Privacy Notice

INTRODUCTION

We at Henderton are committed to respecting your privacy and protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our web site (regardless of where you visit it from), and in the interactions we may have after your visit, and tell you about your privacy rights and how the law protects you.

This privacy policy has been written in accordance with the data protection legislation applicable in the European Union, namely the General Data Protection Regulation (GDPR).

1. Important information and who we are

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Henderton collects and processes your personal data through your use of this web site, including any data you may provide through this web site when you sign up to our newsletter.

This web site is not intended for children and we do not knowingly collect data relating to children.

CONTROLLER

Henderton Limited is a limited company registered in England and Wales. We are affiliated with certain other entities and so when we mention “Henderton”, “we”, “us” or “our” in this privacy notice, we are referring to Henderton Limited or the relevant affiliate responsible for processing your data. We will let you know which entity will be the controller for your data when you engage us to provide services to you. Henderton Limited is the controller and responsible for this web site.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at: DPO@henderton.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was updated in September 2020. Any changes to this privacy notice will be posted on this web site and will be effective on posting.

It is important that the personal data we hold about you are accurate and current. Please keep us informed if your personal data change during your relationship with us.

THIRD-PARTY LINKS

This web site may include links to third-party web sites, 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 web sites and are not responsible for their privacy statements. When you leave our web site, we encourage you to read the privacy notice of every web site you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data such as your name, your employer, your title or position and your relationship to a person or information collected by us as part of our business acceptance processes.

- Contact Data such as your billing address, email address and telephone numbers.

- Financial Data such as bank account details.

- Technical Data such as information from your visit to our web site, or in relation to materials and communications we send to you electronically, including your IP address.

- Marketing and Communications Data such as your preferences in receiving marketing from us, your communication preferences and information you provide to us for the purposes of attending meetings and events, including access and dietary requirements.

- Personal Information provided to us by or on behalf of our clients, partners and employees or generated by us in the course of providing services and employment, including applications for employment submitted to us, which may include special categories of data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but are not considered personal data in law as these data do not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific web site feature. However, if we combine or connect Aggregated Data with your personal data so that they can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide those data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may not be able to provide the requested service to you, but we will notify you if this is the case at the time.

3. How are your personal data collected

We use different methods to collect data from and about you including:

- If you are a visitor to our web site, we may collect certain technical information about your visit, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the web site. We collect such data for administrative and statistical purposes and to help us operate and improve our web site

- If you make an enquiry by email or telephone, we will collect your name and contact information, which will be used to respond to your enquiry. We may also keep records of such communications and / or add your contact details to our business database, if we believe that we may have a good reason to contact you in the future.

- If you register to receive our newsletter or updates from us, we will collect, store and use your name and contact information for this purpose. You can remove yourself from our business database at any point by opting out or contacting us.

- If you register (or are invited by a member) to attend an event organised by us, we will use your name, contact details and the name of the organisation you work in connection with organising the event. We will store such information in our database and our staff or relevant partners will be able to access it.

- If you are applying to work with Henderton, for example as a contractor, consultant or vendor, we will collect, store and use the information you provide to us in your application and any information you provide to us during your interview to assess your suitability for the role, to communicate with you about the engagement process, to make a decision as to whether to enter into a contract with you and to keep records of our hiring process. We may also carry out background and reference checks, if applicable.

- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including Identity and Contact Data from publicly availably sources such as Companies House.

4. How we use your personal data

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 third party 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.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the principal 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / activity

- To register you as a new client.

- To process and deliver our services to you including managing payments, fees and charges, or collecting and recover money owed to us.

- To manage our relationship with you which will include notifying you about changes to our terms or privacy policy.

- To administer and protect our business and this web site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

- To deliver relevant web site content to you and measure or understand the effectiveness of such content we serve to you.

- To use data analytics to improve our web site, products/services, marketing, client relationships and experiences.

- To analyse your application in respect of a position at Henderton.

MARKETING

We may use your contact details to send you our newsletter, or news about Henderton’s services or events. We may use certain of your personal 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 services may be relevant for you.

You will receive marketing communications from us if you have requested information from us or if you have engaged us to provide services to you and, in each case, you have not opted out of receiving that marketing. You can ask us 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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us during the course of a transaction or us providing services to you.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when web sites set or access cookies. If you disable or refuse cookies, please note that some parts of this web site may become inaccessible or not function properly.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected them, unless we reasonably consider that we need to use them 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.

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.

5. Disclosures of your personal data

We may need to transfer personal data to third parties, including third parties based outside the EEA, such as other advisors, accountants and third parties involved in your matters.

We require all third parties, including our affiliates, to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Whenever we transfer your personal data out of the EEA, 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 which have been deemed to provide an adequate level of protection for personal data by the European Commission.

- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected them for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing them.

- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. NO FEE USUALLY REQUIRED

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

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are not disclosed to any person who has no right to receive them. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

- Service providers based in the EEA or the United States who provide IT and system administrative services.

- Professional advisers including lawyers, bankers, auditors and insurers based in the EEA or the United States who provide consultancy, banking, legal, insurance and accounting services.

- HM Revenue & Customs, regulators and other authorities based in the United Kingdom or the United States who require reporting of processing activities in certain circumstances.

11. Changes to the privacy policy

We may change this privacy policy from time to time. Please refer to this web site for the most recent copy of this privacy policy.

London
+44 7377 620971 london@henderton.com
110B Bellegrove Road
London DA16 3QD
United Kingdom
Paris
+33 970 408 708 paris@henderton.com
25 rue de Ponthieu
75008 Paris
France
Stockholm
+46 8 559 230 07 stockholm@henderton.com
Riddargatan 17D 3tr
11457 Stockholm
Sweden
Vienna
+43 660 508 3337 vienna@henderton.com
Siebensterngasse 16
Vienna 1070
Austria