This privacy policy applies betweenyou, the User of this Website and TahoraLtd, the owner and provider of this Website. Tahora Ltd takes the privacy ofyour information very seriously. This privacy policy applies to our use of anyand all Data collected by us or provided by you in relation to your use of theWebsite.
This privacy policy should be readalongside, and in addition to, our Terms and Conditions, which can be foundat: www.Happl.com.
Please read this privacy policy carefully.
Definitionsand interpretation
1. In this privacy policy, thefollowing definitions are used:
Data
collectively all information that you submit to Tahora Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR
the UK General Data Protection Regulation;
Tahora Ltd,
we or us
Tahora Ltd, a company incorporated in with registered number 12430540 whose registered office is at 71-75 Shelton Street, London, WC2H 9JQ ;
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you
any third party that accesses the Website and is not either (i) employed by Tahora Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Tahora Ltd and accessing the Website in connection with the provision of such services; and
Website
the website that you are currently using, wwa.Happl.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. In this privacy policy, unlessthe context requires a different interpretation:
a. the singular includes theplural and vice versa;
b. references to sub-clauses,clauses, schedules or appendices are to sub-clauses, clauses, schedules orappendices of this privacy policy;
c. a reference to a personincludes firms, companies, government entities, trusts and partnerships;
d. "including" isunderstood to mean "including without limitation";
e. reference to any statutoryprovision includes any modification or amendment of it;
f. the headings and sub-headingsdo not form part of this privacy policy.
Scope ofthis privacy policy
3. This privacy policy appliesonly to the actions of Tahora Ltd andUsers with respect to this Website. It does not extend to any websites that canbe accessed from this Website including, but not limited to, any links we mayprovide to social media websites.
4. For purposes of the applicableData Protection Laws, Tahora Ltd isthe "data controller". This means that Tahora Ltd determines the purposesfor which, and the manner in which, your Data is processed.
Datacollected
5. We may collect the followingData, which includes personal Data, from you:
a. name;
b. date of birth;
c. gender;
d. job title;
e. profession;
f. contact Information such asemail addresses and telephone numbers;
g. demographic information such aspostcode, preferences and interests;
h. financial information such ascredit / debit card numbers;
i. IP address (automaticallycollected);
j. web browser type and version(automatically collected);
k. operating system (automaticallycollected);
l. a list of URLs starting with a referringsite, your activity on this Website, and the site you exit to (automaticallycollected);
m. ;
in each case, in accordance withthis privacy policy.
How wecollect Data
6. We collect Data in thefollowing ways:
a. data is given to us byyou ;
b. data is received from othersources; and
c. data is collectedautomatically.
Data thatis given to us by you
7. Tahora Ltd will collect yourData in a number of ways, for example:
a. when you contact us through theWebsite, by telephone, post, e-mail or through any other means;
b. when you register with us andset up an account to receive our products/services;
c. when you complete surveys thatwe use for research purposes (although you are not obliged to respond to them);
d. when you enter a competition orpromotion through a social media channel;
e. when you make payments to us,through this Website or otherwise;
f. when you elect to receivemarketing communications from us;
g. when you use our services;
h. ;
in each case, in accordance withthis privacy policy.
Data thatis received from third parties
8. Tahora Ltd will receive Dataabout you from the following third parties:
a. .
Data thatis received from publicly available third parties sources
9. We will receive Data about youfrom the following publicly available third party sources:
a. .
Data thatis collected automatically
10. To the extent that you accessthe Website, we will collect your Data automatically, for example:
a. we automatically collect someinformation about your visit to the Website. This information helps us to makeimprovements to Website content and navigation, and includes your IP address,the date, times and frequency with which you access the Website and the way youuse and interact with its content.
b. we will collect your Dataautomatically via cookies, in line with the cookie settings on your browser.For more information about cookies, and how we use them on the Website, see thesection below, headed "Cookies".
Our use ofData
11. Any or all of the above Datamay be required by us from time to time in order to provide you with the bestpossible service and experience when using our Website. Specifically, Data maybe used by us for the following reasons:
a. internal record keeping;
b. improvement of our products /services;
c. transmission by email ofmarketing materials that may be of interest to you;
d. contact for market researchpurposes which may be done using email, telephone, fax or mail. Suchinformation may be used to customise or update the Website;
e. ;
in each case, in accordance withthis privacy policy.
12. We may use your Data for theabove purposes if we deem it necessary to do so for our legitimate interests.If you are not satisfied with this, you have the right to object in certaincircumstances (see the section headed "Your rights" below).
13. For the delivery of directmarketing to you via e-mail, we'll need your consent, whether via an opt-in orsoft-opt-in:
a. soft opt-in consent is aspecific type of consent which applies when you have previously engaged with us(for example, you contact us to ask us for more details about a particularproduct/service, and we are marketing similar products/services). Under"soft opt-in" consent, we will take your consent as given unless youopt-out.
b. for other types of e-marketing,we are required to obtain your explicit consent; that is, you need to takepositive and affirmative action when consenting by, for example, checking atick box that we'll provide.
c. if you are not satisfied aboutour approach to marketing, you have the right to withdraw consent at any time.To find out how to withdraw your consent, see the section headed "Yourrights" below.
14. When you register with us andset up an account to receive our services, the legal basis for this processingis the performance of a contract between you and us and/or taking steps, atyour request, to enter into such a contract.
Who weshare Data with
15. We may share your Data with thefollowing groups of people for the following reasons:
a. any of our group companies oraffiliates - ;
b. our employees, agents and/orprofessional advisors - ;
in each case, in accordance withthis privacy policy.
KeepingData secure
16. We will use technical andorganisational measures to safeguard your Data, for example:
a. access to your account iscontrolled by a password and a user name that is unique to you.
b. we store your Data on secureservers.
c. payment details are encryptedusing SSL technology (typically you will see a lock icon or green address bar(or both) in your browser when we use this technology.
17. We are certified to ISO 27001.This family of standards helps us manage your Data and keep it secure.
18. Technical and organisationalmeasures include measures to deal with any suspected data breach. If yoususpect any misuse or loss or unauthorised access to your Data, please let usknow immediately by contacting us via this e-mail address: [Website owner's contact e-mail address].
19. If you want detailedinformation from Get Safe Online on how to protect your information and yourcomputers and devices against fraud, identity theft, viruses and many otheronline problems, please visit www.getsafeonline.org. Get Safe Online issupported by HM Government and leading businesses.
Dataretention
20. Unless a longer retentionperiod is required or permitted by law, we will only hold your Data on oursystems for the period necessary to fulfil the purposes outlined in thisprivacy policy or until you request that the Data be deleted.
21. Even if we delete your Data, itmay persist on backup or archival media for legal, tax or regulatory purposes.
Yourrights
22. You have the following rightsin relation to your Data:
a. Right to access - the rightto request (i) copies of the information we hold about you at any time, or (ii)that we modify, update or delete such information. If we provide you withaccess to the information we hold about you, we will not charge you for this,unless your request is "manifestly unfounded or excessive." Where weare legally permitted to do so, we may refuse your request. If we refuse yourrequest, we will tell you the reasons why.
b. Right to correct - the rightto have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the rightto request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data orlimit the way in which we can use it.
e. Right to data portability -the right to request that we move, copy or transfer your Data.
f. Right to object - the rightto object to our use of your Data including where we use it for our legitimateinterests.
23. To make enquiries, exercise anyof your rights set out above, or withdraw your consent to the processing ofyour Data (where consent is our legal basis for processing your Data), pleasecontact us via this e-mail address: [Websiteowner's contact e-mail address].
24. If you are not satisfied withthe way a complaint you make in relation to your Data is handled by us, you maybe able to refer your complaint to the relevant data protection authority. Forthe UK, this is the Information Commissioner's Office (ICO). The ICO's contactdetails can be found on their website at https://ico.org.uk/.
25. It is important that the Datawe hold about you is accurate and current. Please keep us informed if your Datachanges during the period for which we hold it.
Links toother websites
26. This Website may, from time totime, provide links to other websites. We have no control over such websitesand are not responsible for the content of these websites. This privacy policydoes not extend to your use of such websites. You are advised to read theprivacy policy or statement of other websites prior to using them.
Changes ofbusiness ownership and control
27. Tahora Ltd may, from time totime, expand or reduce our business and this may involve the sale and/or thetransfer of control of all or part of Tahora Ltd. Data provided by Users will,where it is relevant to any part of our business so transferred, be transferredalong with that part and the new owner or newly controlling party will, underthe terms of this privacy policy, be permitted to use the Data for the purposesfor which it was originally supplied to us.
28. We may also disclose Data to aprospective purchaser of our business or any part of it.
29. In the above instances, we willtake steps with the aim of ensuring your privacy is protected.
Cookies
30. This Website may place andaccess certain Cookies on your computer. Tahora Ltd uses Cookies to improveyour experience of using the Website and to improve our range of products andservices. TahoraLtd has carefully chosen these Cookies and has taken steps to ensurethat your privacy is protected and respected at all times.
31. All Cookies used by thisWebsite are used in accordance with current UK and EU Cookie Law.
32. Before the Website placesCookies on your computer, you will be presented with a message bar requestingyour consent to set those Cookies. By giving your consent to the placing ofCookies, you are enabling Tahora Ltd toprovide a better experience and service to you. You may, if you wish, denyconsent to the placing of Cookies; however certain features of the Website maynot function fully or as intended.
33. This Website may place thefollowing Cookies:
Type of Cookie
Purpose
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
34. You can find a list of Cookiesthat we use in the Cookies Schedule.
35. You can choose to enable ordisable Cookies in your internet browser. By default, most internet browsersaccept Cookies but this can be changed. For further details, please consult thehelp menu in your internet browser.
36. You can choose to deleteCookies at any time; however you may lose any information that enables you toaccess the Website more quickly and efficiently including, but not limited to,personalisation settings.
37. It is recommended that youensure that your internet browser is up-to-date and that you consult the help andguidance provided by the developer of your internet browser if you are unsureabout adjusting your privacy settings.
38. For more information generallyon cookies, including how to disable them, please refer to aboutcookies.org.You will also find details on how to delete cookies from your computer.
General
39. You may not transfer any ofyour rights under this privacy policy to any other person. We may transfer ourrights under this privacy policy where we reasonably believe your rights willnot be affected.
40. If any court or competentauthority finds that any provision of this privacy policy (or part of anyprovision) is invalid, illegal or unenforceable, that provision orpart-provision will, to the extent required, be deemed to be deleted, and thevalidity and enforceability of the other provisions of this privacy policy willnot be affected.
41. Unless otherwise agreed, nodelay, act or omission by a party in exercising any right or remedy will bedeemed a waiver of that, or any other, right or remedy.
42. This Agreement will be governedby and interpreted according to the law of England and Wales. All disputes arisingunder the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes tothis privacy policy
43. Tahora Ltd reserves the right tochange this privacy policy as we may deem necessary from time to time or as maybe required by law. Any changes will be immediately posted on the Website andyou are deemed to have accepted the terms of the privacy policy on your firstuse of the Website following the alterations.
You may contact Tahora Ltd by email at support@happl.com.
