Updated: 1st May 2018
Privacy and cookies policy
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data in line with relevant legislation including GDPR.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://handlr.co.uk/members-area or email [email protected]
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, any interactions and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our Google analytics and other analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, our services and how we market our services.
2.3 We may process your account data (“account data“). The account data may include your name, address, email address and information about your business or organisation. The source of the account data is you or an organisation which has provided your details as the contact for that business or organisation. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, our services and our own marketing interests.
2.4 We may process your information included in your personal portal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment details and any other information you choose to provide to us such as social network links. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, our services and our own marketing interests.
2.5 We may process information that you post for publication on our website or through our other communications services such as email, a support desk or external review or social media websites (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, our services and our own marketing interests.
2.6 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is presumed consent at the point the enquiry is made unless otherwise notified in writing via any option to opt out, via email or letter.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and information about our other products and/or services which we believe may interest you. The legal basis for this processing is presumed consent unless you choose to opt out of non-essential communications. Essential communications may include such communications as (but not limited to) system generated password reset emails and payment reminders.
2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, our services and our own marketing interests and communications with users.
2.9 We may process third party statistical or usage data (“statistical data“). This data may include how you and/or your customers and/or any other third party who uses any service we provide, interact with the product and/or service and IP addresses, geographical location, browser type and version, operating system, referral source, length of visit, page views, any interactions and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of this data is Google analytics, other analytics providers including our communications systems including our web chat systems, telephone systems and sms providers. This data may be processed for the purposes of measuring our marketing and product and/or service quality. The legal basis for this processing is our legitimate interests, namely product and/or service quality, our performance, our staff members individual performance, obtaining feedback on the service quality, end user experience and other metrics related to performance and quality we deem necessary.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process information relating to your business, organisation, employment, job title, business or organisation financial information where such processing is necessary for compliance with a legal obligation to which we are subject.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Automated decision-making
3.1 We will use your personal data for the purposes of automated decision-making in relation to displaying relevant information to you which is based upon your personal data.
3.2 This automated decision-making will involve using your personal data to filter you in or out of information which may be presented to you by our systems.
3.3 The significance and possible consequences of this automated decision-making are some content may be unavailable to you on some occasions due to information contained within your personal data.
- Providing your personal data to others
4.1 We may disclose your personal data or data relating to your business or organisation in which you are affiliated to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal data or data relating to your business or organisation in which you are affiliated to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.3 We may disclose usage data, account data, profile data, publication data, enquiry data, notification data, correspondence data and statistical data to our suppliers or subcontractors insofar as reasonably necessary for maintaining our products and/or services, development of our products and/or services and supplying our products and/or services.
4.5 Financial transactions relating to our website and services are handled by our payment services providers, which include the following (and may include their parent or subsidiary companies both UK based and internationally based) Barclays Bank Plc, GoCardless Ltd, Directli Ltd, Stripe Inc, Xero Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at Barclays Bank Plc: https://www.barclays.co.uk/important-information/privacy-policy/ ; GoCardless Ltd: https://gocardless.com/legal/privacy/ ; Directli Ltd: https://www.directli.co.uk/terms-and-conditions ; Striple Inc: https://stripe.com/gb/privacy ; Xero Limited: https://www.xero.com/uk/about/terms/privacy/ .
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices and facilities in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission alongside our corporate rules on data handling which in areas exceed the legal requirements.
5.3 The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 Some of our services providers used to provide our products and/or services are situated in countries outside of the United Kingdom. Some personal data may be passed outside of United Kingdom servers to EEA countries, United States of America and parts of Asia. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission and our own corporate safeguards.
5.5 You acknowledge that any personal data that you submit for publication through our website or via our services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain and delete your personal data as follows:
(a) account data will be retained for 5 years following closure of your account, at the end of which period it will be deleted from our systems.
(b) profile data will be retained for 5 years following closure of your account, at the end of which period it will be deleted from our systems.
(c) notification data category will be retained for 5 years following closure of your account and opting out of marketing communications, at the end of which period it will be deleted from our systems.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of all or part of the usage data will be determined based on the relevance and current need to retain such data.
(b) the period of retention of enquiry data will be determined based on your account remaining open with us and if you still opt in to receive marketing communications.
(c) the period of retention of correspondence data will be determined based on your account remaining open with us and if you still opt in to receive marketing communications.
(d) the period of retention of publication data will be determined based on the relevance and current need to retain such data.
(e) the period of retention of statistical data will be determined based on the relevance and current need to retain such data.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by post, email or through a notification system on the members portal homepage.
- Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (if applicable); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
10.1 Our website and services are targeted at persons over the age of 16.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data, subject to below.
10.3 If the information about any person under the age of 16 is obtained and entered into our database as a result of them being an end user of one of our products and/or services, we may reject any request to delete all or part of the information obtained. An end user could be a person contacting a company for whom we answer calls and/or live web chats for, where their details are taken via our systems to provide to our own customer. In such cases, we will only accept direct requests via a parent, guardian or law court to remove such data and then we may be limited to what data can be removed from the database due to other legal requirements to retain some types of data.
- Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- Acting as a data processor
12.1 In respect of data obtained on behalf of our clients own customers who are the end user of our products and/or services, we do not act as a data controller; instead, we act as a data processor.
12.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
- About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
• Track origin and website entry
• Track chats in progress
• Prevent prompting users who visited recently
• Track chats in progress transcript position
• Message type by visitor persistence across pages
• Check logic handling
• Keep track of visitor visits and chat history
• Detect new chat sessions
• Visitor email addresses (where provided and will be encrypted)
• Tracking banned visitors
• Detect chat box position and minimised status
- Cookies used by our service providers
- Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
- Our details
17.1 This website is owned and operated by Handlr Ltd.
17.2 We are registered in England under registration number 10603748, and our registered office is at Queens Court, 9-17 Eastern Road, Romford, RM1 3NH.
17.3 Our principal place of business is at Queens Court, 9-17 Eastern Road, Romford, RM1 3NH.
17.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
(e) by live web chat, during operational hours as published on our website.
- Call Answering Services
18.1 We collect information about you when you register with us or subscribe to any of our services.
18.2 The information we collect will be directly related to your business and may include personal and sensitive details, such as, but not limited to, the following:
• Name, email, job title and contact numbers
• Business address and payment details
• Business process information
• Third party personal data. Depending on the Handlr products used/purchased we may collect or allow you to provide us with third party personal data.
- Call Recording
19.1 We may record telephone conversations but only for specific purposes, which will meet one or more of the following conditions so as to be deemed lawful under GDPR:
1. The parties involved in the call have given consent to be recorded
2. The recording is necessary in order to fulfil a contract
3. The recording is necessary for compliance with a legal obligation
4. The recording is necessary to protect the vital interests of a data subject or another person
5. The recording is in the public interest, or necessary for the exercise of official authority
6. The recording is in the legitimate interests of the recorder, unless those interests are overidden by the interests of the participants in the call.
19.2 Call recordings are stored on a secure server in compliance with applicable regulations.
Call recordings are recorded on your behalf as a customer of Handlr, and it is your responsibility to ensure that you have discharged your duties under applicable regulations to those people contacting us via a divert from you or your business or a number owned or rented (from us or a third party) by you or your business.
19.3 Call recordings will not be shared with any third party company or organisation except where there is a lawful authority to reasonably request or demand such a recording. e.g. via a court of law.
- Live Web Chat Services
20.1 We collect information about you when you register with us or subscribe to any of our services.
20.2 The information we collect will be directly related to your business and may include personal and sensitive details, such as, but not limited to, the following:
• Name, email, job title and contact numbers
• Business address and payment details
• Business process information
• Geo-location data – Handlr may have access to geo-location data as indicated by your IP address. We collect and process IP addresses of all devices where some of our services are made available on (i.e. Handlr live chat services). Collecting and processing your geo-location data refers to mobile devices as well as computers.
• Third party personal data. Depending on the Handlr products used/purchased we may collect or allow you to provide us with third party personal data. The information that we may collect is name, email address, other contact information and any other information we may reasonably require to provide you with the services you request.