENS IF OUR BUSINESS CHANGES OWNERSHIP?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
9. HOW CAN YOU CONTROL YOUR DATA?
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.
10. YOUR RIGHT TO WITHHOLD INFORMATION
• You may restrict your internet browser’s use of Cookies. For more information, see section 12.
11. HOW CAN YOU ACCESS YOUR DATA?
12. COOKIES
“Cookies” are small pieces of information that are transferred to your browser and stored on your computer’s hard drive. Our cookies enable us to provide you with more personal service. Cookies also allow us to track usage patterns, trends and other aggregate visitor information. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that if you would rather not store the information for future use. We may also collect certain technical and routing information about your computer to facilitate your use of the site and its services (such as browser type, operating system and the Internet Protocol (“IP”) address of your computer). Without expressly informing you in each particular instance, we do not match such information with any of your personal information.