Hughes & Co is the trading name of Roxanne Hughes, and the associated web domain www.roxannehughes.com.
The registered address of the business is 5 Grove Road East, Christchurch, BH23 2DQ, UK.
Hughes & Co adheres to UK legislation and law with regard to data handling and GDPR. In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’.
You can get hold of us in any of the following ways:
(a) by phoning us on +44 7713 891 945
(b) by e-mailing us at [email protected]
(c) by writing to us at our registered address
We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information.
We do not have a dedicated Data Protection Officer, but if you have any questions about this privacy notice or issues arising from it then you should contact Roxanne Hughes, Director of Hughes & Co, in the first instance.
1. Key Definitions
Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored, and how it is used.
Data Processor: any person undertaking work on behalf of Hughes & Co may be required to process data. For the purposes of this policy, Data Processor may refer to any persons appointed by Hughes & Co to conduct such tasks.
Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which an individual can be identified.
2. Details of personal information that we collect and hold about you
2.1 Set out below are the general categories and in each case the types of personal information which we collect, use and hold about you:
Identity Information: This is information relating to your identity such as your name (including any previous names and any titles which you use), gender, and date of birth
Contact information: This is information relating to your contact details such as e-mail address, addresses, telephone numbers
Account Information: This is information relating your account(s) with us, such as usernames and passwords.
Payment Information: This is information relating to the methods by which you provide payment to us, such as bank account details, VAT number, and records of financial transactions that have taken place between us. This information will be only held for the duration of our contracture to you.
Website, device and technical information: This relates to your use of our website and the data we collect about your use via Google Analytics. This includes your IP address, web browser, operating system, time zone and location from where you accessed our website (should those details be available to us). Through this data means, we are unable to identify you as an individual and the data is collected purely for the purpose of advancing website functionality and enhancing user experience.
The types of personal data we collect may differ from person to person, depending on who you are and the relationship between us.
3. ‘Special information’, identified by UK law as information concerning race, ethnicity, or religion, is not collected or stored.
3.1 We do not collect information from you relating to criminal convictions or offences.
4. Details of how and why we use personal information
4.1 We only use your information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below, but in most cases, we will use your personal information for the following legal reasons:
(a) Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you or your company;
(b) Legitimate Interests Reason: this is where the use of your personal information is necessary for our legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests.
(c) Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
(d) Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.
4.2 So that we can provide you with services, we will need your personal and company information. If you do not provide us with the required personal and compnay information, we may be prevented from supplying our services to you.
4.3 It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying our services to you.
4.4 Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information, in which case, we will confirm that reason to you.
4.5 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together wither other personal information and you are not identifiable from that combined data, we are able to use this.
4.6 Under data protection laws we can only use your personal information for the purposes we have told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) which we told you about, then we will contact you to explain this, and what legal reason is in place to allow us to do this.
5. Details of how we collect personal information and special information
5.1 We usually collect Identity Information, Contact Information, Payment Information, directly from you when you complete the form on our website, contact us directly via phone or email, or engage Hughes & Co for services, This includes the personal information which you provide to us when you subscribe to our mailing list or join our network.
6. Details about who personal Information may be shared with
6.1 Your personal information may be shared with employees or contractors of Hughes & Co in order to deliver services that you have engaged us for.
6.2 Your details will only be shared with third parties through necessity. Examples of necessity are
(i) Suppliers: such as IT support services, payment providers, and administration providers.
(ii) Government bodies and regulatory bodies: such as HMRC and fraud prevention agencies
(iii) Our advisors: such as lawyers, accountants, auditors, and insurance companies
(iv) [Credit Reference Agencies
6.3 We do not sell or trade any of the personal information which you have provided to us.
6.4 If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA, and that the transfer is made in compliance with data protection laws.
Details about how long we will hold your personal information
6.5 We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims.
7. Automated decision making
7.1 ‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences). Hughes & Co do not use your information for this purpose.
8. YOUR RIGHTS UNDER DATA PROTECTION LAW
8.1 Under data protection laws you have certain rights in relation to your personal information, as follows:
(a) Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
(b) Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
(c) Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
(d) Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
(e) Right to data portability: this right allows you to request us to transfer your personal information to someone else.
(f) Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason and there is something about your particular situation which means that you want to object to us processing your personal information.
8.2 In addition to the rights set out above, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent.
8.3 If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice.
9. Marketing
9.1 You may receive marketing communications from us about our services if you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.
9.2 However, we will give you the opportunity to manage how or if we market to you. In any e-mail which we send to you, we provide a link to either unsubscribe or opt-out, or to change your marketing preferences.
9.3 If you do request that we stop marketing to you, this will not prevent us from sending communications to you which are not to do with marketing (for example in relation to services that we may be continuing to provide to you.
9.4 We do not pass your personal information on to any third parties for marketing purposes.
10. Complaints
If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.
11. Third Party Websites
Our website may contain links to third party websites. If you click and follow those links then these will take you to the third party website. Those third party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.