Privacy Policy
Hamillroad Software Limited
27th June 2023
Background:
Hamillroad Software Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our current and prospective customers. We will only collect and use personal data in the ways which are described here and which are consistent with our obligations and your rights under the law.
Information About Us
Hamillroad Software Limited is a private limited Company with company number 04375636 registered in England & Wales. Hamillroad Software Limited has a subsidiary company, Hamillroad Limited, also registered in England & Wales with company number 10930734 and VAT registration number GB 303 5174 39. All the information in this notice applies equally to this, and indeed to any other, subsidiary of Hamillroad Software Limited.
Registered Office: 1 Quayside, Bridge Street, Cambridge, CB5 8AB ENGLAND.
VAT number: GB 758 2307 19.
Data Compliance Manager: Kasia Kwasniak
Email address: finance@hamillroad.com.
Telephone number: +44 (0)1223 752640
Postal and trading addresses are the same as the Registered Office.
Information We Collect Directly from You
Information that you directly submit to us through our Services may include:
– Basic contact details including your name, address, phone number, email, Business name, Job title, Profession.
– Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.
Information We Collect through Cookies
We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.
Information We Obtain from Third Parties
Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
– Companies who support our Site and Services, such as Shopify.
– When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.
How We Use Your Personal Information
– Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfil your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and to enable you to post reviews.
– Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
– Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
– Communicating with you. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.
Cookies
Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.
Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.
How We Disclose Personal Information
In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:
– With vendors or other third parties who perform services on our behalf (e.g., IT management, data analytics, customer support, cloud storage, fulfilment and shipping).
– With business and marketing partners, including Shopify, to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
– When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
– With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
– In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
We have, in the past 12 months disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:
Category:
– Identifiers such as basic contact details and certain order and account information
– Commercial information such as order information, shopping information and customer support information
– Internet or other similar network activity, such as Usage Data
Categories of Recipients:
– Vendors and third parties who perform services on our behalf (such as Internet service providers, fulfilment partners, customer support partners and data analytics providers)
– Business and marketing partners
– Affiliates
We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.
We have “sold” and “shared” (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows.
Category of Personal Information
– Identifiers such as basic contact details
– Commercial information such as records of products or services purchased and shopping information
– Internet or other similar network activity, such as Usage Data
Categories of Recipients
– Business and marketing partners
User Generated Content
The Services may enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.
We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.
Third Party Websites and Links
Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.
Children’s Data
The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.
As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.
Security and Retention of Your Information
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.
How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.
Your Rights and Choices
Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.
– Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
– Right to Delete. You may have a right to request that we delete personal information we maintain about you.
– Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
– Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions
– Right to opt out of Sale or Sharing or Targeted Advertising. You may have a right to direct us not to “sell” or “share” your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the “sale” or “sharing” of information for the device and browser that you use to visit the Site
– Right to Limit and/or opt out of Use and Disclosure of Sensitive Personal Information. You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.
– Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
– Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
– Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
– Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
We use Shopify’s ad services such as Shopify Audiences to help personalize the advertising you see on third party websites. To restrict Shopify merchants that use these ad services from using your personal information for such services, visit https://privacy.shopify.com/en.
Complaints
If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.
International Users
Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission’s Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
Contact
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call +44 (0)1223 752640
or email us at finance@hamillroad.com or contact us at 1 quayside, Cambridge, Cambridge, ENG, CB5 8AB, United Kingdom.
For the purpose of applicable data protection laws, we are the data controller of your personal information.
What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal Data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
In simpler terms Personal Data is any information about you which enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data we use is described below.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details below.
b) The right to access the personal data we hold about you. We describe how to do this later in this notice.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details below to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details below to find out more.
e) The right to restrict or prevent the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way. See below to learn more about how we use your personal data.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided below.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Personal Data Do We Collect?
We may collect some or all of the following personal data and this may vary according to your relationship with us:
Name;
Business address;
Email address;
Telephone number;
Business name;
Job title;
Profession;
Your personal data may be obtained from third party companies, as long as the data meets the GDPR requirements:
How We Use Your Personal Data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and/or bypost that you have requested. You may un-subscribe or opt-out at any time by emailing us at finance@hamillroad.com or writing to us at our trading address.
With your permission, and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to protect your rights fully and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We do not use automated systems for carrying out decision-making or profiling. Please contact us to find out more using the details below.
How Long Will We Keep Your Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for no longer than 18 months after it was last used: A quarterly review (or within a reasonable time, as business conditions permit) will be used to assess whether data is being held necessarily and in accordance with the GDPR principles.
How and Where Do We Store or Transfer Your Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We would only share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
Please contact us using the details below for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including: transferring it using SSL and storing it in encrypted form.
Do We Share Your Personal Data?
We will not share any of your personal data with any third parties with one important exception: In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any personal data is transferred outside the EEA, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us, using what is called a “subject access request” for details of that personal data and, if we do hold such personal data, for a copy of it.
All subject access requests should be made in writing and sent to finance@hamillroad.com.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example if you repeatedly ask for the same information) then we may charge you to cover our administrative costs in responding.
We will do our best to respond to your subject access request within seven working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Sally Dowding):
Email address: finance@hamillroad.com
Telephone number: +44 (0)1223 752640
Address: 1 Quayside, Bridge Street, Cambridge, CB5 8AB ENGLAND.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. Changes may be necessary, for example, if the law changes, or if we change our business in a way which affects personal data protection.
Any changes will be made available on our website.
Last updated: 27th of June 2023
Links to policies:
Privacy Policy
Data Protection Policy
Data Retention Policy
Cloud Data Protection Policy