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 websites to purchase goods
   
3. Your use of our websites to purchase insurance services, and
   
4. Your use of the Harry Hall app.

This privacy policy refers to the websites harryhall.com, harryhallinsurance.com and related sub-domains.

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. 

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 

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 websites 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 websites operates on multiple platforms 
   
7. troubleshoot, test, support and maintain our 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 websites 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 

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. 

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, 

4 Coop Place, Hope Park Business Centre, Bradford, BD5 8JX