Privacy Policy – Hardington Capital

WHAT IS THE PURPOSE OF THIS NOTICE?

Hardington Capital LLP (“Hardington”, “We” or “Us”) are committed to protecting and respecting your privacy. You can contact us at 17 Grosvenor Hill, London, W1K 3EB or info@hardingtoncapital.com.

This privacy notice describes how we collect and use your personal data in accordance with the General Data Protection Regulation (“GDPR”) and other applicable laws.

We are a “data controller”. This means that we are responsible for deciding how and why we hold and use your personal data. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to you in relation to your use of our website at www.hardingtoncapital.com, or employment with Hardington.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your personal data, so that you are aware of how and why we are using your personal data.

DATA PROTECTION PRINCIPLES

We will comply with data protection law in relation to your personal data. The law says that the personal data we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

THE TYPES OF PERSONAL DATA WE MAY HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where your identity has been removed (i.e. anonymous data).

We may collect, store, and use the following categories of personal data relating to you:

Information you give us. You may give us information about you by filling in forms on the Site, corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Site, subscribe to our services or when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number, financial and your personal description.
Information we collect about you. With regard to each of your visits to the Site we may automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may also receive information about you where we carry out any Know Your Customer (“KYC”), sanctions or other client checks that we are required to make, in addition we may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

HOW WE WILL USE PERSONAL DATA ABOUT YOU

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:

These interests may include:

Where we need to perform a contract we have with you. We may also disclose your personal data to our business partners, suppliers and sub-contractors in order where necessary for us to do so.
Where we need to comply with a legal obligation, including carrying out any KYC or similar checks.
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.

These interests may include:

Providing you with information about other goods and services we offer that are similar to those that you have already purchased and telling you about our other products and services; and
Where we enter into discussions to, sell all or a part of our business or a property to which your personal data relates;
Processing necessary to administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to improve the Site to ensure that content is presented in the most effective manner for you and for your computer and to allow you to participate in interactive features of our service when you choose to do so;
Notifying you about changes to our services;
Ensuring that content from our site is presented in the most effective manner for you and for your computer;
The use of analytics and search engine providers that assist us in the improvement and optimisation of our site; and
As part of our efforts to keep the Site safe and secure and to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

Where you give your consent to processing.

We may share your information as part of aggregated information where this does not to provide any identifiable information about you with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.

We may also use your personal data in the following situations:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest.

Where you must provide personal data to us in relation to a contract we may not be able to perform this agreement without such data.

We may process your personal data to assist in the prevention of crime or to protect the vital interest of you or any other person.

We may use your personal data to undertake searches against sanction lists maintained by United Kingdom or United States governments, including those lists maintained by the United Kingdom Treasury and the United States Office of Foreign Assets Control or any other government list from time to time considered appropriate by us.

“Special categories” of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process such special categories of personal information about you in the following circumstances:

With your explicit written consent.
Where we need to carry out our legal obligations and in line with our data protection policy.
Where it is needed in the public interest, such as for equal opportunities monitoring in line with our data protection policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may have to share your personal data with third parties, including third-party service providers and other entities in our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).

We require third parties to respect the security of your personal data and to treat it in accordance with the law.

HOW LONG WILL YOU USE MY INFORMATION FOR?

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 and in accordance with our policy. To determine the appropriate retention period for your 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.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with this policy and applicable law.

INTERNATIONAL TRANSFERS

In order for us to be able to achieve these processing purposes within the global Hardington organisation, Hardington transfers your personal data to its service providers and to certain of its group companies to enable the global organization to work together and to support reporting relationships across the Hardington group. Hardington will provide an adequate level of data protection should your personal data be transferred to service providers and Hardington group companies in countries outside the European Economic Area.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

If you have any questions about this privacy notice or how we handle your personal data, please contact info@hardingtoncapital.com 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. You can find out more about your rights in relation to your personal data at www.ico.org.uk.

Please note that you have rights to obtain a copy of your personal data and in certain situations to obtain correction, erasure and restriction of processing of your personal data. You have a right of data portability.

Where processing is based on your consent you have a right to withdraw this at any time.

You have the right to ask us not to process your personal data for marketing purposes or for purposes that are in our legitimate interests. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

You can also exercise any of your rights at any time by contacting us at Hardington Capital LLP, Montpelier House, 106 Brompton Road, London SW3 1JJ, info@hardingtoncapital.com

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Hardington Capital LLP, 17 Grosvenor Hill, London, W1K 3EB. info@hardingtoncapital.com