Here at Hardware Pioneers Ltd (“We”), we are committed to protecting and respecting your privacy and 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.
This Privacy Notice (together with our Website Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting any website owned and operated by Hardware Pioneers Ltd you are accepting and consenting to the practices described in this Policy.
For the purpose of the Data Protection Act 1998 (“the Act”) and the General Data Protection Regulation 2016 (“GDPR”), the data controller is Hardware Pioneers Ltd, a limited company in England, whose registered address is at 2701 Landmark West Tower, 22 Marsh Wall, London E14 9AL, United Kingdom.
Please also use the Glossary as and where necessary to understand the meaning of some of the terms used in this Privacy Notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY 1. Important information and who we are
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how we collect and process your personal data through your use of the Site, your registration for our events and/or sign up to our newsletter, or take part in a promotion.
The Site is not intended for children and we do not knowingly collect data relating to children.
Data Protection Officer
Hardware Pioneers Ltd
2701 Landmark West Tower
22 Marsh Wall
London, E14 9AL
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, and would therefore ask that you please contact us in the first instance.
This Site 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 Site, we encourage you to read the privacy notice of every website you visit.
2. 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 which we have grouped together follows:
• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes billing/invoice address, contact names, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
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.
If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods).
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes, without limitation, personal data you provide when you:
• register for our events;
• apply for our products or services;
• create an account on our Site;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• provide us with feedback.
Automated technologies or interactions
. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.Third parties or publicly available sources
. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties: (a) analytics providers (such as Google, based outside the EU); (b) advertising networks (based inside and outside the EU); and (c) search information providers (based inside and outside the EU).
• Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services (based inside and outside the EU).
• Identity Data and Contact Data from data brokers or aggregators (based inside and outside the EU).
• Identity Data and Contact Data from publicly availably sources (such as Companies House and the Electoral Register based inside the EU).
4. 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 into or have entered into with you.
• 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.
Please refer to the Glossary section to find out more about the legal basis.
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. 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 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.
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 below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us
We may use your Identity Data, Contact Data, Technical Data, Usage Data 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. You will receive marketing communications from us if you have requested information from us or purchased goods (or services) from us and, in each case, you have not opted out of receiving that marketing. Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company (that is, other than Hardware Pioneers Ltd) for marketing purposes. Opting out
You can ask us or third parties to stop sending you marketing messages at any time – either by logging into the website and checking or unchecking relevant boxes within your preferences to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product/service experience or other transactions.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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 may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
• External Third Parties as set out below (in the Glossary)
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice. 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
In the course of undertaking the activities specified in this Privacy Notice it may be necessary to transfer data to third parties who provide services to us outside the European Economic Area including countries that have different levels of data protection laws to the country from where you submitted your personal data.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
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.
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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 only keep your information for as long as it is necessary. By law we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six years after they cease being customers for legal and tax purposes. We regularly review all our personal information and archive, delete or remove data that is no longer needed or is felt to be out of date for the purposes in which we use data. In some circumstances you can ask us to delete your data. 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. Please refer to the Glossary section below to find out more about these rights:
• 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 email@example.com
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 will 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. Glossary LEGAL BASIS Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
• Service providers, acting as processors, who provide IT and system administration services.
• Professional advisers, acting as processors or joint data controllers, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide legal, banking, accounting, insurance and consultancy services.
• HM Revenue & Customs, regulators and other authorities, acting as processors or joint data controllers based in the United Kingdom.
YOUR LEGAL RIGHTS
You have the right to:Request access
to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time
A cookie is a text only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number. Cookies cannot be used by themselves to identify you and are not computer programs, and can't cause any damage to your computer.
Persistent Cookies are created and stored on your computer's hard drive for a period of time to identify it to the site tracking tool. The cookie does not collect any personal information. The cookie we issue contains a uniquely generated random number so that we can differentiate visitors and the expiry date of the cookie.
Session Cookies are temporary cookies that remain in the cookie file of your browser until you leave our site. Session Cookies allow you to carry information across pages of our site and avoid having to re-enter information into calculators, tools, illustrations and demonstrations.
We now outline the types of cookies we use on this site and what we use them for. The site operates an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete Hardware Pioneers cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, "Private Browsing" in Firefox and Safari etc.)
Persistent Cookies for Site Analytics and Performance:
We use some persistent cookies to enhance the relevancy of information displayed on the site. User data is anonymous. More information about persistent cookies and what they are used for at http://www.allaboutcookies.org/cookies/persistent-cookies-used-for.html
Google Analytics – we use this to understand how the site is being used in order to improve the user experience. User data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html
Disabling / Enabling Cookies:
By modifying the settings of your browser, you may opt to accept cookies, to be informed when one is about to be placed on your computer, or to automatically reject all cookies. However, you will not be able to use all the interactive features of our site or our online savings account if cookies are disabled. More information on cookies can be found at About Cookies
.Changes to this Privacy Notice
Hardware Pioneers Ltd reserves the right to change this Privacy Notice from time to time as it sees fit and your continued use of our services will signify your acceptance of any adjustment to these terms. You are therefore advised to re-read this statement on a regular basis.
(The Privacy Notice has been updated in May 2021)
© Hardware Pioneers Ltd 2021 All Rights Reserved