April 2022

Happy Finish Ltd understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy of all of ouremployees, clients and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law.

Information About Us

Happy Finish Ltd

Limited company registered in England under company number 05144546.

Registered address: 26-28 Underwood Street, London, N1 7JQ.

Main trading address:26-28 Underwood Street, London, N1 7JQ.

VAT number: 253587971.

Data Protection Officer: Sharon McHallum.

Email address: [email protected].
Postal address: 26-28 Underwood Street, London, N1 7JQ.

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact ususing the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that wehold. Please contact ususing the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to ususing your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we arerelying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to usdirectly, we areusing it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. Wedo not use your personal data in this way.

For more information about ouruse of your personal data or exercising your rights as outlined above, please contact ususing the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data wehold about you changes, please keep usinformed as long as have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about ouruse of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact usfirst, using the details in Part 11.

What Personal Data Do You Collect and How?

Wemay collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Wedo not collect any special ‘category’ or ‘sensitive’ personal dataand/orpersonal data relating to childrenand/or data relating to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Contact information including name, email, company, phone number.	Contact form submitted via email.
Business information including name, position, email, phone number.	Sales outreach.
Payment information including company card details.	Contact form submitted via finance department.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how wemay use your personal data, and ourlawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Supplying our products AND/OR services to you.	Name, email, phone number.	Administering our business.
Managing payments for our products AND/OR services.	Name, address, email, payment card details.	Administering our business.
Communicating with you.	Name, email, phone number.	Sales Acquisition Process, Administering our business.
Supplying you with information by emailthat you have opted-in-to (you may opt-out at any time).	Name, email.	Marketing, administering our business.

With your permission and/or where permitted by law, wemay also use your personal data for marketing purposes, which may include contacting you by emailwith information, news on ourservices. You will not be sent any unlawful marketing or spam. Wewill always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.Wewill always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.]

Wewill only use your personal data for the purpose(s) for which it was originally collected unless wereasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If wedo use your personal data in this way and you wish usto explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, wewill inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, wemay process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including name, date of birth, gender.	6 years.
Contact information including address, email, phone number.	6 years.
Business information including business name, job, profession.	6 years.
Payment information including card details, bank account details.	7 years.

How and Where Do You Store or Transfer My Personal Data?

Wewill only store your personal datain the UK. This means that it will be fully protected under the Data Protection Legislation.

Wewill only store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

Wemay store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.

Wewill use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by uswhen transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, wetake a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we arelegally required to do so.

Wewill not share any of your personal data with any third parties for any purposes, subject to the following exception[s].

If wesell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of ourbusiness may continue to use your personal data in the same way(s) that wehave used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we areinvolved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell useverything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within fourteen days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time.

How Do I Contact You?

To contact usabout anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Sharon McHallum):

Email address: [email protected]
Postal Address: 26-28 Underwood Street, London, N1 7JQ.

Changes to this Privacy Notice

Wemay change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website. This Privacy Notice was last updated on 10^th April 2022.

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