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Privacy Policy

Welcome to Holland Mountain’s Privacy Policy.

Please read this Privacy Policy carefully before you start to use our website or register with our services, as it will apply to your use of our website: www.hollandmountain.com and to your registration with us.

If you do not agree with this Privacy Policy, you must not use our website or register with our services.

Holland Mountain Group Limited (“us”, “we” and “our”) respects your privacy and is committed to protecting the personal data of those who use our website www.hollandmountain.com and register with our services.

This Privacy Policy will inform you as to how we look after your personal data when you visit our website, including the Holland Mountain Directory, (regardless of where you visit from) and tells you about your privacy rights and how the law protects you.

  1. Important information and who we are

What is the purpose of this Privacy Policy?

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this website, such as when you register your details with us or upload a profile of your business or firm.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy 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 Holland Mountain Group Limited is the controller and responsible for your personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Head of Operations using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Holland Mountain Group Limited

FAO: Head of Operations

Email address: info@hollandmountain.com

Postal address: 2 Angel Square, London, EC1V 1NY

Telephone number: 020 7394 0763

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 this Privacy Policy and your duty to inform us of changes

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.

Third-party links

This website may include 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 policy of every website you visit.

  1. What data do you collect about me?

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 follows:

  • Identity Data includes first name, last name and title.
  • Contact Data includes billing address, email address and telephone numbers, and information included on business cards
  • Transaction Data includes details of 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 language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website; when you access our website from a mobile device additional data may be collected, including data relating to your mobile network, device and telephone number.
  • Profile Data includes your username and password.
  • Usage Data includes uniform resource locators (URLs), data about your internet service provider, information about how you use our website, products and services, such as the number and timing of clicks to and from our website content, which products you view, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to contact us and how you interact with website content (such as by sharing on social media, which can create data relating to the contents of a post of comment or which social media network was used).
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share 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 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 our 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.

  1. 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, and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • register with our website to create an account;
    • upload a profile of your business or firm;
    • provide account user details upon registration or by communicating with us (for example, to report a problem with our website or our Services);
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • ; or
    • 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, server logs and other similar technologies. Please see our cookie policy https://hollandmountain.com/cookie-policy/ for further details.
  • 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:

(a) analytics providers such as Google based outside the EU;

  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  • Identity and Contact Data which you upload to the Holland Mountain Directory.
  • Identity and Contact Data relating to your interactions with any interactive features on our website and any of our social media applications

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this website.

Data obtained from third parties may be used for the same purposes as data you provide us or data we collect from you, and may also be deleted or anonymised and/or combined with other data we have collected.

  1. How and why do you use my 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 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.

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 if you have engaged with us in an individual capacity. 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.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a user of or contributor to our website (a) Identity

(b) Contact

Necessary for our legitimate interests (to conclude and perform a contract with your company or organisation)
To contact you with any queries about your registration (a) Identity

(b) Contact

Necessary for our legitimate interests (to conclude and perform a contract with your company or organisation)
To manage payments, fees and charges

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Necessary for our legitimate interests (to conclude and perform a contract with your company or organisation)
To collect and recover money owed to us (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Necessary for our legitimate interests (to recover debts due to us)
To notify you about changes to our terms, privacy policy, cookie policy, website terms of use or acceptable use policy (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Necessary to comply with a legal obligation
To notify you about changes to our services (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Necessary for our legitimate interests (to conclude and perform a contract with your company or organisation)
To ask you to leave a review or take a survey (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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)

 

To ensure that content from our website is presented in the most effective manner for you and for your computer  (c) Technical Your consent
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

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)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
To carry out research and statistical analysis including our IT survey (a) Identity

(b) Contact

 

(d) Transaction

(e) Marketing and Communications

(f) Technical

(g) Usage

(h) Profile

Necessary for our legitimate interests (to undertake statistical analysis and research)
To enable us to comply, monitor compliance with, carry out our obligations or exercise our rights under this Privacy Policy, our Cookie Policy (http://hollandmountain.com/cookies/),  our Website Terms of Use http://hollandmountain.com/terms/ and our Acceptable Use Policy (http://hollandmountain.com/acceptable-use/). (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Technical

 

Necessary to comply with a legal obligation

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe instructions on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our provision of services to you, in connection with any feedback you provide regarding our provision of such services or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://hollandmountain.com/cookie-policy/.

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.

  1. Will you disclose my data to third parties?

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties – other companies in the Holland Mountain Group, including Hertalis Limited acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
  • External Third Parties – these include:
  • Service providers acting as processors, based in inside and outside of the EEA, who provide IT and system administration services including software vendors.
  • Potential customers where, with your consent, we include your personal details to support a reference request from a potential customer regarding our Services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • analytics and search engine providers
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

  1. International transfers

We share your personal data within the Holland Mountain Group. This may involve transferring your data outside the European Economic Area (EEA).  Some of our external third parties we may share your data with are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. 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.

However, please note that you are responsible for keeping your password and access credentials confidential.

  1. Data retention

How long will you use my personal data for?

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.

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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
  • Request correction of your personal data – 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 can also 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.
  • 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 your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: 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 our Privacy Compliance Officer by email at info@hollandmountain.com or by post at Holland Mountain Group Limited, 2 Angel Square, London, EC1V 1NY.

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 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.

How can I contact you?

You can contact us by telephoning our team on +44 (0) 20 7394 0763 or by writing to us by email at info@hollandmountain.com or by post at Holland Mountain Group Limited, 2 Angel Square, London, EC1V 1NY.

Thank you for visiting our website.

Last updated 4th Spetember 2018.

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