Privacy and Cookies Policy
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. Notwithstanding, the other provisions of this Section 1 by using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. If you would like to opt out from that consent, please contact us immediately via compliance@hedhntz.com to enquire further.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via compliance@hedhntz.com.
1.5 In this policy, “we”, “us” and “our” refer to Hedhntz Group Ltd. For more information about us, see Section 19.
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely [the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include executive search and business enhancement advisory or consultancy services. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent or our legitimate interests, namely the proper management of our customer relationships.
2.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.12 We may process data specified in clause 2.2, 2.3, 2.4, 2.5, 2.6, 2.7, 2.8, 2.9, 2.10, and clause 2.11. This data may include any data listed in the clauses 2.2 up until 2.11 inclusive. The source of this data is but also not limited to questionnaire survey, face-to-face interview, telephone interview, group techniques (interview, facilitated workshop, focus group), document review, inventory data sources, identify data stores and data elements and tips and hints. This data may be processed for:
The legal basis for this processing is consent or our legitimate interests, namely provision of executive search, consultancy and business enhancement advisory services or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.13 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.14 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.15 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.1 We will use your personal data for the purposes of automated decision-making in relation to when the decision is necessary for entering into, or performance of, a contract between the individual and the controller; the decision is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or the decision is based on your explicit consent; and the controller has implemented suitable measures to safeguard the individual’s rights and freedoms and legitimate interests (which includes at least a means for the individual to obtain human intervention, express his or her point of view and/or contest the decision)
3.2 This automated decision-making will involve any IT or software shortlisting processes only if necessary for entering into, or performance of, a contract between the individual and the controller; or upon individuals instructions for the performance of the contract between the individual and us.
3.3 The significance and possible consequences of this automated decision-making are meeting candidate’s or client’s requirements for entering into, or performance of, a contract between the individual and the controller.
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found via compliance@hedhntz.com
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose personal data specified in clause 2.3 and clause 2.4 to our suppliers or subcontractors identified by requesting a supplier info via compliance@hedhntz.com insofar as reasonably necessary for entering into, or performance of, a contract between the individual and the controller.
4.4 Financial transactions relating to our website and services are or may be handled by our payment services providers, where the information can be requested via ewelina@hedhntz.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices by contacting us via ewelina@hedhntz.com.
4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to your relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers within UK or to EEA however, will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://bit.ly/2nTZWUz or the use of binding corporate rules, a copy of which you can obtain from our Compliance Team via compliance@hedhntz.com.
5.3 The hosting facilities for our website are situated in UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://bit.ly/2nTZWUz or from Compliance Team via compliance@hedhntz.com.
5.4 The IT maintenance facilities are situated in UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://bit.ly/2nTZWUz or from Compliance Team via compliance@hedhntz.com.
5.5 We have been advised by our website developers that their server is based within the United Kingdom or Europe and will always be in this geographical location (currently in France). Link to their Privacy Policy is available via compliance@hedhntz.com. As per their terms and conditions with us they may need to change the location of their servers in the future for performance or other reasons, but they will always be in UK or Europe.
5.6 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data, we need to collect we may not be able to continue to provide work-finding or consultancy services to you.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data category listed in clause 2 will be determined based on legitimate interest of contractual obligations or legal requirements that we must comply with.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
7.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
7.7 The Company takes every precaution to protect our users’ information, (e.g. but not limited to firewalls, browser certification technology, encryption, limited access, use of passwords etc. as appropriate].
7.8 The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
7.9 If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may or will notify you of changes or significant changes to this policy by email or through the private messaging system on our website.
9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by requesting confirmation of data and/or links allowing you to access the data stored on secure inhouse platform from Compliance Team via compliance@hedhntz.com.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us by contacting Compliance Team via compliance@hedhntz.com in addition to the other methods specified in this Section 9.
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. Please be aware that the Company is also not responsible for the privacy practices of such other sites. When you leave our site, we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
10.3 If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business
11.1 Our website and services are targeted at persons over the age of 16 years old.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
14.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: provision of services specified in this policy).
(b) status – we use cookies [to help us to determine if you are logged into our website (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice.
(c) personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice.
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice.
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice.
(f) analysis – we use cookies [to help us to analyse the use and performance of our website and services (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice; and
(g) cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq (also http://bit.do/eopaS). Please note however that any further technical information is beyond our remit, therefore we would strongly recommend you seek professional legal advice.
15.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
15.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: only Google Analytics Cookies are used. Please refer to the following info: https://bit.ly/2lFtpkq
15.4 The site also uses the following WordPress cookies when a user is logged into the WordPress dashboard. This service uses cookies for the purposes listed in 15.1. You can view the privacy policy of this service provider at https://automattic.com/privacy/. The relevant cookies are: https://bit.ly/2lJpaEx
15.5 WordPress Definition (please note this has been taken directly from https://wordpress.org). […] WordPress is open source software you can use to create a beautiful website, blog, or app. Beautiful designs, powerful features, and the freedom to build anything you want. WordPress is both free and priceless at the same time. 30% of the web uses WordPress, from hobby blogs to the biggest news sites online. Extend WordPress with over 45,000 plugins to help your website meet your needs. Add an online store, galleries, mailing lists, forums, analytics, and much more […].
Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17.1 You can manage your preferences relating to the use of cookies on our website by contacting our Compliance Team via compliance@hedhntz.com
18.1 This website is owned and operated by Hedhntz Group Ltd (also known as “The Company”).
18.2 We are registered in England and Wales under registration number 10738012, and our registered office is at 68 King William Street, London EC4N 7HR.
18.3 Our principal place of business is at Hedhntz Group Ltd of 68 King William Street, London EC4N 7HR.
18.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
19.1 We are registered as a data controller with the UK Information Commissioner’s Office.
19.2 Our data protection registration number is ZA249674.
20.1 Our representative within the European Union with respect to our obligations under data protection law is our Data Protection Officer – Ewelina Janiec of Hedhntz Group Ltd; you can contact our representative by:
email – ewelina@hedhntz.com
phone – 0203 633 5411.
21.1 Our data protection officer’s contact details are:
email – ewelina@hedhntz.com
phone – 0203 633 5411.
If you wish to complain about this privacy notice or any of the procedures set out in it, or request a copy of Data Protection Procedure, please contact Ewelina Janiec of Hedhntz Group Ltd via:
email – ewelina@hedhntz.com
phone – 0203 633 5411.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.