Privacy Policy

This is an important notice regarding your privacy and the way in which the Habro group of companies (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.

This policy applies to our applicants, business contacts (i.e. clients and prospective clients), customers, suppliers and third parties generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.

This policy 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.

For the purpose of applicable privacy legislation, the data controller is Habro Properties Limited of 823 Salisbury House, 29 Finsbury Circus, London EC2M 5QQ. Our company registration number is 05705750.

Questions regarding this policy should be directed to our Data Protection Compliance Manager, Mark Avery. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and this policy, and can be contacted by email at info@habro.co.uk. Any questions about the operation of this policy or any concerns that the policy has not been complied with should be referred in the first instance to the Data Protection Compliance Manager.

 

1.     What information do we hold about you?

We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):

Applicants 

  • Personal contact details such as your name, title, address, telephone number, e-mail address and your IP address when you visit our website.
  • Recruitment information (including personal information such as copies of your right to work documents, your CV or cover letter which is sent to us as part of the application process).
  • Information provided to us by recruitment agencies in relation to your application for employment with us.
  • Information collected during the course of your application including psychometric and personal profiling data (i.e. tests administered by our third party test supplier).

 

Business partners 

  • Contact details such as your name, title, business telephone number, business e-mail address and your IP address when you visit our website.

 

Corporate clients 

  • Personal contact details such as your name, address, telephone number, e-mail address and your IP address when you visit our website. 
  • Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company. 
  • Personal information provided to us via our website or social media accounts, for example, by contacting us on LinkedIn.
  • Personal information provided to us during telephone calls which you have made to us and which are recorded. 
  • Personal information provided to us by the third-party service providers we work with, for example, analytics providers.

 

Suppliers 

  • Personal details such as your name, address, bank account information, telephone number and your IP address where you visit our website.

 

Generally 

  • If you visit our offices and login to our guest Wi-Fi network, information may be collected about your usage.
  • Any personal information you provide to us during your interactions with us.
  • Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookie Policy, which can be found at [https://www.habro.co.uk/policies/ ].
  • Information provided to us by third party service providers we work with, for example, payment service or analytics providers.

 

2.     How will we use your personal information and what is the legal ground we rely on for doing so?

We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:

  • Where you have provided us with your consent for us to do so;
  • Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
  • Where we need to comply with a legal obligation to which we are subject;
  • Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Applicants

  • To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
  • To carry out right to work checks – to comply with a legal obligation.

Business partners

  • To manage our relationship with you, including notifying you about changes to our terms or privacy policy or asking you to leave a review – performance of a contract with you; and necessary for our legitimate interests (to keep our records updated and to study how clients use our services).
  • Your contact details to process and respond to an enquiry – necessary for our and your legitimate interests to resolve queries and enquiries regarding our services.
  • To facilitate the services (such as online payment) being provided by you – performance of a contract with you.

Corporate clients

  • Your contact details to register you as a new client – performance of a contract with you.
  • Your personal information provided to us during correspondence – performance of a contract with you.
  • Dealing with your service-related enquiry – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
  • Your payment information – to perform the contract with you or to take steps to enter into a contract with you.
  • Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.

Suppliers

  • Your personal details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).

Generally

  • Health and safety purposes – to comply with a legal obligation.
  • To track your Wi-Fi usage – in pursuit of our legitimate interests (in ensuring our network is being used for acceptable purposes).
  • To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
  • To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
  • To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
  • To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
  • Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
  • Your personal information provided to us over the telephone – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
  • To provide information regarding our services – where you have given us your consent to do so.

3.     What happens if there is a change of purpose?

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.     Which type of third parties might we share your personal information with?

We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.

We may share your personal data with the parties set out below for the purposes set out in the table above:

  • Technical support providers, for example, assisting with our website.
  • Providers assisting us with receipt of payments via our website.
  • Recruitment agencies assisting us with filling our vacancies.
  • Professional advisers such as lawyers, accountants, insurance companies and business analysts.
  • Providers which help us collate and organise information effectively and securely.
  • Providers which help us generate and collate surveys and reviews of our services.
  • Third party software hosting companies which provide us with software solutions.
  • Providers which host our servers in their data centres.

5.     International transfers

We share your personal data with other group companies within the Habro Group. This may involve transferring your data outside the UK to our parent company in Denmark, whose privacy policy can be found here [https://www.habro.dk/om-habro/databeskyttelse/].

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
  • Using another authorised exception safeguard or if an exception applies.

 

6.     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.

7.     Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Applicants

  • Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
  • Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 12 months.

Business partners

  • If you have provided us with your personal information for the purpose of making a complaint or a customer service call, we will keep this information for 6 years.
  • Personal data provided by investors in managed projects will be deleted 6 years after completion of the project, or at the point when the project has not been in our administration for 5 years.

Generally

  • Our server logs which log IP addresses are deleted after 6 years.

8.     Where we store your personal data

Electronic versions of your personal information are stored on our servers in the United Kingdom and our parent company in Denmark.

Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.

In the unlikely event that your personal data is transferred outside of the EEA, we will take steps to ensure that your personal data is adequately protected.

9.     Rights of access, correction, erasure and restriction

Your rights in connection with your personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request the erasure of your personal information. This enables you to ask us to delete or remove personal information when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Compliance Manager in writing using the contact details set out at the beginning of this privacy policy.

10.  No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

11.  What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access any personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.

12.  Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Compliance Manager in writing using the contact details set out at the beginning of this policy.

Once we have received notification that you have withdrawn your consent, we will no longer process the relevant personal information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.

13.  What happens if you fail to provide personal information?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our premises).

14.  Right to complain

You have the right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).