2 Privacy Notice
Your privacy is important to us. This privacy statement explains how we, HPD Software (hereafter 'HPD'), will collect, store and process your Personal Data in line with the requirements of relevant privacy laws and regulations (hereafter ‘Data Protection Laws’).
2.1 What Personal Data do we collect?
In the running and maintenance of our website, we collect and process some Personal Data about you. You provide us with this data directly when you fill out an online registration or request form. We also collect some information indirectly from you by recording how you interact with our website by using technologies such as cookies. The data we collect can include one or more of the following:
- Contact details:
- Your first name, last name, job title, email address, phone number and company name
- Location data:
- Your region of residence or business operation
- Use of our site data:
- Traffic data, location data and IP addresses derived from details of your visits, the pages you have viewed and the resources that you access
- Usernames and passwords for our websites and online services
- Images, audio or video recordings of you during company meetings, events and conferences
We do not normally obtain or purchase any data about you from third parties, but if we receive such data, it will be the responsibility of HPD to ensure appropriate data security.
2.2 Why do we collect your Personal Data?
We collect and process your Personal Data on the basis of legitimate interest, where both you and HPD benefit from the business relationship. This may take the form of a contractual requirement, or a requirement necessary to enter into a contract. You are not obliged to provide your Personal Data. However, as a possible consequence of not providing the required data, HPD may not be able to support your business appropriately. HPD does not use your Personal Data for automated decision-making processes or profiling.
In providing your Personal Data, you support HPD in improving your business, in ways such as:
- Direct marketing, newsletters, and relevant articles
- Recommending new products and services that will better your business
- Providing you with information you have requested from us
- Informing you of upgrades and new modules available for your HPD
We also use your Personal Data for business, regulatory and legal purposes:
- To meet the requirements of our contract
- To support commercial discussions between us
- Providing you with our services/updates/promotions etc.
- Dealing with your requests
- Getting in touch in case we need to contact you, for reasons such as policy changes, contractual arrangements or service notifications
- Internal administrative purposes
We may at times record audio and/or video meetings through web conferencing software for the purpose of providing you with training or informing you about our products and services during public conferences and events. We will only do so where it is a clear benefit to you and the organisation. You will not be requested to provide your consent for the recording as legitimate interest is the lawful basis being relied on. You will be notified beforehand that audio and/or video recording will take place. If you do not want to be recorded, you could:
- For audio and video conference recordings: Mute your microphone, turn off your webcam and/or choose not to contribute.
- For public conferences and events: Stand in designated areas where recording equipment will not capture you.
Audio or video recording for any other purpose, not outlined above, will not be lawful under this basis and another valid lawful basis must be sought, such as consent.
The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
In any event, we are committed to ensuring that the information we collect and use is appropriate for the purposes above, and does not impact your privacy. We only collect data that is relevant to the purpose of processing and no information is collected without reason.
When HPD contacts you, our aim is not to be intrusive, and we endeavour not to ask irrelevant or unnecessary questions.
If HPD intends to process the Personal Data for a purpose other than those stated in this document, we shall provide you with the appropriate information and request your consent before doing so.
2.3 With whom will we share your Personal Data?
HPD will not share your Personal Data with any organisation outside of the HPD group of companies, consisting of;
- HPD Software Limited, registered in England
- HPD Service Centre Limited, registered in England
We will not share your Personal Data with any third party without first obtaining your consent. Should you provide your consent, we will only pass your data on to third parties with whom HPD has a contractual arrangement in place, who will be obliged to keep your details securely, and to use them only for the contracted purpose. When they no longer need your data to fulfil this service, they will dispose of the details in line with HPD's procedures.
There will be circumstances where your Personal Data may be transferred across borders to countries outside of the EEA, within the HPD group of companies. For such cross-border transactions, appropriate safeguards have been put in place to protect your Personal Data and to ensure it is processed, stored and disposed of appropriately.
2.4 Where will your Personal Data be stored?
Personal data collected by HPD may be stored and processed in your region or in any other country where HPD or its service providers maintain facilities. HPD maintains data centres in the United Kingdom, Australia and the United States. HPD's service providers maintain data centres in the United Kingdom and other countries in the European Union, Australia and the United States.
Typically, the primary storage location and any backup location is in your region. HPD has chosen the storage location(s) to operate efficiently, to improve performance and to create redundancies to protect the data in the event of an outage or other problem. We take steps to ensure that we process the data we collect according to the provisions of this privacy notice and the requirements of laws applicable at the data location.
Data HPD collects from you may be transferred to, and stored at, a country outside the European Economic Area ("EEA"). We will not do this unless (i) an adequacy finding has been made under the Data Protection Laws that the relevant jurisdiction provides an adequate level of protection; or (ii) we have put in place appropriate safeguards as required under the Data Protection Laws for such processing or transfers.
2.5 For how long will we keep your Personal Data?
We govern data retention periods according to specific business-sector requirements and stated practices, as well as the type of data and the context in which we collected the data.
HPD is required to retain some information in accordance with the law, such as information needed for income tax and audit purposes, for a period no longer than that specified by such laws.
For as long as we maintain a non-contractual business relationship, and notwithstanding any legal requirement, as stated above, we will retain your data for a maximum of 5 years from the last date of contact. After this time, we will permanently dispose of your data.
If you become a client of ours under contract, we will retain your data for the duration of our relationship and, notwithstanding any legal requirement as stated above, for a maximum of 5 years after termination of the contract.
We may retain Personal Data for additional periods depending on individual business needs. You will be contacted and kept informed regarding such requirements. HPD will always endeavour to only keep your data for as long as deemed necessary.
If at any time before the end of the stated retention period you would like us to remove your data from our database or your preferences otherwise changed, notwithstanding any legal requirement as stated above, please contact us at firstname.lastname@example.org.
2.6 What are your rights regarding your Personal Data?
At any point while HPD is in possession of or processes your Personal Data, as the Data Subject you have the following rights:
- The right of access: you have the right to request a copy of the information that we hold about you.
- The right of rectification: you have the right to correct data that we hold about you that is inaccurate or incomplete.
- The right to be forgotten: in certain circumstances, you can ask for us to erase the data we hold about you from our records.
- The right to the restriction of processing: where certain conditions apply, you have the right to restrict the processing.
- The right of portability: you have the right to have the data we hold about you transferred to another organisation.
- The right to object: you have the right to object to certain types of processing such as direct marketing and automated processing, including profiling. You also have the right to be subject to the legal effects of automated processing or profiling.
- The right to judicial review: if HPD refuses your request under rights of access, we will provide you with a reason why.
We will forward on all of the above requests should there be a third party involved in the processing of your Personal Data.
You can find out more information about HPD’s Subject Access Request procedures, or submit a Subject Access Request to HPD, by following this link.
2.7 How can you access and control your Personal Data?
If HPD holds Personal Data about you, you can request the following information about the processing of the data:
- The identity and contact details of the person or organisation that has determined how and why to process your data
- The contact details of the data protection officer, where applicable
- The purpose of the processing as well as the legal basis for processing
- Information about the legitimate interest of HPD, if applicable
- Information about the type of data we collect, store and process
- The recipient(s) to whom we will disclose the data
- Information about the transfer of data outside of the EEA, if applicable
- How long we will retain the data
You can also request the following at any time:
- To view, update, correct or delete any of your Personal Data that HPD holds about you
- To obtain a copy of your data
- To restrict certain access or block certain restrictions
- To restrict certain processing
- To object to any communications
- To withdraw consent
You can send any request to email@example.com. When making requests regarding your Personal Data, you will be asked to verify your identity.
2.9 How can you file a complaint?
If you wish to make a complaint about how HPD, or other third parties contracted by HPD, process your Personal Data, or how we have previously handled your complaint, you have the right to complain directly to the Supervisory Authority and HPD.
The details for each are:
- Information Commissioner’s Office (ICO)
- Please use the Data Privacy contact details below
2.10 Who can you contact?
As the data controller, HPD is responsible for your Personal Data that it collects. Should you wish to contact someone regarding any of the information above, please contact us at firstname.lastname@example.org.
Last updated on 21st June 2021 as version 4.1.