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Privacy Notice

Welcome to the PRIVACY NOTICE of Frank Hirth.

Frank Hirth respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

 

IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Frank Hirth collects and processes your personal data, in accordance with the General Data Protection Regulations (GDPR).

It is important that you read this privacy notice 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 notice supplements all other notices and is not intended to override them.

CONTROLLER 

Frank Hirth is made up of different legal entities:

  • Frank Hirth PLC. 1st Floor, 236 Gray's Inn Road, London, WC1X 8HB, United Kingdom.
    Registered In England: No. 03945095
  • Frank Hirth & Co. LLP. 1st Floor, 236 Gray's Inn Road, London, WC1X 8HB, United Kingdom
    Registered In England: No. OC313751
  • Frank Hirth LLC. 100 Wall St, Suite 802, New York, NY 10005, USA
  • Frank Hirth LTD. Level 4, Office 2, 24 Johnston Street, Wellington, 6011.
    Registered In New Zealand: No. 6133327

This privacy notice is issued on behalf of the entities above, hereinafter “Frank Hirth”.

We have appointed a Data Protection Officer (DPO) who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CHANGES TO THE PRIVACY NOTICE

Any changes we make to our privacy policy notice in the future will be updated on our website at: www.frankhirth.com/privacy-notice

THIRD-PARTY LINKS 

Our 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 notice of every website you visit.

THE TYPES OF DATA WE HOLD ABOUT YOU

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 as follows:

  • Identity Data includes (but not limited to) first name, maiden name, surname, username or similar identifier, marital status, title, date of birth, gender, nationality, country of residence, the nature of our relationship with you (e.g. client, referral partner, professional advisor to Frank Hirth).
  • Contact Data includes (but not limited to) work address, residential/home address, delivery address, email address and telephone numbers.
  • Financial Data includes (but not limited to) bank account and payment card details together with any and all financial, tax, wealth and pension information provided to or generated by us in the performance of our agreement with you.
  • Transaction Data includes (but not limited to) details about payments to and from you and other details of paid for products and services we are providing to you.
  • Technical Data includes (but not limited to) internet protocol (IP) address, your login data, 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 our website.
  • Profile Data includes (but not limited to) your username and password, purchases or orders made by you, details of the contact we have had with you in relation to the provision of our services, information about any complaints and enquiries you make to us, your interests, preferences, expertise/areas of work, feedback and survey responses.
  • Usage Data includes (but not limited to) information about how you use our website, products and services. Please see our Cookie Policy for more information on how we use cookies on our website.
  • Marketing and Communications Data includes (but not limited to) your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Recruitment Data (but not limited to) any data submitted directly by you or via a third party (for example a recruitment agency) in a CV or other form of job application. This may include previous work history or professional memberships/qualifications as well as other data types listed above such as Identity Data. We do not require or request 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).  Where you include any information related to a Special Category of Personal Data within a job application we will retain it in line with our data retention policy.  For recruitment purposes we will keep applications for 6 months from the date the candidate is notified of the outcome of the process unless a formal offer of employment is made, in which case please refer to our privacy notice for employees.

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 notice.

We don’t collect Special Categories of Personal Data via our website, however, if we are providing a service to you or if you are applying for a job then we will tell you at the time that we are collecting it and the reason.

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 products or services). Alternatively, we may be unable to comply with our legal or regulatory obligations. 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, Financial, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you:
    • Enquiry about our products or services, or you request a proposal from us in respect of our services;
    • or your employer engages us to provide our services and also during the provision of those services;
    • create an account on our website;
    • make a payment via https://payments.frankhirth.com;
    • subscribe to our service or publications;
    • sign up to an event;
    • download content;
    • request marketing to be sent to you;
    • you contact us by email, online via our website forms, email, telephone, post or social media (for example when you have a query about our services);
    • enter a competition, promotion or survey;
    • give us some feedback; or
    • request to be added to our database as a referrer;
    • from third parties and/or publicly available resources (for example, from your employer or from Companies House).
  • 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may purchase or receive personal data about you from various third parties and public sources. In this instance, we are using data that already exists and therefore are not responsible for the origination or accuracy of it. Examples of where we may get this information are set out below:

Technical Data from the following parties:

  1. analytics providers such as Google based inside or outside the EU;
  2. advertising networks such as Google based inside or outside the EU; and
  3. search information providers such as Microsoft or Google based inside or outside the EU. 
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Worldpay based inside OR outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU or the Internal Revenue Service based in the USA.
  • Companies we collaborate with such as other professional advisors when we host joint events inside OR outside the EU.
  • Organisers of events and conferences we are a part of either by sponsorship or attending as a delegate.
  • Identity and Contact Data from external anti-money laundering verification providers.

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 or your employer. This is necessary for the performance of our services and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
  • Where it is necessary for our legitimate interests (or those of a third party) provided that those interests do not override your interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development and statistical management purposes.
  • Where we need to comply with a legal or regulatory obligation.
  • We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Click glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

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. 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis 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
(b) Contact

Performance of a contract with you

To process and deliver your order for our services including:
(a) Order fulfilment. Manage payments, fees and charges
(b) Billing: Collect and recover money owed to us
(c) Notify you of updates to legislation
(d) Request information from you necessary for us to perform our services

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Notify you about any changes to our services
(c)  Seeking your thoughts and opinions on the services we provide

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) 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)
(b) Necessary to comply with a legal obligation

To deliver relevant 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 products or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

To process a job application (direct through a third party) which will include:
(a) Updating you on the status of your application
(b) Invite you to meetings with Frank Hirth employees (where relevant)
Make offers of employment

(a) Identity
(b) Contact
(c) Recruitment

(a) Necessary for us to assess your suitability for a position at Frank Hirth
(b) Necessary to make offers of employment where relevant

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use. You can find a link to this from any marketing emails that we send you.

PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, Technical, Usage, Profile Data and Marketing and Communications 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, signed up to our referral database 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 outside the Frank Hirth group of companies for marketing purposes.

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by following the ‘Manage your preferences’ to adjust your marketing preferences or the ‘Opt-out from future mailings’ links 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 a service, service experience 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 our 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.

DISCLOSURES OF YOUR PERSONAL DATA

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 as set out in the glossary
  • External Third Parties as set out in the glossary
  • 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 notice.

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.

TRANSFERRING PERSONAL DATA OUTSIDE THE EEA

We will transfer the personal data we collect about you to the following countries outside of the EEA: USA and New Zealand, in order to perform our contract with you.

There is an adequacy decision by the European Commission in relation to New Zealand therefore it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.

As there is no adequacy decision by the European Commission in relation to USA it will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation. However, when applicable we will transfer your personal data to the USA in accordance with EU data protection law requirements by using model contract clauses that have been approved by the European Commission.  Such a transfer may also be necessary for the performance of our contract with you or through obtaining specific consent from you.

DATA SECURITY

We have put in place commercially reasonable and 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 suspected breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

  • The requirements of our business and the services provided;
  • Any statutory and legal obligations;
  • The purposes for which we originally collected the personal data;
  • The lawful grounds on which we based our processing;
  • The types of personal data we have collected;
  • The amount, nature/categories, and sensitivity of the personal data;
  • The potential risk of harm from unauthorised use or disclosure of your personal data;
  • Whether the purpose of the processing could reasonably be fulfilled by other means.

Details of retention periods for different aspects of your personal data are available in our retention policy. In relation to marketing and referrals only:

  • Should you not reply to our communications in line with GDPR regarding acceptance of our privacy notice and opt-in for either marketing communications, or to remain on our database as a referrer; your identity, contact, profile and marketing and communications data, will be kept for a period of 12 months and then deleted.
  • Should you opt out of marketing communications and/or our referral database, your details (identity, contact, profile and marketing and communications data), will be kept on a suppression list that is only accessible by a limited number of staff within Frank Hirth.  

YOUR LEGAL RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes which we need to be made aware by contacting us.

YOUR RIGHTS IN CONNECTION WITH PERSONAL DATA

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

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully
  • Request correction of your personal data.
  • 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 also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below.)
  • 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request restriction of processing your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
  • Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

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. Under GDPR article 12.3, this period will be extended by two further months where necessary, taking into account the complexity and number of requests.

CONTACT DETAILS 

Our full details are:

Data Protection Officer: Andrew Grieve
Address: Frank Hirth PLC, 1st Floor, 236 Gray's Inn Road, London, WC1X 8HB, United Kingdom
Email address: dpo@frankhirth.com
Telephone number: +44 (0)20 7833 3500

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The ICO’s contact details are as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone number: 0303 123 1113 (local rate) or 01625 545 745
Website: https://ico.org.uk/concerns

Our ICO Registration Number is: Z4733533


GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
INTERNAL THIRD PARTIES

Other companies in the Frank Hirth Group acting as joint controllers or processors and who are based in the United Kingdom, United States of America and New Zealand, and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES  

  • Service providers acting as processors based in the EU who provide IT and other system administration services
  • Services providers acting as processors including designers and printers, market researcher and telesales providers based in the United Kingdom, United States of America and New Zealand who provide Marketing Services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, United States of America and New Zealand who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, Internal Revenue Service, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, United States of America and New Zealand who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. 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 also have the right to 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 of 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 the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contact Us

Frank Hirth
1st Floor, 236 Gray's Inn Road,
London, WC1X 8HB

tel: +44 (0)20 7833 3500
fax: +44 (0)20 7833 2550
email: mail@frankhirth.com

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