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
- Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Hamilton Global Opportunities PLC is the controller and responsible for your personal data.
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.
- The data we collect about you
Personal data 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).
Depending on your engagement with us and the services we provide to you, 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, job title].
- Contact Data includes [email address, telephone number and billing address].
- 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, 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.
- 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 your communication preferences].
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 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.
- 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 and Financial Data by corresponding with us by email or otherwise.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.
- 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.
[Generally, 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, in a table format, 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 the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To deliver our services to you including:|
(a) liaising with you about the services you have asked us to assist you with;
(b) managing payments, fees and charges in respect of our services
|Performance of a contract with you|
|To administer and protect our business and this website (including troubleshooting,|
data analysis, testing, system maintenance, support, reporting and hosting of data)
|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)
|To use data analytics to improve our website, products/services, marketing,|
customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products|
and services, to keep our website updated and relevant, to develop our business
and to inform our marketing strategy)
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.
- Disclosures of your personal data
We only share your personal data with third parties where we are able to do so in compliance with all applicable laws. We will never sell your personal data for direct marketing.
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.
- International transfers
We do not transfer your personal data outside the UK.
- 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.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
- Your legal rights
Your personal data is protected under data protection laws and you have a number of rights (explained below) which you can seek to exercise. Please contact us using the details provided in the contact and complaints section below if you have any queries in relation to your rights.
If you seek to exercise your rights we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances.
- Right of access – You have a right to access the personal data we hold about you upon request. This is known as a “Data Subject Access Request”. You can exercise this right by making a request in writing, by email or by telephone.
- Right of rectification – You can ask us to correct or update your personal data to ensure it is accurate and complete.
- Right to erasure and right to restrict processing – You can ask us to stop processing and/or to delete your personal data in certain circumstances (for example, where it is processed with your consent, or it is no longer necessary for us to process it).
- Right to data portability – You have a right to ask us to provide you with your personal data in a form that suits you, and/or to provide your information to a third party.
- Right to object – You have a right to object to our processing of your personal data.
- Profiling and automated decisions – You have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling. We do not undertake any automated decision making or profiling.
Right to object to direct marketing – Where you have consented to receive direct marketing, you can change your mind at any time by contacting us or following the link to “unsubscribe” provided in each email we send to you. Please allow a few days for us to action your request.
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 could 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 requests within one month. Occasionally it could 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.
Contact and Complaints
by writing to us at: 1st Floor, Lansdowne House, 57 Berkeley Square, London, W1J 6ER
by emailing email us at: firstname.lastname@example.org
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) by writing to: Information Commissioner’s Office, Water Lane, Wilmslow, SK9 5AF or calling: 0303 123 1113. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so would be grateful for you contacting us in the first instance.