Privacy Policy

We at Hilvy Ltd respect and are committed to protecting the privacy of every individual who visits our website.

Last updated: 01/04/2022

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.hilvy.io including any information you may provide through our site when you purchase a product or service, sign up to our newsletter. or contact us via any of our contact forms.

By providing us with your data, you warrant to us that you are over 13 years of age.

Hilvy Ltd. located at 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ, company number 11529251 (“Hilvy”) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Hilvy Ltd

info@hilvy.io

71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@hilvy.io

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, maiden name and last name
  • Contact Data may include your billing address, email address and telephone numbers.
  • Financial Data may include your bank account details (submitted directly to Stripe).
  • Transaction Data may include details about payments between us and other details of purchases made by you.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.]

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

  • Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by, phone, email or otherwise, including when you:
  • order our products or services;
  • subscribe to our service or publications;
  • request resources or marketing be sent to you;
  • enter a competition, prize draw, promotion or survey; or give us feedback.
  • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
  • analytics providers such as Google based outside the EU;
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at info@hilvy.io

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at info@hilvy.io if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose/Activity

To register you as a new customer

Type of data

(a) Identity

(b) Contact

Lawful basis for processing

Performance of a contract with you

Purpose/Activity

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

Type of data

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Lawful basis for processing

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Lawful basis for processing

(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

Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Lawful basis for processing

(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

Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

(c) Technical

Lawful basis for processing

(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

Purpose/Activity

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing

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

Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical

(b) Usage

Lawful basis for processing

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Lawful basis for processing

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

Marketing communications

You will receive marketing communications from us if you have:

  1. requested information from us or purchased goods or services from us; or
  2. if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  3. in each case, you have not opted out of receiving that marketing.

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

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@hilvy.io at any time].

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@hilvy.io

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. 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 in paragraph 4 above:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

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

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at info@hilvy.io if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

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

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to the processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@hilvy.io

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.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

This Cookie Policy explains how Hilvy, Ltd and our affiliates use cookies and similar technologies to recognise you when you visit our Websites.

It explains what these technologies are and why we use them, as well as your rights to control our use of them.

What are cookies?

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website.

When you visit the site again, the cookie allows that site to recognise your browser. Cookies may store user preferences and other information.  

Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page.

For example, you may have already downloaded a form or white-paper or read a specific article last time you were on our Website, a cookie helps us to recall your specific information on subsequent visits and we may then show you similar articles or avoid showing you the same offer that had already downloaded .

Cookies set by the website owner (in this case, Hilvy) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies".  Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics).

The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites.  For example, Hilvy keeps track of the Websites and pages you visit within Hilvy, in order to determine what portion of the Hilvy Website is the most popular or most used.

This data may also be used to deliver customised content and promotions within the Hilvy Website for customers whose behaviour indicates that they are interested in a particular subject area.

Third parties serve cookies through our Websites for advertising, analytics and other purposes.  This is described in more detail below.

What types of cookies do we use and how do we use them?

The specific types of first and third party cookies served through our Websites and the purposes they perform.

These cookies include:

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites, Subscription Service and Mobile Apps and to use some of its features, such as access to secure areas.

Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Websites, Subscription Service and Mobile Apps but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites, Subscription Service and Mobile Apps are being used or how effective our marketing campaigns are, or to help us customise our Websites for you.

Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Websites, Subscription Service or Mobile Apps through third party social networking and other websites. These cookies may also be used for advertising purposes too.

How can I control cookies?

You have the right to decide whether to accept or reject cookies.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising.  If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

You may opt out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/).

Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

Essential website cookies: Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.

Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements.

This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you.

The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons.  Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at info@hilvy.io

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