HulaTech is a UK based technology company. We are committed to safeguarding the privacy of the personal information that is provided to us or collected by us during the course of our business as well as the personal information we receive from visitors to our HulaTech website and any associated websites under our control (together our “Websites”). HulaTech is the data controller of any personal information collected by or provided to us in the circumstances described below in section 2.
This Privacy notice explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information. In line with our aim to have a consistent approach to protecting personal data, this is a global policy that we follow in each of our offices. It is based on data protection principles that are set out in the UK and relevant European Union data protection laws. Where we have offices in jurisdictions with significantly different data protection laws it may be that the rights and obligations set out in this Privacy notice do not apply. If you have any questions about how this Privacy notice applies to you or want to make a complaint to us about how we handle your personal information, please contact the firm’s Privacy Partner or your contact at our international offices (details are set out in section 8 below).
We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this Privacy notice.
This Privacy notice applies in the following circumstances:
We collect personal information about prospective clients and their beneficial owners, controllers and/or directors as part of business development initiatives and our business acceptance process. The type of personal information we may collect includes name, address, nationality, business interests, track record and employment history. We obtain this information from you or your employer directly and from publicly available open sources either directly or through a third party.
We may also collect personal information about other individuals who may be, or working for, counterparties of our clients or our prospective clients or otherwise involved on matters we may be acting on.
The type of personal information that we may collect includes current and historical information including your name and contact details (such as your address, email address and telephone numbers) and identifiers such as your organization, employment history, professional and business expertise and positions held.
We will also collect personal information you choose to provide to us directly, or, for example, through your use of our Apps or other online services, and information about your other dealings with us and our clients, including contact we have with you in person, by telephone, letter, email or online. We obtain personal information from your IP address and the operating systems and web browsers that you use to access our Websites. It enables us to identify which organizations have visited our Websites and we use this information to compile statistical data on the use of those sites to help us to improve the user experience.
We collect personal information directly from you, from our clients or other parties to a matter and their authorized representatives. We may also collect personal information from third parties such as your employer, other organizations that you have dealings with, regulators, government agencies, credit reporting agencies, publicly available records (including electronic data sources to carry out checks to enable us to comply with applicable law), information or service providers (some of whom may process your personal information on our behalf), third party platforms that we engage to host our training and events, recruitment agencies and other law firms or professional advisers. Your personal information may be collected in the firm’s contact database when you register to receive legal updates or we otherwise receive your contact details.
We use a third party service provider to manage the firm’s contact database and deliver emails to inform you about our services, technical developments and updates and invite you to HulaTech events (including those we may jointly host with other organizations).
You can control the information you receive through our direct marketing function by using the “Managing your preferences” option at the bottom of the emails. If you no longer wish to receive marketing emails relating to our services by email or post, you can unsubscribe at any time by using the “Unsubscribe” option on the email footer or by contacting email@example.com .
If you apply for a role or work experience opportunity, open day or insight event at the company we will collect personal information directly from you, or from recruitment agencies, recruitment websites and apps or other third parties involved in our recruitment and screening process.
We will only use your personal information if and to the extent that applicable law allows. We will therefore only process your personal information if:
We may use your personal information to:
We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. Personal information processed in connection with our business acceptance processes and/or providing technical services will be retained in accordance with the company’s Retention and destruction policy unless we agree otherwise with you, in writing. If you wish to know more about the firm’s Retention and destruction policy or any of the company’s different retention periods, please contact firstname.lastname@example.org .
We may share your personal information with our offices, branches, in-house companies and associated partnerships due to, for example, our shared IT systems.. We use third parties who provide services on our behalf and will share your information with them, for example a technology supplier may have access to your personal information when providing software support, or a company we use for a communications campaign or to host our events may process the personal information of our contacts or attendees for us.
During the course of working with you or the organization you work for we may use certain third party technology services to assist with our work on the matter. Where these services are integral to our work for you, we deploy them as a matter of course. We also use various ancillary services, for example, software that is capable of effecting bulk data transfers or facilitating e-signatures and virtual completions. In addition we make use of third party technology services that are more integral to the work we do, i.e. running the company’s business. The use of these integral and ancillary services may require your personal information to be held in the cloud on infrastructure managed by the relevant service provider.
To enable us to provide the services set out in this Privacy notice, it is likely that we will transfer your personal information to countries outside the jurisdiction where you provided it or where we collected it, for example information that we collect through cookies or through your completion of our online forms. Therefore, if you are based outside the UK (for example, in the European Economic Area (EEA)), your data may be transferred to the UK and other third countries as set out below.
Your personal information may be accessed by our offices, branches, in-house companies and associated partnerships and third parties in countries whose laws provide varying levels of protection for personal information.
Some of your personal information may be stored in a cloud located within or outside of the UK or the EEA and managed by a third party service provider. In adopting this approach, the confidentiality of your personal information is of key importance to us and we conduct careful due diligence on the security of any third party technology systems we use.
Where we transfer your personal information outside the UK or the EEA we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Personal information shared between HulaTech offices is subject to a data sharing agreement which sets out the standards each office must follow.
We may share your personal information with third parties where:
If you would like more detailed information about the legal bases upon which we rely to process your information and the third parties we use, please contact email@example.com .
We use up to date data storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss.
All our partners, staff and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
However, the transmission of information via the internet is not completely secure. Although we take appropriate and proportionate steps to manage the risks posed, we cannot guarantee the security of your information transmitted to our online services.
Our Websites contain links to other sites which are controlled by third parties. We also use social media sites, such as LinkedIn, Facebook and Twitter and third party platforms to host events, training and seminars. You should review these other sites’ privacy policies. We do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information.
You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold. These rights are to:
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once the company has received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you would like to exercise any of these rights, please contact the Privacy Partner in writing by emailing firstname.lastname@example.org or by letter to:
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Privacy notice. However, we may refuse to provide access and may charge a fee for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
The company has appointed the Privacy Partner to oversee compliance with this Privacy notice. If you have any questions about this policy or how we handle your personal information, please contact them as set out above.
We hope that the firm’s Privacy Partner can resolve any query or concern you raise about our use of your personal information. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at ico.org.uk/concerns or telephone 0303 123 1113.
If you are based outside the UK, you may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction.