1. Important information and who we are
As part of the services that we provide to our customers, we also act as a data processor in relation to employee personal data that they provide us with. To ensure that you understand how your data is used, we have also detailed that processing below. We have indicated where we act as a data controller, and where we act as a data processor.
Full name of legal entity: Tahora Limited, trading as Happl
Email address: firstname.lastname@example.org
Postal address: Tahora Limited, trading as Happl, 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would really appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
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.
2. The data we process 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 be provided with, 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, profile picture, date of birth, age and gender.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank details and credit card information.
· HR Data includes detailed HR information such as your salary, start date, role, position, manager, options allocation, probation end date, working pattern, employee ID, tax ID, tax code, contract type, place of work, team, department, time off usage and allowance and working location.
· Transaction Data includes details about payments to and from you, together with 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.
· Sensitive Data includes information about your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data and sex life and/or sexual orientation.
· Profile Data includes purchases or orders made by you, your interests, preferences and feedback.
· 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 third parties and your communication preferences.
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 product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact, Financial, HR and Sensitive Data by filling in forms or by corresponding with us via our website. Your employer may also provide us with this data as detailed below. This includes personal data you provide when you:
• create an account on our website;
• access or purchase goods and/or services via our wesbite; or
• give us feedback or contact us.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
o Technical Data from analytics providers such as Google based outside the UK;
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe;
o Identity, Contact, Financial, HR Data and Sensitive Data from your employer, either manually or via an automatic integration with their HR, accounting or other software provider.
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 obligation.
- Where we have been appointed to process that personal data on behalf of our customers, and we do so in accordance with their specific instructions.
Generally, with the exception of Sensitive Data, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 process your personal data and have indicated whether we do so as a data processor or a data controller. Where we act as a data controller, we have identified 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.
Processing undertaken as a data processor on behalf of our customers, acting in accordance with their instructions
Processing undertaken as a data controller
Promotional offers from us
When permitted to do so by law, we may use your Identity, Contact, Technical, Usage, Sensitive 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. If we have your consent to do so, we may contact you by email with information about these products and services.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
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 share your personal data with the parties set out below for the purposes set out in the table above.
• External Third Parties:
o Your employer, when they have asked us to do so as part of the services that we provide to them.
o Service providers acting as data processors who provide IT and system administration services.
o Payment and bank card processing providers, such as Stripe.
o Professional advisers acting as data processors or data controllers including lawyers, bankers, auditors and insurers who provide professional services to us.
o HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
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
When we share personal data with the third parties listed above this may involve a transfer of your personal data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate legal safeguards are implemented. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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?
When we are acting as a data controller, 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, legal and/or accounting purposes. In some circumstances you can ask us to delete your data. In some circumstances we will 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. When we are acting as data processor, your employer will notify us of our obligations regarding data deletion when our relationship with them ends.
9. Your legal rights
Under certain circumstances, you have the following tights under data protection laws in relation to your personal data:
o Request access to your personal data.
o Request erasure of your personal data
o Object to processing of your personal data
o Request restriction of processing your personal data
o Request transfer of your personal data
o Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
February 3, 2023
For more information or if you have any questions please email email@example.com