Henchman Privacy Policy

Henchman Europe BV respects your privacy and is committed to protecting your personal data. This data protection policy informs you about how we handle your personal data, what your privacy rights are and how the law protects you.

 

1. Important information and who we are

Purpose of this privacy policy

This policy is intended to provide you with information about how Henchman BV collects and processes your personal data. It is important that you read this policy, together with any other fair processing policy or notice that we may provide on specific occasions where we collect or process personal data about you, so that you are fully aware of how and why we process your use data. This policy supplements the other notices and is not intended to replace them.

Responsible

Henchman BV is responsible for the processing of your personal data (collectively referred to in this privacy policy as " Henchman ", " we ", " us " or " our ").

We have appointed a data privacy manager who is responsible for questions related to this privacy policy. If you have any questions about this policy, as well as requests to exercise your legal rights, you can contact the data privacy manager using the details below.

Contact details

Our full details are:

Full name of the legal entity: Henchman Europe BV

Title: Data Privacy Manager

E-mail address: info@henchman.eu

Postal address: Henchman Europe BV,Concertgebouwplein 15H,1071LL Amsterdam

You have the right to make a complaint to the Dutch Data Protection Authority at any time, but we would like the opportunity to resolve your concerns before you turn to them, so please contact us in the first instance. Your duty to notify us of changes.

It is important that the personal information we hold about you is accurate and up to date. We request that you keep us informed of changes to your personal data during contact with us.

Henchman Europe BV and Henchman Ltd are joint data controllers.

The BV and the Ltd are joint controllers within the meaning of Article 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, (hereinafter: the "GDPR"). The BV and the Ltd are both complaint with the rules and obligations as laid down in the GDPR.

Third Party Links

Our website may contain links to third party websites, plug-ins and applications. Clicking on or activating these links may allow third parties to collect or share information about you. We have no control over these third party websites and are not responsible for their privacy practices. When you leave our website, we recommend that you read the privacy statement of each website you visit.

How we use cookies

As you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this technical data by using cookies. A cookie is a small file that asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets us know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by collecting and remembering information about your preferences.

We use traffic log cookies to track which pages are being used. This helps us analyze data about web page traffic and improve our website to better tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. We use Google Analytics, which is located outside the European Economic Area (EEA).

Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you other than the data you choose to share with us.

If you want to know more about how we use cookies, click here to read our cookie policy. You can block all non-essential cookies by clicking on the link here or by visiting https://henchman.eu/cookie-settings page. Essential cookies enable core functionality of the website. Without these cookies the website cannot function properly. They help make a website usable by enabling basic functionality.

 

2. The information we collect about you

Personal data, or personal information, is any information about an individual from which that individual can be identified. This does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different types of personal data about you, which we have grouped as follows:

• Identity data including first name, last name, title, date of birth and gender.
• Contact information, including billing address, delivery address, email address and telephone number(s).
• Financial information, including bank account and payment card information.
• Transaction Data includes details about payments to and from you and other details about products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your email address and password, purchases or orders you have made, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data, including your preferences in receiving marketing from us.

We do not collect special categories of personal data about you (this includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect information about criminal convictions and offences.

If you do not provide personal data

If we are required by law or a contract to collect your personal information and you do not provide this information when requested, we may not be able to perform the contract we have or are trying to enter into with you (we cannot for example, do not deliver products if you do not provide your contact or financial information).

 

3. How is your personal data collected?

We collect personal data from and about you when you provide identity, contact and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This also includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• request marketing to be sent to you; or
• give us feedback or contact us.

 

4. How we use your personal data

We will only use your personal data when the law allows us to. Typically, we will use your personal data in the following circumstances:

• When we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• When we need to comply with a legal or regulatory obligation.

The types of lawful basis we will rely on to protect your

Processing personal data can be summarized as follows:

"Performance of a contract" means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into such a contract.

"Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to provide you with the best service and the best and most secure experience. We ensure that we consider and balance all possible consequences for you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests outweigh the consequences for you (unless we have your consent or are required or permitted by law). You can learn more about how we balance our legitimate interests against the potential impact on you in relation to specific activities by contacting us.

"Comply with a legal or regulatory obligation" means processing your personal data where it is necessary to comply with a legal or regulatory obligation to which we are subject.

We generally do not rely on consent as a legal basis for processing your personal data, except in connection with sending direct marketing communications to you via email, where you have not purchased any products or services from us. You have the right to withdraw your consent to marketing at any time by contacting us.

 

5. Purposes for which we will use your personal data

The purpose for which we process your personal data is to enable us to perform our contract with you; for example by providing our products and services to you.

Please be aware that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you would like to know more about the specific legal basis we rely on to process your personal data.

Marketing: sign in and sign out

We may use your Identity, Contact, Technical, Usage and Profile Data to form a picture of what we think you want or need, or what may be of interest to you. This is how we estimate which products, services and offers may be relevant to you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us. When you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of providing you with our products or services.

For marketing by email, we will usually ask you to opt-in to receive marketing information from us, unless you have purchased products or services from us and you have not opted out of receiving that marketing. For this processing of personal data, we rely on our legitimate interest to send you marketing emails about similar products or services.

Change of target

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis on which we can do so.

Please note that we may process your personal data without your knowledge or consent, in accordance with the above rules, where required or permitted by law.

 

6. Disclosure of your personal data

We may need to share your personal data with the parties listed below for the purposes set out in paragraph 5 above:

• Third parties, when necessary in the provision of our products and services, including suppliers who provide services to support the operation of our business.
• Professional advisers acting as processors or joint controllers, including lawyers, bankers, accountants and insurers.
• Regulatory Agencies and Other Authorities.
• Third parties to whom we intend to sell, transfer or merge parts of our business or assets. We may also seek to acquire or merge with other companies. If there is a change in our business, the new owners may use your personal data in the same way as set out in this privacy statement.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

 

7. International transfers

Some of our external third parties may be based outside the EEA, so their processing of your personal data will entail a transfer of your data outside the EEA. When we transfer your personal data outside of the EEA, we ensure that it receives a similar level of protection, which means that we ensure that at least one of the following safeguards is applied:

• we only transfer your personal data to countries deemed by the European Commission to offer an adequate level of personal data protection; or
• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection for personal data transferred between Europe and the US.

Please contact us if you would like more information about the specific mechanism we use when transferring your personal data outside the EEA.

 

8. Data security

We have taken appropriate security measures to prevent your personal data from being accidentally lost, used in an unauthorized manner or accessed, changed or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they are bound by a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any necessary regulator of a breach where we are legally required to do so.

 

9. Data retention: how long will you use my personal data?

We will only retain your personal data for as long as necessary for the purposes for which we collected it, including to maintain our accreditation database, to satisfy any legal, accounting or reporting requirements and other legitimate business interests. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we purposes through other means and the applicable legal requirements.

In some circumstances you can ask us to erase your data: see Request erasure below for more information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes; in that case we can use this information indefinitely without further notice to you.

 

10. Your legal rights

Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing this data.
• Request correction of the personal data we hold about you. This allows you to have any incomplete or inaccurate information we hold about you corrected, although we may need to verify the accuracy of the new information you provide.
• Request erasure of your personal data. This gives you the opportunity to ask us to delete or remove personal data where there is no good reason why we should continue to process this data. you also have the right to ask us to erase or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we must erase personal data to comply with local laws. However, please be aware that we cannot always comply with your data erasure request due to specific legal reasons, which will be communicated to you, if applicable, at the time of your request.
• Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground, as you feel it affects is on your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request to restrict the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) if our use of the data is unlawful, but you do not want us to erase it; (c) if you want us to keep the data, even if we no longer need it because you need it for the establishment, exercise or defense of legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data to you or to a third party. We will provide you, or a third party chosen by you, with your personal data in a structured, commonly used, machine-readable format. Please be aware that this right normally only applies to automated information that you initially gave us permission to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing that took place before you withdrew your consent. If you withdraw your consent, we may no longer be able to provide you with certain products or services. We will let you know if this is the case when you withdraw your consent.

If you wish to exercise any of the rights mentioned above, please contact us. 

Usually no fee required

You do not have to pay a fee for access to your personal data (or for exercising any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request in these circumstances.

What we may need from you

We may need specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in connection with your request so that we can respond more quickly.

Deadline to respond

We try to respond to all legitimate requests within one month. Sometimes it can take longer than a month if your request is particularly complex or if you have submitted multiple requests. In that case we will notify you and provide updates.

 

11. Changes to this Privacy Policy

We will review this Privacy Policy as necessary and at least once a year, in July of each year, and we will post any updates on this web page.