HN Systems (“We” or “Us”) are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
HN Systems is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters contact our Data Representative on 0330 321 16 14, or via email on firstname.lastname@example.org
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To maintain our own accounts and records required by HMRC.
To confirm the contract for sale of goods to the purchaser.
As proof of purchase for warranty returns, product updates and product recalls.
To respond to information you voluntarily provide by corresponding with us by phone, e-mail or otherwise. This includes filling in forms on our sites(advenrweb.co.uk or hnsystems.net (our web site) including reporting issues with our website, participating in social media discussion boards or other social media functions, via our e-commerce platforms, Social media Business pages or entering competitions and surveys hosted by HN Systems.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process or have restricted access to the following categories of your data:
Personal data that we store and process which you provide to us, may include your Name, current Address, e-mail address, Phone Number(s) and Product(s) purchased.
In addition, Personal data of customers applying for finance via one of our General Data Protection Regulation (GDPR) compliant Lenders. We have restricted access to (and do not store) Personal data held by the Lender during the application process. Please see the relevant Lender’s Privacy notice, which sets out how they store and use your personal data. A copy of which will be made available to you during the application process.
We obtain your personal data from yourself and no other third party sources.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
☐ Consent of the data subject;
To receive respond to correspondence by phone, e-mail or otherwise, including website form data.
☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
As proof of purchase for warranty returns, product updates and product recalls.
☐ Processing necessary for compliance with a legal obligation
To maintain our own accounts and records required by HMRC and to confirm the contract for sale of goods
to the purchaser.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will not be shared for marketing purposes. Your personal data will only be shared with our GDPR compliant Lenders during the finance application process.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 7 years in order to maintain our own accounts and records required by HMRC, to confirm the contract for sale of goods to the purchaser and proof of purchase for warranty returns, product updates and product recalls.
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter in to a contract of sale with you.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the only lawful basis for processing the personal data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not transfer personal data outside the EEA.
11. Automated Decision Making
We do not use any form of automated decision making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Representative on 0330 321 16 14
While we will make every attempt to rectify any situation, where you feel your data has not been handled appropriately you have the right to contact the regulator. In this case the regulator is the Information commissioner’s office (ICO). You can contact them on 0303 123 113 or by visiting https://www.ico.org.uk/concerns