Privacy Policy - Data Retention and Destruction Policy

Privacy Policy - Data Retention and Destruction Policy

Who we are 

We are Harry Hall International Limited (referred to in this document as We, Us, Our and Harry Hall). We are the Data Controller for your information under the Data Protection Legislation.  

 

Our office address is;  

Harry Hall International Limited, 

Park View Mills, 

Wibsey Park Avenue, 

Bradford,  

BD6 3QA 

 

We are registered with the ICO under Registration number ZA515101

We are regulated by the FCA for the provision of insurance services under reference number 968047. 

Introduction 

We understand the importance of your personal data and are committed to meeting the requirements of the Data Protection Legislation. To help us meet our obligations, and your expectations, we have developed this privacy notice to ensure that you are fully aware of;

  1. the personal data we collect about you,
  2.  what we do with your information,
  3. what we do to keep your information secure, and
  4.  the rights and choices you have over your personal information.

This notice applies to all of our data collection and processing activities including;

  1. Any interaction with our customer services team,
  2. Your use of our website to purchase goods
  3. Your use of our website to purchase insurance services, and
  4. Your use of the Harry Hall Riding mobile app.

Throughout this notice, where we refer to Data Protection Legislation, we mean the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with this legislation.

When you are based in the EU, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

We will use your information as set out in this Privacy Policy. If we need to use your personal information for any other purpose, we will take steps to provide you with additional information and we will update this Privacy Policy. 

The personal data we collect 

We only collect personal information that we genuinely need to provide our services to you and in accordance with the Data Protection Legislation.

We collect information about you from multiple sources depending on the services that you are engaging with – some information is collected directly from you, some is generated when you interact with our services and, in some cases, we gather information about you from third parties.

Information we collect directly from you may include -

  1. Name
  2. Telephone Number
  3. Email Address
  4. Postal Address
  5. Home Address
  6. Date of Birth
  7. Payment Information (bank or payment card information)
  8. Details of previous insurance claims / your claims history
  9. Any information you share in interactions with our customer services team over the phone, by email or via our social media presence.
  10. Details of your horses (including their age and veterinary history) and equipment (such as details of your trailers) in order to provide you with appropriate insurance.

When you are using the LiveRide or SafeRide functionalities of the Harry Hall Riding app we will also collect your

  1. Location
  2. Riding History - Including date and time of the ride
  3. Riding Routes
  4. A profile photo
  5. Information from your contacts (with your express permission)
  6. Any information that you voluntarily upload to any community pages.

Further information on the permissions required by the Harry Hall Riding App are given at the point of download. Your use of the App will also be governed by the App Terms of Use

In your use of our services, we may generate information about you such as

  1. purchase history
  2. claim history
  3. your interests and preferences
  4. technical information such as IP address, log in information and your devices.

We collect limited technical information about your visit to our site and the use of our App, this helps us to better understand how our customers move around, and interact with, our services.

Harry Hall does not routinely collect or process any Special Category information about you in the provision of our services.

We may incidentally collect some limited information in relation to your health, financial status or current personal circumstances directly from you should you contact our contact centre in relation to your insurance. In some cases we are obliged to keep a record of this information to help manage your account determine the suitability of our insurance products for you. This is to ensure we are meeting our Financial Conduct Obligations. 

Lawful basis for processing your personal data 

We will only ever process your personal data if we have a lawful basis to do so. The lawful bases we rely on are; 

  1. Contract – This is where we process your information to fulfil a contractual arrangement we have made with you such as for the provision of our insurance services or the delivery of your items. 
  2. Consent – This is where we have asked you to provide permission to process your data for a particular purpose such as to send you marketing material. Please note, if we are relying on your Consent, you can withdraw your consent at any time by contacting us or using the opt out link in any emails that we send to you.
  3. Legitimate Interests - This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way.
  4. Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
  5. Vital Interest – This is where we need to process personal information in an emergency to protect an individuals safety. 

Your Rights 

You have a number of Rights under the Data Protection Legislation. If you would like to exercise any of these rights you can contact us using the contact details in the “Contact Us” Section. 

 

You rights under the Legislation are – 

 

The right to be informed about our collection and use of personal data 

You have the right to be informed about the collection and use of your personal data. This Privacy notice gives you this information.  

 

Right to access your personal information 

You have the right to access the personal information that we hold about. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from the point that we are able to confirm your identity. We will ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. 

 

Right to correction your personal information 

If any of the personal information we hold about you is inaccurate, incomplete or out of date, you can ask us to correct it. You can update your information thorough your online account or by contacting our customer services team. 

 

Right to restrict processing 

You have the right to ask us to restrict the processing of your personal data. For example, this may be because you have issues with the accuracy of the data we hold or the way we have processed your data. The right is not absolute and only applies in certain circumstances. 

 

Right to erasure 

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. 

 

Please note if you are using the Harry Hall Riding App you can deactivate your account at any time by visiting the settings page in the App Once your account is deactivated all your activity will be lost and cannot be reinstated. 

 

Right to portability 

The right to portability gives you the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit this data directly to another controller. 

 

Right to object 

You have the right to object to our processing of some or all of the personal data that we hold about you. This is an absolute right when we use your data for direct marketing but may not apply in other circumstances where we have a compelling reason to do so, for example if we have a legal obligation.  

You can change your marketing preferences at any time through our Preference Centre  

 

For more information about your privacy rights 

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make lots of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access the ICOs consumer information at https://ico.org.uk/for-the-public. 

 

Your Right to make a complaint 

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. 

Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have. 

Providing services to Children

Harry Halls website and services are not aimed at children and children using our website should only do so where they have the permission of their legal guardian. 

 

The Harry Hall Riding App is intended for use by people aged 13 and above. Children aged 13-15, inclusive, are required to gain parental consent to use the Services. You must not use the Services until you are 16 or are 13-15 and have parental consent. If you believe we may have accidentally received such information, please contact us immediately at   dpo@harryhall.com 

How we use your personal data 

We will use your personal information for a number of purposes namely to ensure we are providing our services to you in the ways that you would expect. We will particularly use personal information for the below purposes -  

 

To Process orders that you place and facilitate any returns we will take payment card details to process payments made to us, this is then processed by our chose payment processors 

  1. we will use your address to deliver your purchases to you and to facilitate any returns 
  2. we will use your contact information to keep you up to date on the status of your order. 

To provide you with a Harry Hall Account  

  1. To register an account with us we capture information such as your name, date of birth, contact and delivery information, and a password to protect your account.
  2. If you are taking insurance products we will also use information as described in the insurance section.
  3. We use this information on an ongoing basis to manage and provide secure access to your account and provide you with the services you request. 

To provide you with Insurance Services 

  1. If you are a club member or purchase any of our insurance products, we will collect additional information relating to your horse, equipment and previous claims history to ensure we can offer you the most appropriate product. 
  2. We may also ask you top provide information on previous criminal convictions to ensure that we, or our partners, are able to offer you insurance. 
  3. We will use your contact information to contact you about your insurance services including renewal. 
  4. We will share information with our insurance partners, underwriters and claims management companies who provide insurance services with us and who will be responsible for working with you should you need to make a claim. These organisations will also contact you directly in relation to your insurance. 
  5. We will also use your information to conduct pre insurance checks, including Political Exposure and Sanctions checks. These checks will be conducted through our insurance partners.

To answer any questions that you have or to follow up with you on any customer services enquiries  

  1. If you contact us through email, social media, phone or through our website we will use your information to answer your questions and to correspond with you. 
  2. We will record phone calls and maintain copies of your interactions with us and will use this on an ongoing basis for quality monitoring and to help us improve our services. 

 

To Manage and improve our business and our interactions with you  

We will use certain personal and technical information including information from Cookies to; 

  1. analyse and understand our consumer base 
  2. understand the effectiveness of our advertising campaigns 
  3. develop new products and services 
  4. secure our network 
  5. investigate and respond to service or security issues 
  6. ensure our website operates on multiple platforms 
  7. troubleshoot, test, support and maintain out website, App and other business services. 
  8. for logistical and demand forecasting. 

To meet our legal and regulatory obligations  

  1. We use your data to ensure we comply with any requirements imposed on us by law or court order, including disclosure to law or tax enforcement agencies and authorities or pursuant to legal proceedings. 
  2. We will share data with regulatory and other official bodies if they make formal requests. 
  3. We will maintain records to meet regulatory and tax requirements (including FCA requirements).

To Prevent and Detect Crime  

  1. We use your account information, order history and payment history to assist in monitoring for fraudulent transaction. 
  2. When you register an account, or contact our call centres we use your account information and previous purchase history information to assist in confirming your identity. 
  3. We use device identifiers and IP addresses in fraud prevention and investigation, and to maintain network and data security. 

To keep in touch with you and promote our products and services  

  1. If you give us your permission, we will use your information to send you promotional material and newsletters that we believe will be relevant to you including prize draws, competitions or survey requests. 
  2. We will use your information to make suggestions and recommendations on our website and around the web about goods and services that may be of interest to you. 

Note - You can unsubscribe from marketing communications at any time using the unsubscribe link in our email, by contacting our customer services team or through your online account.  

  1. We will also use your contact information to send you service message such as changes to this policy, updates to our terms and conditions, product recalls or information about your account – these communications are not marketing messages. 
  2. We may also contact you to take park in satisfaction surveys or for your for leave a review on a product that you have purchased – we will also use this information to help in developing our products and services. 

How long we retain your personal data 

We retain a record of your personal information in order to provide you with a high quality and consistent service and to evidence the actions we have taken on your behalf.  

 

In line with the Data Protection Legislation we only keep your personal information for the length of time we need it to  

  1. Deliver our services to you 
  2. Meet our Business needs 
  3. Meet our legal obligations 

Where you are an insurance customer we will retain information related to our insurance services for at least 6 years after the expiry of your product to meet our financial conduct obligations.  

Who we may share your personal data with 

In some circumstances we may need to share your personal data with third parties in order to

  1. Provide you with the service that you have asked for, 
  2. Meet our legal obligations,
  3. Run and manage our business, 

We may share your personal information with;  

  1. Law Enforcement or other public authorities that require us to release information
  2. To any organisation where it is necessary for us to establish a legal claim or to defend ourselves against such a claim 
  3. Other members of our group of companies as required for them to provide you with our group products or services including delivery of your goods and the provision of insurance services.
  4. Our professional advisors including accountants, legal professionals or insurers 
  5. Payment services providers who process payments on our behalf 
  6. Delivery service companies who deliver your goods to you 
  7. Providers of ancillary business support services such as Information Technology services (as a processor on our behalf) 
  8. Marketing service providers (as processors on our behalf) including organisations that help us communicate with you 
  9. Online Advertising providers that help us in showing advertising material to you on our site, on the internet and on social media (if you are opted in to Marketing)  
  10. Our insurance partners, underwriters and claims management companies as required to provide insurance services to you. This may include transferring your information to Equario Insurance (Guernsey) Limited as a Joint Controller in the provision of your insurance. The identity of the company that is responsible for your policy can be found in your insurance documentation.
  11. Any organisation in the event of the sale, merger, reorganisation, dissolution or disposal of our business. We will inform you of any such transfer or disclosure as required by law. 

In all cases we 

  1. only provide the minimum personal information that each party requires to carry out their duties
  2. only disclose personal information to organisations who we have a contractual relationship with or have an overriding legal requirement to hold the information 

International transfers of personal data 

In some instances your personal information may be processed outside the UK and the European Economic Area. For example, we work with suppliers and partners who may make use of cloud and /or hosted technologies across multiple geographies and jurisdictions. 

 

If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the UK or the EEA. 

 

Where we need to transfer your data outside the UK or EEA we will use one of the following safeguards: 

  1. The use of standard contractual clauses in contracts for the transfer of personal data to third countries or
  2. Transfers to a non-EEA country with privacy laws that give the same protection as the EEA. 

How we protect your personal data 

Data security is of great importance to Us and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure any information that we control

   

At a high level we have put the below measure in place:

  1. Limiting access to our buildings to those that we have determined are entitled to be there; 
  2. Implementing access controls to our information technology estate; 
  3. Limiting the availability of personal information to those that require access to that information; 
  4. All our employees and agents who have access to or are involved in the processing of personal information are contractually obliged to protect the confidentiality of personal information; 

Our websites may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. We cannot guarantee the content or privacy practices of any external websites and does not accept responsibility for those websites. 

Changes to this Policy 

We may change this Privacy Policy from time to time (for example, if the law changes). If the changes are material we will take steps to inform you via email or through our services.  

How to contact us 

If you would like to 

  1. exercise one of your rights as set out above,  
  2. have a question or a complaint about this policy, or 
  3. have a question or complaint about the way your personal information is processed 

You can contact us using the details below – 

  1.  By emailing us at - dpo@harryhall.com 
  2. By writing to us at – 

FAO Data Protection Officer 

Harry Hall International Limited, 

Park View Mills, 

Wibsey Park Avenue, 

Bradford,  

BD6 3QA

3. By calling our customer services team on 01274 711 011 

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