Privacy Policy
Introduction
Hark London Limited (Hark) is committed to safeguarding your privacy. This privacy policy sets out the basis on which we, Hark (“We”, “Us”, “Our”) collect and use your personal data through our website, www.harklondon.com (the “Site”) and any other platforms.
We may occasionally modify the Privacy Policy and will post the revised Privacy Policy on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.
We will inform you of any changes to the Privacy Policy via the homepage when this happens, but you should check the policy frequently to read the latest Privacy Policy. Our website includes 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.
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Hark London collects and processes your personal data, including any data you may provide through this website.
It is important that you read this Privacy Policy 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 Policy supplements the other notices and is not intended to override them.
Controller
Hark is the controller and is responsible for your personal data (collectively referred to as “Hark”, “we”, “us” or “our” in this Privacy Policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Kieren Liu
Data Protection Officer
kieren.liu@harklondon.com
Our registered company address:
Hark London Ltd at Kings Croft, Jaspers Green, Shalford, Essex, CM7 5AT
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.
Changes to the Privacy Policy and your duty to inform us of changes.
This version of the Privacy Policy was last updated on 01/03/2024 and historic versions can be obtained by contacting us.
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.
What information do we collect? How do we collect it?
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 as follows:
Identity Data: includes first name, last name, username or similar identifier, title, date of birth and gender.
Contact Data: includes billing address, delivery address, email address and telephone numbers.
Financial Data: includes bank account and payment card details.
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.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect and use 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 Policy.
We may collect Special Categories of Personal Data about you on occasion (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). We will only collect this information if you consent to providing it. Schedule 1 of the DPA 2018 provides conditions for processing special category.
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 or services). In this case, we may have to cancel a service you have with us but we will notify you, if this is the case, at the time.
How we collect personal data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services
- register on our website
- request marketing to be sent to you
- enter a survey
- give us some feedback
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.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers, such as Google, based outside the EU
- advertising networks based inside the EU
- search information providers based inside the EU
Identity and Contact Data from data brokers or aggregators based inside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU
This data is stored on our database. Subject to the use of this data to which you have consented, the database enables EVERFI EdComs to provide you with information you request from us. When we collect personal information, we include a link to this Privacy Policy on the page that we request your personal data.
How we use your personal data
We will only use your personal data for the purposes set out below. Additionally, if at any time you wish us to stop using your information for any or all of the below purposes, please let us know by contacting us at info@harklondon.com
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
Personal data provided by you when contacting us or registering to receive our newsletter is not used to track your visits to the site.
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 or clicking unsubscribe on our emails.
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 may 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 the table below:
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client | (a) Identity
(b) Contact |
Performance of a contract with you |
| To process and deliver your requests 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 for our legitimate interests (to recover debts due to us) (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
| To enable you to partake in completing a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business) |
| 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 |
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) |
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business, to enable us to give you the best 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.
Marketing to education audiences
We will process your data and distribute relevant marketing communications for your professional role to your business email address, on the grounds of legitimate interest to our business in conducting and managing our business and/or client’s business.
We will only send marketing communications to a non-business email if you have opted in to receive communications with a non-business email, or if you provided us with your details when you registered for a service.
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 services may be relevant for you (we call this marketing).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Third party data sharing
We will get your express opt-in consent before we share your person data with any other company, including for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time or by unsubscribing from an email.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing a service, or other transactions.
If at any time you wish us to stop using your information for any or all of the below purposes, please let us know by contacting us at info@harklondon.com
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.
Security
Any user-submitted data in forms will be transferred securely via SSL. 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.
Notice to minors
This Site is intended for use by adults. If you are under 16 please do not send us any personal information including your email details. If you would like to contact us, please do so through a parent or legal guardian (ask them to email us on your behalf). If you are a parent or legal guardian of a child who has submitted to us personal information, please let us know by contacting us at info@harklondon.com We will delete such personally identifiable information from our database as soon as possible following our receipt of any such notice.
Do we share the information we receive?
We do not otherwise disclose information which identifies you to any third parties for marketing purposes unless we have your prior consent.
Disclosures for other purposes will occur if required by applicable law regulation, for our legitimate interest, the performance of the contract or to provide an efficient service.
Third parties are parties to whom we may choose to sell, transfer, merge parts of our business or assets, if we seek to acquire, merge with other businesses, to service providers, HM Revenue & customs, Regulators and professional advisers including lawyers, bankers, auditors and insurers.
Information may be transferred to third parties and internationally, some of whom may not have laws that protect privacy rights as extensively as in the United Kingdom. Where this is the case, 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.
Data Retention: How long will your personal data be used?
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.
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 Request erasure below for further information.
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 which are as follows:
- 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.
- Request correction 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.
- Request erasure 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:
- if you want us to establish the data’s accuracy
- where our use of the data is unlawful but you do not want us to erase it
- 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
- 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.
- If you wish to exercise any of the rights set out above, please contact us at info@harklondon.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.
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.
What about ‘cookies’?
‘Cookies’ are small pieces of information that are stored by your browser on your computer’s hard-drive. Most Web browsers automatically accept cookies, but you can usually change your browser to prevent that. We only use cookies to keep track of the pages you visit on the Website and to tell us whether you have visited the Website previously so that, in order to serve you better, we understand how you and other visitors use the Website. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
How we use cookies
We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.
We use a type of cookie called Analytical/Performance Cookies. These allow us to recognise and count the number of users of our website and see how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily.
We use targeting cookies. These record your visit to our website, the pages you have visited and the links you have followed. We use this information to make advertising displayed on third party sites more relevant to end users.
Your consent
You represent and warrant that all information you provide to us shall be truthful and accurate and shall not violate the rights of any third party. By using the Website and submitting information, you consent to: the collection and use of your personal information by us as described above.
Online data
This general Privacy Policy only applies to the collection of data online and not to offline information.
Further information
If you have any requests or questions regarding this policy please write to : info@harklondon.com