Privacy Policy
February 2021
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
Huddle Communications Ltd is a company registered in England and Wales (registration number 12973935). Our services relate to consultation and planning permission and corporate and public affairs. For further information about us please visit www.huddlecommunications.com
In providing our services, we collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union and in the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Personal information means any information relating to an identified or identifiable individual.
1. Introduction
The personal information we collect, and the use we make of it, varies depending on our relationship with you. For that reason, this privacy policy distinguishes between our:
Customers.
Suppliers.
Associates, contacts, enquirers and newsletter subscribers.
Job applicants.
Website users.
Please be sure to read the sections of the privacy policy which apply to you.
You can find information about how we process personal data relating to a specific consultation on the website created for that consultation.
2. Personal information we collect about you
We may collect and use the following personal information about you:
Customers
Your name, job title, employer organisation and contact information (including email address, telephone numbers and postal address).
Information to enable us to check and verify your identity.
Your billing, transaction and payment information.
Information to enable us to undertake credit or other financial checks on you.
Your contact and customer history.
Suppliers
Your name, job title, employer organisation and contact information (including email address, telephone numbers and postal address).
Information to enable us to check and verify your identity.
Your billing, transaction and payment information.
Information to enable us to undertake credit or other financial checks on you.
Your supplier history.
Associates, contacts, enquirers and newsletter subscribers
Your name, job title, employer organisation and contact information (including email address, telephone numbers and postal address).
Your contact preferences.
Other personal information provided by you.
Job Applicants
Your name, date of birth, gender and contact information (including email address, telephone numbers and postal address).
Your qualifications, employment history and other information contained in your curriculum vitae.
References.
Other personal information provided by you.
Website users
We use cookies and analytics to determine:
How you accessed the site including your device’s IP address, operator system, browser type, route of access, the operating system, date, location (city) and time of access,
How you use our site including which pages you looked at and how much time you spent on each page.
You are not obliged to provide us with this personal information but if you don't it may delay or prevent us from providing our services to you, ordering goods or services from you, sending you our newsletter, providing you with information about us, responding to your enquiry or considering your job application. It may also affect your experience of our website.
3. How your personal information is collected
We collect most of this personal information directly from you - in person, by telephone, text or email and/or via our website. However, we may also collect information:
From publicly accessible sources such as Companies House or HM Land Registry
From credit reference agencies
From customer due diligence providers
From employment agencies
Via cookies on our website
4. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
Where you have given consent, or
For our legitimate interests or those of a third party.
A legitimate interest is when there is a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
5. Who we share your personal information with
Generally, we do not share your personal information with anyone else. The exceptions are:
Zoho Campaigns which distributes our newsletter by email and receives names and email addresses for that purpose.
Other third parties we use to help deliver our services to you, for example, payment service providers and holders of political or officer positions within London's governance.
Third parties we use to help us run our business, for example, web monitoring companies such as Google Analytics, our IT service providers, credit reference agencies, our insurers and brokers, our bank and other professional advisers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
6. Where your personal information is held
Your personal information is securely stored on our servers located at our offices in London, with data backed up to a remote location in the UK.
7. Transferring your personal information out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA).
These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:
the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law.
When we transfer your name and email address to Zoho Campaigns, we do so subject to standard data protection contract clauses approved by the European Commission. These are available upon request.
8. How long your personal information will be kept
We will not retain your personal information for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal information and generally we apply the following retention periods.
If you are a customer or supplier, we will hold your personal information for seven years after the end of our contractual relationship with you unless we have a legitimate business interest in retaining such information, such as an ongoing relationship or a clear relevance with the work of Huddle Communications and its clients.
If you are an associate or contact, we will keep your information for as long as we believe we have a legitimate business interest in retaining such information, such as an ongoing relationship or a clear relevance with the work of Huddle Communications and its clients.
If you are an enquirer or newsletter subscriber, your information will be retained for as long as is necessary to respond to enquiries or for as long as you wish to continue receiving information from us.
If you are a website user, we will retain your information for six months from your last visit to our website.
If you are a job applicant, we will keep your personal information for six months from the date of rejection for a job or, if you are accepted for a job, your personal information will be kept in accordance with our Privacy Policy for Staff.
If any contact tells us that you object to receiving marketing information from us, we will delete your contact information from such marketing databases.
We may keep your personal information longer to respond to any questions, complaints or claims made by you or on your behalf or if required to do so by law.
9. Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal information.
Rectification
The right to require us to correct any mistakes in your personal information.
Erasure
The right to require us to delete your personal information in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal information in certain circumstances, for example, if you contest the accuracy of the data.
Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
To object
The right to object at any time to your personal information being processed for direct marketing (including profiling); and in certain other situations to our continued processing of your personal information, for example, processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email, call or write to us (details below in the ‘How to contact us’ section). Please ensure that you:
let us have enough information to identify you;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
10. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
11. Changes to this privacy policy
We may change this privacy policy from time to time so please check it periodically.
12. How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Address: First Floor, Telecom House, 125-135 Preston Road, Brighton, East Sussex, United Kingdom, BN1 6AF
Telephone: 0800 433 2622
Email: raj@londoncommunications.com