Privacy Policy

1. Introduction

We are HCP Packaging UK Ltd (registered at 1 High Street, Guildford, Surrey, GU2 4HP United Kingdom). We are committed to:

• Processing your Personal Data in accordance with this Privacy Policy, as amended and updated from time to time;

• Processing your Personal Data and subscriber data in accordance with the Data Protection Act 2018 and The General Data Protection Regulation 2016/679, both as amended and updated from time to time; and

• Processing your Personal Data and subscriber data in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended and updated from time to time.

2. Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how HCP Packaging UK Ltd collects and processes your Personal Data including any data you may provide through our website or when you sign up to our newsletter.

Our website is not intended for children and we do not knowingly collect data relating to children under the age of 13 years old.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

HCP Packaging UK Ltd is made up of different legal entities, details of which can be found in the link below. This Privacy Policy is issued on behalf of the HCP Packaging UK Ltd so when we mention “HCP Packaging”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company HCP Packaging UK Ltd who is responsible for processing your data. HCP Packaging UK Ltd is the Data Controller and responsible for our website.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

CONTACT DETAILS
Full name of legal entity: HCP Packaging UK Ltd
Name: Jackie Mantle
Email address: jmantle@hcpackaging.com
Postal address: Tayfield House, 38 Poole Road, Westbourne, Bournemouth, Dorset, BH4 9DW

Company structure

3. How we obtain your personal data

We may obtain your Personal Data in the following ways:

A) HCP Packaging website:
Information that you provide us by filling in forms on our website at www.hcpackaging.com. This includes information provided at the time of registering an enquiry, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our website or our orders.

If you contact us, via the website or email, we may keep a record of that correspondence for our internal review processes.

B) Exhibitions:
If you give HCP Packaging UK Ltd representatives your business card, the information on this card will be captured and stored on HCP Packaging UK Ltd’s database. You will receive communication offering you the opportunity to Opt-in and receive HCP Packaging UK Ltd marketing and product information. You can Opt-out at any time.

C) Orders:
If you have done business with HCP Packaging UK Ltd before 25th May 2018 and you have not selected to Opt-in to receive marketing materials from us, where you continue to do business with us, your information will still be stored on a secure server.

You will not receive marketing communication unless you have responded to our ‘Opt-in’ email or instructed us to do so in writing. You can request for your information to be removed from our server at any time as per Clause 8 below.

New business contacts will be sent an ‘Opt-in’ email to specify which areas of our marketing you give us permission to receive. All e-marketing provides the opportunity to Opt-out at any time.

4. The data we collect about you

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name, employment title, employer and country.

• Contact Data includes company email address and company telephone numbers.

• Technical Data includes internet protocol (IP) address, 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.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us.

• Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details 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 any information about criminal convictions and offences.

We may receive Personal Data about you from various third parties and public sources, including but not limited to Google, Companies House and the Electoral Register.

5. What do we use your data for?

Personal information submitted to us via the HCP website or to an HCP office will be used for the purposes specified in this Privacy Policy or in relevant parts of the website.

We may use your personal information to:
• Enable your use of the services available on our website.
• Send you email notifications which you have specifically requested.

• Send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications).

• Deal with enquiries and complaints made by or about you relating to our website or our products.

6. Cookies

Our website uses Cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse our website, you are agreeing to our use of Cookies.

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. 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 gathering and remembering information about your preferences.

We use traffic log Cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, 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.

You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but you can modify your browser setting to decline Cookies if you prefer. This may prevent you from taking full advantage of the website however.

We use functionality Cookies. The sole purpose of this Cookie is to store your website session and to remember anything for the next time you come back to our website.

Cookies used on our Website:

Cookie, Universal Analytics (latest version) & What we use them for:

_ga: This is used by Analytics to calculate visitors, session, campaign data, etc. Expiration time is set to two (2) years and it resets each time when a visitor hits a page. No personal information or data is stored. Used to distinguish users. This Cookie enables us to estimate our audience size and usage pattern. See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

_gat:
Described by Google as “Used to throttle request rate”. Expires in ten (10) minutes. This Cookie enables us to limit the number of times information is recorded. See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

_gid: This is used to distinguish users but has a 24hours expiration time. See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

SSID, SID, APSID, HSID, NID:
Various unique identifiers, which stores your options such as preferred zoom level. Google set a number of Cookies on any page that includes a Google Map. While we have no control over the Cookies set by Google, they include a mixture of pieces of information to measure the number and behaviour of Google Maps users. Most of these Cookies expire 10 years after your last visit to a page containing a Google Map.

UTMA, UTMB, UTMT, UTMV, UTMZ: Various unique identifiers, which stores your options such as preferred zoom level. Google set a number of Cookies on any page that includes a Google Calendar. While we have no control over the Cookies set by Google, they include a mixture of pieces of information to measure the number and behaviour of Google Calendar users, as well as information about which calendar you are viewing, and which tab you are currently on. All these Cookies are immediately deleted or expire within 4 months.

How to manage cookies:

Our Cookies do not store financial information, or information which is capable of directly identifying you (such as your name or address). Cookies simply allow our website to retrieve this information in order to personalise and improve your experience of our website.

However, if you wish to restrict, block or delete Cookies provided by our site – or any other website – you can use your browser to do this. Each browser is different so check the ‘Help’ menu of your particular browser to learn how to change your Cookie preferences, or use the following weblinks:

Microsoft Internet Explorer
Help: http://support.microsoft.com/?ln=en-gb

How to manage Cookies in IE 11:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox
Help: http://support.mozilla.org/en-US/home?as=u
Cookies: http://support.mozilla.org/en-US/kb/Cookies?s=manage+cookies&r=0&e=es&as=s

Google Chrome
Help: http://support.google.com/chrome/?hl=en-GB
Manage Cookies: http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647

Our analytics partner also provides the ability for users to opt-out using the following links:

Google Analytics:
https://tools.google.com/dlpage/gaoptout

Further information on Cookies is available online at: www.aboutcookies.org

Please bear in mind that if you do this, certain personalised features of this website and others cannot be provided to you.

Third party Cookies:

To help improve your experience of our site we use content from other sites to help users and improve usability. We also use social media sites such as Facebook and LinkedIn to allow businesses to communicate with their clients along with analytics to help improve user experience. We do not control these social media websites and we suggest you read their cookie policy to see how to manage them.

Third-party Cookies & What their Cookies are used for:

Google: We use Google Maps to show our location. Googles privacy policy: http://www.google.co.uk/intl/en/policies/privacy/

Social Tools:
We take advantage of social networks and like to share our content with friends across these networks, such as Facebook and LinkedIn, you may receive Cookies from these websites. We are not in control of these third-party Cookies, if you would like to learn more about them – visit their websites:

Facebook: https://www.facebook.com/privacy/explanation
Linked In: https://www.linkedin.com/legal/cookie-policy

7. Legal

We may use your Personal Data for the purposes of enforcing any orders from you, and for the purposes of dealing with fraud and complying with any legal obligations applicable to us.

• Where your data is stored:
We securely store your Personal Data primarily at the HCP Packaging UK office for marketing purposes. The Personal Data is also stored on our servers that are within HCP Packaging offices world-wide.

• Security Measures:
We are firmly committed to data security and we aim to follow good industry practice in relation to the prevention of unauthorised access to your data stored in our systems, including using password-protected servers. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

• Keeping your data secure:
Sending information over the internet is generally not completely secure, and we cannot guarantee the security of your Personal Data while it is in transit.

• Any data you send is at your own risk:
We have procedures and security features in place to keep your data secure once we receive it.

• Accuracy and Updating Information:
You can amend any inaccuracies by contacting us via post or email and request that we update, modify or delete any Personal Data that is no longer accurate or up-to-date.

8. Rights of individuals

In accordance with applicable laws you have the right to the following:

• Access to Your Data:
The law gives you a right to be told what personal data we hold about you, subject to certain limitations. This is commonly known as a "data subject access request". Please email us on marketing@hcpackaging.com for all data subject requests.

• Stopping Marketing:
If we are sending you marketing communications using your Personal Data, the law gives you a right to ask us to stop doing this.

• Re-subscribe Marketing:
If you have unsubscribed or opted- out of HCP Packaging marketing, you will need to contact your HCP representative or email marketing@hcpackaging.com to confirm that you wish to be put back on our mailing list.

• Object to 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 which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

• Damage and Distress:
The law gives you a right to ask us to stop using your data for any purpose, where that purpose is causing you unwarranted substantial damage or distress; and the law gives you a right to claim compensation for damage suffered if we breach the law.

• Changes to Your Personal Data:
You have the right to ask for the rectification, erasure or blocking of any of your Personal Data which is inaccurate.

• Request restriction of processing of your personal data:
This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend 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 the transfer of your Personal Data to you or to a third party:
We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• How long do we hold your Personal Data:
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including, but not limited to; Contact, Identity and Transaction Data) for six (6) years after they cease being customers for tax purposes. 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 which case we may use this information indefinitely without further notice to you. In some circumstances you can ask us to delete your data: see Request erasure of your personal data, below for further information.

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

10. What we may need from you

We may need to request specific information from you to help us 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 relation to your request to speed up our response.

11. Time limit to respond

We try to respond to all legitimate requests within thirty (30) calendar days from the date of receipt of your request. Occasionally it may take us longer, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Where you are sending us a request via post rather than email we recommend you send it via recorded delivery to guarantee safe delivery.

12. Purposes for which we will use your Personal Data

Purpose/Activity:
To register you as a new customer.

Type of data:
(a) Identity
(b) Contact

Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you.

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Purpose/Activity:
To process and deliver your order.

Type of data:
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

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Purpose/Activity:
To manage our relationship with you (which will include notifying you about changes to our terms or Privacy Policy).

Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests

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Purpose/Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Type of data:
(a) Identity
(b) Contact
(c) Technical

Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

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Purpose/Activity:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

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Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

Type of data:
(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

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Purpose/Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you.

Type of data:
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business).

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not liable for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

14. Marketing from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods from us and, in each case, you have not opted out of receiving that marketing.

15. Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the ”HCP Packaging” group of companies for marketing purposes.

16. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time via email (marketing@hcpackaging.com). Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.

17. Change of purpose

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 wish to get an explanation as to 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 we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

18. Disclosures of your Personal Data

We may have to share your Personal Data with the parties set out below:

Internal Third Parties:
Other companies in our group acting as joint controllers or processors and that provide IT and system administration services and undertake reporting.

External Third Parties:
Including service providers acting as processors or hosts who provide IT and system administration services and service agents for support and delivery companies for the transportation of products.

Professional advisers acting as processors or joint controllers including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Government Agencies for example for fraud or illegal activities.

Third parties to whom we may choose to sell, transfer, or merge parts or all of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data 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 permit them to process your Personal Data for specified purposes and in accordance with our instructions.

19. International transfers

We share your Personal Data within the “HCP Packaging” Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• 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 to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

20. Change to this Privacy Policy

We may change this Privacy Policy at any time in line with data protection laws and will update this page accordingly. You should therefore periodically visit this web page to check our current policy.

21. Severability

If a court finds part of this Privacy Policy illegal, the rest will continue in force. Each of the clauses of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining clauses will remain in full force and effect.

22. Assignment

You may not assign, mortgage or otherwise transfer this Privacy Policy, data or any rights, duties and obligations hereunder.

It is acknowledged by you that we may use our employees, officers, representatives or third party consultants to carry out our work within this Privacy Policy. We may assign, licence or sub-contract the benefit of this Privacy Policy, data or any rights, duties or obligations to any firm or company in which we hereafter acquire a controlling interest or which acquires a controlling interest in us without prior approval from you. Save that we shall remain primarily liable hereunder until such time as the prospective assignee enters into an agreement to fulfil our obligations hereunder.

23. Waiver

No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term.

24. Third parties

Save to the extent expressly set out herein, this Privacy Policy and is not intended to nor shall it create any rights, entitlements, claims or benefits enforceable by any person that is not a party hereto. Accordingly, save to the extent expressly set out in this Privacy Policy, no person shall derive any benefit or have any right entitlement or claim in relation to this agreement by virtue of the Contract (Rights of Third Parties) 1999.

25. Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of England. The parties irrevocably agree that the English Courts shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this Privacy Policy.

26. Data Controller

The data controller responsible in respect of the information collected on this website is HCP Packaging Ltd.

27. Contact

If you have any questions about this Privacy Policy or our treatment of your personal information, please write to us by email to marketing@hcpackaging.com or by post to: HCP Packaging UK Ltd, Tayfield House, 38 Poole Road, Westbourne, Bournemouth, Dorset BH4 9DW.