Privacy Notice

HighNetwork Limited

General
1. HighNetwork Ltd (“we”, “us” or “HNW”) take the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal data which may be obtained via our app, website or other means including online forms, email, or phone.
2. This notice applies to personal data provided by our clients (which may include the organisation, firm or entity for whom you work) and their staff, personal data collected directly by us through publicly available information, personal data provided by you (such as via our app), as well as any third party suppliers whose data we process. In this notice “you” refers to any individual whose personal data we hold or process.
3. In general, our services relate to the provision of virtual business development coaching services to users from law, accountancy and other such professional service firms, to encourage and promote networking and sales activities. We do not process personal data on a large scale, but we will hold and process personal data in order to supply our services and this policy explains how we do so.
4. This notice is governed by the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation.
Legal basis on which we process personal data
1. The personal data we hold about you, as detailed in section 3 below, will be processed either because:
  1. you have consented to the processing of it for one or more specific purposes;
  2. the processing is necessary in order for us to comply with our obligations under a contract with you, specifically for the provision of our services; or
  3. the processing is necessary in pursuit of our “legitimate interests”. A legitimate interest in this context means a valid interest we have, or a third party has, in processing your personal data which is not overridden by your interests in data privacy and security; or
Personal data we collect and how we process this data
1. Below we have set out the categories of data we collect and how we process the data:
  1. we will hold contact information for our users who have registered with us or whose details have been passed to us on their behalf by their employer, organisation or firm for whom they work such as name, email address, mobile telephone number (for authentication), (“Contact Information”). We will use such information to provide our services and communicate with you;
  2. we will hold information about your professional status or role such as your profession, country of employment, grade and professional registration details, job title, your employer or institution, number of years qualified, and /or area of expertise (“Professional Information”) which we will use to provide our services and understand who our users are;
  3. we will hold information relating to your responses to the surveys in the app which we may use for our statistical (e.g. behavioural analysis) or other business purposes such as for analytical purposes or improving our services;
  4. we will hold information relating to user generated content which you input into the app or post to one of our services such as user comments which may contain personal data (“User Generated Information”) and which we may use to display and share comments and other information for our users. For the avoidance of doubt, we may aggregate some of the content that you input into the Appapp together with content from other users however this will be for our statistical (e.g. behavioural analysis) or other business purposes only and tomay also share such content with our clients (i.e. the organisation for whom you work) in accordance with 5 below. To the extent that such aggregated data is shared with other users, it will not contain any personal data;
  5. we will hold Cookie Information. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. We use Cookie Information to analyse and improve our services or in order to customise the website according to your personal interests;
  6. we will hold a record of any correspondence or communication between you and us (“Communication Information”) which we will use to provide our services and communicate with you;
  7. we will hold information about our suppliers such as contact information (“Supplier Information”) which we will use to procure goods and services from those suppliers;
  8. we may hold certain information about you in order to provide information about our services including names, email addresses, phone numbers, addresses, and other information (“Marketing Information”) which we may use to market and promote our services.
2. If you are a user of our services, we process all of the categories of information above (except for Marketing Information and Supplier Information) on the basis of your consent, the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients and users., the performance of our contract with our clients or on the basis of your consent.
3. We may from to time process Marketing Information on the basis of our legitimate interests in communicating with interested individuals about our services or on the basis that you have consented to receive the information.
4. We process Supplier Information on the basis of our legitimate interests in obtaining goods and services from suppliers.
5. Generally we will collect information directly from you,publicly available information however we willmay also usually collect certain information from the organisation, entity or firm for whom you work such as your contact information, job title or role, and your work history, mobile number in order to provide you with the services. In this instance or if we obtain your personal data from any other third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
6. You do not have to supply any personal data to us however in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data (please see below).
Data retention
1. Our current data retention policy is to delete or destroy (to the extent we are able to) personal data in accordance with the following retention periods:
  Information relating to our users
  We will hold information for registered and non-registered users for 7 years from the date on which we collect the data, or if later, from the date on which you cease to be a user.
  Information relating to our suppliers
  We will hold information for suppliers for 7 years from the date on which our agreement with that supplier has terminated.
  Marketing and business development records (where we have not provided services to you and you have not provided information to us)
  Up to 3 years from the date on which you last interacted with us.
2. For any category of personal data not specifically defined in this section or notice, and unless otherwise specified by applicable law or regulations, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
3. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
4. We review the personal data (and the categories of personal data) we hold on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.
5. If you wish to request that data we hold about you is amended or deleted, please see section 8 below, which explains your privacy rights.
Sharing your information
1. We do not disclose any information you provide to any third parties other than as follows:
  1. from time to time we will transfer personal data to our sub-processors which will include Amazon Web Services, The Core (hosted by AWS), Cloudflare and other service and technology providers;
  2. if you are a user of our services, from time to time we may share certain data with our clients (i.e. the organisation, firm or entity for whom you work) for statistical and analytical purposes. For instance, at a user level, the relevant organisation for whom you work would be able to view who had access to the app and how often the app was being used. On a broader level, we may aggregate certain data with other users’ data and create analytics reports for such organisations however individuals would not be identifiable through such reports.
  3. we may be required to disclose certain data to regulators or other lawful authorities;
  4. we may disclose information to our group companies;
  5. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  6. in order to enforce any terms and conditions or agreements for our services that may apply;
  7. if we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
  8. we may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  9. to protect our rights, property and safety, or the rights, property and safety of our users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
2. Other than as set out above, we shall not disclose any of your personal data unless you give us permission to do so. If we do supply your personal data to a third party, we will take reasonable steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.
Security
1. We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and to protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
  1. protecting our servers with software firewalls;
  2. locating our data processing storage facilities in secure locations (e.g. within Europe or the US);
  3. encrypting all data stored on our server(s) with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  4. securely disposing of or deleting your data;
  5. regularly backing up and encrypting all data we hold;
  6. regular penetration testing to ensure system robustness.
  7. conducting regular and comprehensive security audits.
2. We will take reasonable steps to ensure that our employees and other staff are aware of their privacy and data security obligations.
Cookies and IP address
1. A cookie is a piece of data stored locally on your computer or mobile device and contains information about your activities on the internet. The information in a cookie does not contain any personally identifiable information you submit to our website or app.
2. On our website and app (as applicable), we may use cookies to track users’ progress, allowing us to make improvements based on usage data. A cookie helps you get the best out of the website/app and helps us to provide you with a more customised service.
3. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browser settings you should go to your advanced preferences. Once you close your browser, our access to the cookie terminates.
4. We are required to obtain your consent to use cookies. We will obtain this consent (as necessary) with a toolbar which appears when you first visit our website or app.
5. If you choose not to accept the cookies, this will not affect your access to the majority of information available on our website or app. However, certain online services may not be available.
6. An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our website, and to administer and improve the website.
Your privacy rights
1. With respect to your personal data, you have the right to:
  1. request that your personal data will not be processed;
  2. ask for a copy of any personal data that we have about you;
  3. request a correction of any errors in or update of the personal data that we have about you;
  4. request that your personal data will not be used to contact you for direct marketing purposes (however please note that as a business, we do not typically engage in direct marketing activities).
  5. request that your personal data will not be used for profiling purposes;
  6. request that your personal data will not be used to contact you at all;
  7. request that your personal data be transferred or exported to another organisation, or deleted from our records; and/or
  8. at any time, withdraw any permission you have given us to process your personal data.
2. All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below.
3. We will endeavour to comply with such requests as soon as reasonably possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
Data breaches
1. If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager and/or the Information Commissioner’s Office (ICO) as is deemed necessary.
2. If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as reasonably possible.
Transferring your information outside the EEA
1. We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (“EEA”) but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
  1. from time to time some of our data processors or server providers may be based outside of the EEA, such as the US. If that is the case then we will ensure that we have an agreement with such processors or service providers to provide adequate safeguards and a copy of such agreements will be available on request;
  2. if you access the services whilst outside of the EEA, your information may be provided outside of the EEA in order to provide you with our services;
  3. we may communicate with parties outside of the EEA, in providing our services. Those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you.
2. If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
Notification of changes to the contents of this notice
1. We will post details of any changes to our policy on our website to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties. Please ensure you check the website regularly for any updates.
Contact us
1. If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by contacting Fiona Voong using the details below:
  Email: admin@highnetwork.co.uk
Complaints
1. If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.

Last updated: 26/08/2019

Privacy Notice

HighNetwork Limited

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