Privacy Policy

Your privacy is important to us

It is our policy here at Hartwell Strategies Ltd to respect your privacy regarding any information we may collect while operating our website. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of personal information.

We have outlined our privacy policy below.

We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual.

We do not use your information for marketing purposes unless you actively sign up to our newsletter where you can choose to opt out at any time.

We will collect and use personal information solely for fulfilling those purposes specified by us and for other ancillary purposes, unless we obtain the consent of the individual concerned or as required by law.

Personal data we collect is relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, we make all efforts to ensure the data is accurate, complete, and up-to-date.

We will protect personal information by using reasonable security safeguards against loss or theft, as well as unauthorised access, disclosure, copying, use or modification.

We will make readily available to customers information about our policies and practices relating to the management of personal information.

We will only retain personal information for as long as necessary for the fulfilment of those purposes unless required by law.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. Hartwell Strategies Ltd may make changes to this policy from time to time at our sole discretion.

Hartwell Strategies Ltd is committed to making sure your data is kept safe and in accordance with GDPR.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by selecting ‘unsubscribe’ from our correspondence.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

To register you as a new customer or contact.
To process and deliver your order.
To deliver marketing communications.
To manage our relationship with you.
To notify you about changes to our terms or privacy notes.
Asking you to leave a review or take a survey.
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To develop our products/services and grow our business.

Marketing

We endeavour to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers and other information (such as in respect of events we may run or news updates we may provide) may be relevant for you.

You may receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted-in to receive that marketing and have not subsequently opted out of receiving that marketing.

Third-party marketing

We will also get your express opt-in consent before we share your personal data with any company outside the Company (or our group) for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Further information can be found at https://ico.org.uk/for-the-public/online/cookies.

Who we share your data with

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

External Third Party Websites may include:

Service providers acting as processors who provide IT and system administration services, e.g. Google Analytics as well as social media scheduling tools/apps/sites in order to fulfil our contractual obligations with you.
Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants/auditors, marketing advisers, human resources advisers and insurers who provide consultancy, banking, legal, marketing, human resources, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

International Transfers

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Visitor comments may be checked through an automated spam detection service.

Although most changes are likely to be minor, Hartwell Strategies Ltd may change its Privacy Policy from time to time, and in Hartwell Strategies Ltd sole discretion. Hartwell Strategies Ltd encourages visitors to frequently check this page for any changes to its Privacy Policy. If you have a https://www.hartwellstrategies.co.uk account, you might also receive an alert informing you of these changes. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.