Privacy Policy v01.00
(Published: 31st December 2020 and last updated 31st December 2020)
GENERAL
New Horizon Innovation Ltd are committed to protecting and respecting your privacy. This policy, together with our Website Terms of Use and any other documents referred to on www.newhorizoninnovation.com (“site”), sets out the basis on which New Horizon Innovation Ltd, will process any (“personal data”) which you provide to us, or we collect from you, in the course of using our site and our services.
Personal data is defined as meaning any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
This policy contains information on:
· Who we are
· The personal data we collect
· How and why we collect, store, use and share personal data
· Your data protection rights, and
· How to contact us and supervisory authorities in the event you have a complaint.
This policy may change from time to time, therefore you should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website, or use our services.
If you have any questions or comments about this policy, or would like this policy in another format, please contact: enquiries@newhorizoninnovation.com
Please note that if you click on, or follow, any links from our site to external websites, our privacy policy will no longer apply. Please check the privacy policies of any such external site before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.
WHO WE ARE
New Horizon Innovation Ltd (“we” or “us”) collect, use and are responsible for certain personal data about you. When we do so we are regulated under the General Data Protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of those laws.
We specialise in innovation strategy and management consultancy services, innovation personal development services, and innovation facilitation and support services (“Services”).
THE INFORMATION WE USE
When you use our site and our services, there are a number of ways in which you provide information and other data to us. By using the site and our services, you consent to us processing and collecting this data, on the terms and for the reasons which are explained below.
INFORMATION YOU GIVE US:
This is information about you that you give to us by filling in forms on our site, purchasing our services, or by corresponding with us by phone, e-mail or otherwise.
It includes personal data required for you to be able to use our site, register to use our services, search for a product or service, register to subscribe to our newsletter, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition or promotion or survey, and when you report a problem with our site.
The information you give us may include your name, address, e-mail address, phone number and payment information.
INFORMATION WE COLLECT ABOUT YOU:
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, and operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
This website is hosted by Squarespace, who have put in place the necessary arrangements to comply with GDPR. Specifically Squarespace as web host and its partners collects and uses the following information when you use the site.
WEBSITE VISITORS
Squarespace collects personal data when you visit this website, including:
Information about your browser, network and device
Web pages you visited prior to coming to this website
Your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. To ensure that content from our site is presented in the most effective manner for you and for your computer. Squarespace analyses the data in a de-personalized form.
WEBSITE COOKIES
This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app.
Functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
Analytics and performance cookies are used on this site, as described below, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.
Please also see our Website Cookie Notice.
For the latest information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
WEBSITE ANALYTICS
If consent has been given, this website collects personal data to power our site analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Your IP address
This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
WEBSITE MARKETING E-MAILS
We may send you marketing emails, which you can unsubscribe from by clicking the link at the bottom of the email. We share your contact information with Squarespace, our email marketing provider, so they can send these emails on our behalf.
WEBSITE FONTS
This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:
Information about your browser, network, or device
Your IP address
INFORMATION WE RECEIVE FROM OTHER SOURCES:
This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers, personal and administrative assistants, and credit reference agencies). We only use this data in order to deliver our Services.
HOW YOUR INFORMATION IS USED
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
· Your consent. You are able to remove your consent at any time. You can do this by contacting: enquiries@newhorizoninnovation.com
· We have a contractual obligation.
· We have a legal obligation.
· We have a vital interest.
· We need it to perform a public task.
· We have a legitimate interest.
In some circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with a legal or contractual obligation.
The below paragraphs set out why we process your personal data, as well as the data processing conditions we rely on when processing this data.
To enter into contracts
Where you enter into a contract with us for our Services, we need to process your Personal Data to provide these Services to you. Our use of your Personal Data in this way includes sharing your Personal Data with the third party agents, consultants, suppliers and contractors we need to in order to provide the Services, as well as for the purposes of assessing fraud, credit and/or security risks.
We need to process your Personal Data in this way to enter into and perform the contract for the Services you have asked us to provide. If you do not wish to provide us with your Personal Data in this way, you will be unable to use our Services.
We do not store the credit or debit card details of any of our customers.
To provide customer services
We may also process Personal Data in order to provide various supporting customer services to you (such as where you contact us with a question in connection with our other services which we might be able to provide to you). The data processing condition we rely on when we process your Personal Data in these circumstances is our legitimate interest to provide effective customer support services. If you do not provide us with the Personal Data we request from you for customer services purposes, we may not be able to fully answer your queries.
To employ services of others
We also process Personal Data where we contract for the provision of third party goods and services as part of the effective delivery of services to our clients and for the management of our facility.
We will also process your Personal Data for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The data processing condition we use in these circumstances is our legitimate interest to provide you with the best customer experience we can, and to ensure that our site is kept secure.
To make our website better
We will also process Personal Data in order to provide a more effective user experience (such as by displaying our website in a way which is tailored for your device and browsing habits). This processing means that your experience of our site will be more tailored to you, and that the Services you see on our site may differ from someone accessing the same site with different browsing habits. We also use various cookies to help us improve our site, and share your Personal Data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site.
For marketing purposes
We retain Personal Data of those with whom we conduct business and may use that data for providing information regarding our capabilities and the services we may provide to our business associates. We may send you our newsletters from time to time, provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
If you do not want us to use your information for marketing purposes, contact us directly by emailing enquiries@newhorizoninnovation.com
In response to requests by public authorities.
In addition, we will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Sale of the Company
We may disclose your personal information to any of our group companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985) and also to third parties in the following circumstances: – to any prospective seller or buyer of all (or part of) our business or assets; if we are required to do so by law, any applicable regulation or to protect the rights, property, or safety of ourselves or others. This may include disclosing to other companies and organizations in connection with fraud protection and credit risk reduction.
WHERE DO WE STORE YOUR INFORMATION?
All Information we use is processed by our staff in the UK.
No third parties have access to your personal data unless the law allows them to do so.
Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.
However, and unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site at transmission stage; any transmission is at your own risk.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will retain your data for as long as you are a client of, or supplier to, New Horizon Innovation Ltd, and for ten years thereafter, to ensure that we are able to contact you should we or you have any questions, feedback or issues in connection with any of the Services we or you have received.
We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years.
The Information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
All Personal information will be removed from our systems and any physical data will be disposed of securely.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
· We may deny access to personal data where the burden or expense of providing access is disproportionate to the risks of the originating data subject’s privacy or where right of persons other than the originating data subject would be violated.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
· the processing is no longer necessary in relation to the purposes for which your Personal Data were collected or otherwise processed;
· our processing of your Personal Data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your Personal Data;
· you object to the processing in as set out in this policy and we have no overriding legitimate interest for our processing;
· the Personal Data have been unlawfully processed; and
· the erasure is required for compliance with a law to which we are subject.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
· the accuracy of the Personal Data is being contested by you;
· the processing by us of your Personal Data is unlawful, but you do not want the relevant Personal Data erased;
· we no longer need to process your Personal Data for the agreed purposes, but you want to preserve your Personal Data for the establishment, exercise or defence of legal claims; or
· we are processing your Personal Data on the basis of our legitimate interest to improve our site, provide customer services, or on the sale of our business (as set out above) and you:
o object to our processing as set out above; and
o want processing of the relevant Personal Data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
· based on our legitimate interests to improve our site, provide customer services, or on the sale of our business (as set out above). If you ask us to stop processing your personal data for these reasons, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
· for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulations.
Please contact us at enquiries@newhorizoninnovation.com if you wish to make a request.
HOW TO COMPLAIN
If you have any concerns about our use of your personal data, you can make a complaint to us at: enquiries@newhorizoninnovation.com. We commit to resolve complaints about privacy and its collection and/or use of personal data expeditiously
If your complaint remains unresolved you or we can refer the complaint to the Information Commissioner’s Office (“ICO”), the supervisory authority for data protection issues in England and Wales.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
