Legal

PLEASE READ THIS PRIVACY POLICY AS IT APPLIES TO ANY PERSONAL DATA YOU PROVIDE US OR WE COLLECT ABOUT YOU, FOR EXAMPLE IF YOU ACCESS THE WEBSITE AT www.hylo-london.com OR ANY OTHER WEBSITE OWNED, OPERATED OR PROVIDED BY FINSBURY TOWER ESTATES LIMITED INCORPORATED IN ENGLAND, COMPANY 119473, REGISTERED OFFICE 44 Esplanade St Helier Jersey, JE4 9WG (‘WEBSITE’ AND ‘US’, ‘WE’ RESPECTIVELY) OR ENQUIRE ABOUT ANY OF OUR PRODUCTS (‘PRODUCTS’) OR SERVICES (‘SERVICES’). WE DO NOT MARKET TO OR ENTER INTO CONTRACTS WITH CHILDREN NOR WE DO COLLECT PERSONAL DATA FROM ANY PERSON UNDER 18 YEARS OF AGE. PLEASE DO NOT ACCESS OR USE THE WEBSITE OR SERVICES IF YOU ARE UNDER 18 YEARS OF AGE.

 

THIS POLICY

THIS POLICY SETS OUT WHAT PERSONAL DATA WE MIGHT COLLECT, HOW WE PROCESS AND PROTECT THAT DATA, THE LAWFUL GROUNDS FOR THAT PROCESSING, AND YOUR RELATED RIGHTS. ESSENTIALLY ‘PERSONAL DATA’ MEANS ANY INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON, NAMELY ONE WHO CAN BE IDENTIFIED, DIRECTLY OR INDIRECTLY FROM THAT INFORMATION ALONE OR IN CONJUNCTION WITH OTHER INFORMATION.

 

IN MOST CASES, THE LAWFUL GROUND WILL BE THAT THE PROCESSING: (I) IS NECESSARY FOR OUR LEGITIMATE INTERESTS IN CARRYING OUT OUR BUSINESS, PROVIDED THOSE INTERESTS ARE NOT OUTWEIGHED BY YOUR RIGHTS AND INTERESTS (‘LEGITIMATE INTERESTS’), (II) IS NECESSARY TO PERFORM A CONTRACT WITH YOU (‘CONTRACT’), OR (III) IS NECESSARY TO COMPLY WITH OUR LEGAL OBLIGATIONS (‘LEGAL OBLIGATION’). WHERE PROCESSING IS BASED ON YOUR CONSENT (‘CONSENT’), WE WILL IDENTIFY THE PROCESSING PURPOSES AND PROVIDE YOU WITH RELEVANT INFORMATION TO MAKE THE PROCESSING FAIR AND TRANSPARENT.

 

AS DATA PROTECTION LAW AND PRACTICE ARE CONSTANTLY DEVELOPING, WE’LL NEED TO UPDATE THIS POLICY FROM TIME TO TIME, WHICH WE’LL DO BY POSTING A NEW POLICY ON THE WEBSITE THAT TAKES EFFECT FROM THE DATE STATED. IT IS YOUR RESPONSIBILITY TO RETURN TO THE WEBSITE FROM TIME TO TIME AND CHECK FOR CHANGES.

 

HOW DO WE OBTAIN PERSONAL DATA?

WE COLLECT OR ARE PROVIDED PERSONAL DATA IN THE NORMAL COURSE OF BUSINESS, FOR EXAMPLE:

  • YOU MAY PROVIDE US WITH YOUR DETAILS DURING DISCUSSIONS ABOUT OUR PRODUCTS,
  • WHEN YOU VISIT THE WEBSITE, WE MAY COLLECT INFORMATION ABOUT YOUR VISIT SUCH AS YOUR IP ADDRESS AND THE PAGES YOU VISITED,
  • YOU MAY PROVIDE US WITH YOUR DETAILS WHEN YOU ASK ABOUT OUR SERVICES (THROUGH THE WEBSITE, BY EMAIL OR OTHERWISE) AND WE MAY OBTAIN LEGALLY-COMPLIANT LISTS OF POTENTIAL CUSTOMERS FOR OUR PRODUCTS AND SERVICES FOR OUR MARKETING PURPOSES.

WHEN YOU PROVIDE US WITH PERSONAL DATA ABOUT YOURSELF OR ANOTHER PERSON, YOU ARE CONFIRMING TO US THAT YOU ARE AUTHORISED TO PROVIDE US WITH THAT INFORMATION AND THAT ANY PERSONAL DATA YOU GIVE US IS ACCURATE AND UP-TO-DATE.

 

SENSITIVE PERSONAL DATA

GIVEN THE NATURE OF OUR BUSINESS, WE DO NOT ASK FOR ‘SENSITIVE’ OR ‘SPECIAL CATEGORIES OF PERSONAL DATA’, SUCH AS INFORMATION ABOUT YOUR HEALTH, POLITICAL OPINIONS, RACIAL ORIGINS OR SEXUAL LIFE AND WE WOULD ASK YOU NOT TO SEND ANY TO US.

 

HOW DO WE USE PERSONAL DATA?

WE USE PERSONAL DATA IN THE NORMAL COURSE OF OUR BUSINESS, FOR EXAMPLE:

  • TO RESPOND TO ENQUIRIES ABOUT OUR PRODUCTS AND SERVICES, TO PROVIDE THE WEBSITES AND SERVICES, TO PROVIDE ADVICE AND SUPPORT. LAWFUL BASIS: LEGITIMATE INTERESTS OR CONTRACT.
  • TO ANALYSE AND IMPROVE THE WEBSITE, THE SERVICES, FOR EXAMPLE FOR TECHNICAL OR SECURITY PURPOSES AND TO IMPROVE THE CUSTOMER EXPERIENCE. LAWFUL BASIS: LEGITIMATE INTERESTS, HOWEVER WHERE FOR EXAMPLE APPLICABLE LAW REQUIRES YOUR CONSENT TO USE CERTAIN COOKIES, WE WILL ASK FOR YOUR CONSENT HAVING PROVIDED YOU WITH RELEVANT INFORMATION.
  • TO MARKET OUR PRODUCTS AND SERVICES – IF WE DO SO, WE WILL PROVIDE YOU WITH AN EASY AND FREE WAY TO OPT-OUT OF RECEIVING SUCH COMMUNICATIONS IN THE FUTURE. LAWFUL BASIS: LEGITIMATE INTERESTS (OR CONSENT AS ABOVE).
  • IN CERTAIN CIRCUMSTANCES, TO SHARE IT WITH A LIMITED NUMBER OF THIRD PARTIES AS DESCRIBED IN THIS POLICY, FOR EXAMPLE FOR OPERATIONAL REQUIREMENTS AND BUSINESS CONTINUITY PURPOSES. LAWFUL BASIS: MOST PROCESSING WILL BE BASED ON LEGITIMATE INTERESTS, SOME PROCESSING IS BASED ON CONTRACT AND, WHERE NECESSARY (AS ABOVE) SOME PROCESSING MAY BE BASED ON YOUR PRIOR CONSENT.

 

SHARING DATA & INTERNATIONAL TRANSFERS

WE WILL NOT GIVE, SELL OR RENT YOUR PERSONAL DATA TO THIRD PARTIES SO THEY CAN MARKET THEIR PRODUCTS OR SERVICES TO YOU. NOR DO WE ACCEPT ADVERTISING FROM THIRD PARTIES ON THE WEBSITE. WE MAY SHARE PERSONAL DATA IN THE FOLLOWING LIMITED CIRCUMSTANCES.

  • FOR PROVISION OF THE SERVICES, AND FOR OUR OWN DISASTER RECOVERY AND BUSINESS CONTINUITY PURPOSES, WE MAY STORE OR TRANSMIT PERSONAL DATA TO OR THROUGH THIRD PARTY PROVIDERS, SUCH AS WITH OUR CONTRACTORS AND ADVISORS TO HELP US OPERATE, SECURE AND ANALYSE OUR BUSINESS. LAWFUL BASIS: LEGITIMATE INTERESTS OR CONTRACT.
  • WE MAY BE OBLIGED TO DISCLOSE YOUR PERSONAL DATA TO COMPLY WITH A LAW, ORDER OR REQUEST OF A COURT, GOVERNMENT AUTHORITY, OTHER COMPETENT LEGAL OR REGULATORY AUTHORITY OR ANY APPLICABLE CODE OF PRACTICE OR GUIDELINE. LAWFUL BASIS: LEGAL OBLIGATION.
  • IF WE ENTER NEGOTIATIONS WITH A THIRD PARTY FOR THE SALE OR PURCHASE OF ALL OR PART OF OUR BUSINESS, WE WILL ONLY DISCLOSE PERSONAL DATA TO THAT THIRD PARTY TO THE EXTENT IT RELATES TO THAT BUSINESS AND ONLY UNDER CONDITIONS OF CONFIDENTIALITY REQUIRING THE THIRD PARTY TO BE BOUND BY THE PRIVACY POLICY THAT APPLIES TO THAT DATA. LAWFUL BASIS: LEGITIMATE INTERESTS.

IN EACH CASE, WE SHARE THE MINIMUM PERSONAL DATA NECESSARY AND WE HAVE WRITTEN CONTRACTS IN PLACE INCORPORATING RELEVANT WORDING TO SAFEGUARD THAT PERSONAL DATA AND COMPLY WITH APPLICABLE LAWS, AND WE WILL ONLY SHARE SUCH DATA AS IS NECESSARY FOR THE PURPOSE IN QUESTION. WHERE POSSIBLE, WE KEEP PERSONAL DATA WITHIN THE EUROPEAN ECONOMIC AREA (‘EEA’). HOWEVER, IN ORDER TO CARRY OUT THE ABOVE PURPOSES, WE MAY USE THIRD PARTIES AND THEIR FACILITIES OUTSIDE THE EEA. IN ALL SUCH CASES WE WILL ENSURE THAT APPROPRIATE SECURITY MEASURES ARE IN PLACE TO PROTECT YOUR PERSONAL DATA AND A VALID LEGAL BASIS FOR THE TRANSFER APPLIES.