We take your privacy very seriously. This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you. We are required to notify you of this information under data protection legislation. Please ensure that you read this privacy notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Hexagon of Highgate Limited (‘Company’) is a ‘data controller’ and gathers and uses certain information about you.
We will comply with the data protection principles when gathering and using personal information, as set out in our data protection policy.
The table below sets out the personal data we will or may collect in the course of dealing with you.
Personal data we may collect depending on the services you ask us to provide
Your name, address and telephone number
Information to enable us to check and verify your identity, eg your date of birth or passport details
Electronic contact details, eg your email address and mobile phone number
Information relating to the services we will provide.
Information to enable us to undertake a credit or other financial checks on you
Your financial details so far as relevant to the services
Your National Insurance and tax details
Your bank and/or building society details
Your employment status and details including salary and benefits
Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
We collect most of this information from you direct. However, we may also collect information:
from publicly accessible sources;
directly from a third party, eg credit reference agencies;
from a third party with your consent, eg:
your bank or building society, another financial institution or advisor;
consultants and other professionals we may engage in relation to your matter;
via our information technology (IT) systems
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
We may use your personal data to send you updates (by email, text message, telephone or post) about developments that might be of interest to you and/or information about our services, including exclusive offers, promotions, new services or products. We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal data with:
professional advisers instructed on your behalf;
other third parties where necessary to provide our services;
credit reference agencies;
our insurers and brokers;
external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We will not share your personal data with any other third party.
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above. Some of these third parties may be based outside the European Economic Area.
We will keep your personal data after we have finished providing services to you. We will do so for one of these reasons:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. When it is no longer necessary to retain your personal data, we will delete or anonymise it.
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the services we are providing.
These transfers are subject to special rules under European and UK data protection law.
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal data
The right to require us to correct any mistakes in your personal data
To be forgotten
The right to require us to delete your personal data—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email, call or write to us; and
let us have enough information to identify you;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.