HANHAA LIMITED PRIVACY POLICY – May 2018

Who are we?

Hanhaa Limited, Tintagel House, 92 Albert Embankment, London SE1 7TY, United Kingdom
2SF, United Kingdom, contact email gdpr@Hanhaa.com

What does this Policy cover?

We at Hanhaa Limited take your personal data seriously. This policy:

  • sets out the types of personal data that we collect about you;
  • explains how and why we collect and use your personal data;
  • explains how long we keep your personal data for;
  • explains when, why and with who we will share your personal data;
  • sets out the legal basis we have for using your personal data;
  • explains the effect of refusing to provide the personal data requested;
  • explains the different rights and choices you have when it comes to your personal data; and
  • explains how we may contact you and how you can contact us.

What personal data do we collect about you?

We collect the information necessary to be able to respond to in-bound enquiries, product
sales enquiries, account management processes, technical support, product and service
developments and accounting enquiries
We do not collect sensitive personal data about you, but if we do need to collect sensitive
personal data from you, and further process this data, we will only do so where you have
given your explicit consent.

Where do we collect personal data about you from?

The following are the different sources we may collect personal data about you from:

  • Directly from you via website forms;
  • By meeting or word of mouth, for example you may be recommended by a colleague
    or met with us and provided a business card.
    How and why we use your personal data?
    We use your personal data to respond to your in-bound enquiry or to update you with
    technical information, details of other software and services, meetings/conferences and
    updates on the services we provide and news about our company

How long do we keep your personal data for?

We only retain your information for as long as is necessary for us to use your information as
described above or to comply with our legal obligations. However, please be advised that we
may retain some of your information after you cease to use our services, for instance if this
is necessary to meet our legal obligations, such as retaining the information for tax and
accounting purposes.

When determining the relevant retention periods, we will take into account factors including:

a. our contractual obligations and rights in relation to the information involved;
b. legal obligation(s) under applicable law to retain data for a certain period of time;
c. statute of limitations under applicable law(s);
d. (potential) disputes;
e. if you have made a request to have your information deleted; and
f. guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
We do not share your data with third parties unless we have your explicit agreement for us
to do so in the case of our Supplier Showcase service.

What legal basis do we have for using your information?

For providing software and services solutions data processing is necessary for our legitimate
interests in that we need the information in order to support our customers.

What happens if you do not provide us with the information we request or ask that we
stop processing your information?

If you do not provide the personal data necessary or withdraw your consent for the
processing of your personal data, we may not be able to support you as a customer.

Do we make automated decisions concerning you?

No, we do not carry out automated profiling.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal
data when you browse.

Do we transfer your data outside the EEA?

No, we do not transfer personal data out of the EEA, but if we did need to transfer data out
of the EEA to a country which has not been deemed to provide adequate data protection
standards, we always have security measures and approved model clauses in place to
protect your personal data. To find out more about how we safeguard your information as
related to transfers contact us on GDPR@hanhaa.com.

What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further
information and advice about your rights can be obtained from the data protection regulator
in your country.

Rights: What does this mean?

The right to be informed
You have the right to be provided with clear, transparent and easily understandable
information about how we use your information and your rights. This is why we’re providing
you with the information in this Policy.

The right of access
You have the right to obtain access to your information (if we’re processing it), and certain
other information (similar to that provided in this Privacy Policy). This is so you’re aware and
can check that we’re using your information in accordance with data protection law.

The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.

The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request
the deletion or removal of your information where there’s no compelling reason for us to
keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is
restricted, we can still store your information, but may not use it further. We keep lists of
people who have asked for further use of their information to be ‘blocked’ to make sure the
restriction is respected in future.

The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across
different services. For example, if you decide to switch to a new provider, this enables you to
move, copy or transfer your information easily between our IT systems and theirs safely and
securely, without affecting its usability.

The right to object to processing
You have the right to object to certain types of processing, including processing for direct
marketing (i.e. if you no longer want to be contacted with potential opportunities).

The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal
data with your national data protection regulator.

The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right
to withdraw your consent at any time (although if you do so, it does not mean that anything
we have done with your personal data with your consent up to that point is unlawful). This
includes your right to withdraw consent to us using your personal data for marketing
purposes.

We usually act on requests and provide information free of charge, but may charge a
reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we
can. Generally, this will be within one month from when we receive your request but, if the
request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone or email. If you prefer a particular contact means over
another please just let us know.

How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on
the processing of your personal data, contact us here:

Hanhaa Limited, Tintagel House, 92 Albert Embankment, London SE1 7TY, United Kingdom, contact email gdpr@hanhaa.com TERMS OF USE – May 2018

Stephen HartnettPrivacy Policy