PRIVACY POLICY

This website is operated by HDC Americas Inc. You can contact us at the postal or email address that can be found in the footer on this page.

POLICY STATEMENT

HDC Americas Inc. respects your privacy and is committed to protecting your personal data. This policy (together with our Terms of Business, Disclaimer, and any other documents referred to on our website) sets out the basis of how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

In this Privacy Policy, HDC Americas Inc. ('we' or 'us') is the 'data controller' (the company who is responsible for, and controls the processing of, your personal data).

THE WAY WE COLLECT PERSONAL DATA

BY EMAIL
We will obtain personal data about you such as your name, email address, and query details, whenever you email HDC Americas Inc. By emailing us customers are voluntarily providing us with Personal Data and, by implication consent to us processing your Personal Data in relation to your enquiry.

We will only use your personal data when the law allows us to. To deal with your enquiry, we will need to process your Personal Data. Subject to how the enquiry progresses, we may also need to retain Personal Data you have provided. Details of how we process Personal Data is detailed below:

• Where we need to perform a contract we are about to enter into or have entered into with you. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


• 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.  “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance any potential impact on 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 are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).


• Where we need to comply with a legal or regulatory obligation.   This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Specifically the data we collect includes:

• Identity Data which can include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data which can include correspondence address, billing address, delivery address, email address and telephone numbers.
• Financial Data which can include bank account and payment card details.
• Transaction Data which can include details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data which can include internet protocol (IP) address, your login data, 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 which can include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data which can include information about how you use our website, products and services.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

WEBSITE COOKIES
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

INFORMATION ABOUT OTHER INDIVIDUALS
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:?give consent on his/her behalf to the processing of his/her data?receive on his/her behalf any data protection notices

THIRD PARTY LINKS
This website includes links to external third-party websites and/or applications.  External links from this website are always opened in a separate browser window or tab which transfers you to the external website in a different browser session.   We do not control those third-party websites and are not responsible for their privacy statements, and clicking on the links and/or enabling those external browser sessions may allow third parties to collect or share data about you.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

HOW WE USE YOUR PERSONAL DATA
We may use your data for the following purposes:

• to help us identify you and any business you conduct with us
• administration
• research, statistical analysis and behavioural analysis
• customer profiling
• fraud prevention and detection
• security vetting
• improving our services

DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to:

• our agents and service providers
• law enforcement agencies in connection with any investigation to help prevent unlawful activity

KEEPING YOUR DATA SECURE
We will use technical and organisational measures to safeguard your personal data. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you, or to you via the internet.

MONITORING
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance and training.

INTERNAL THIRD PARTIES
Other companies that at any time are in a legally-formed group of companies that includes HDC Americas Inc and are acting as joint controllers or processors. This includes our subsidiaries, our ultimate holding company and its subsidiaries.

EXTERNAL THIRD PARTIES

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• US Internal Revenue Service, regulators and other authorities acting as processors or joint controllers based in the USA who require reporting of processing activities in certain circumstances.

ACCESS TO YOUR PERSONAL DATA
Your right of access to information can be exercised in accordance with the appropriate legislation enacted at the time of exercise.  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. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

You may:

• 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 it.
• Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• 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.
• 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 carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CHANGES TO OUR POLICY
Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Data Protection Officer.

DATA CONTROLLER
HDC Americas Inc is the controller and responsible for your personal data (collectively referred to as “HDC Americas Inc”, “we”, “us” or “our” in this notice).   We have appointed a data protection officer (DPO) 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 DPO using the details set out below.

Data Protection Officer
HDC Americas Inc 
1719 Newport Gap Pike 
Wilmington
DE 19808-6119
USA
Email:  info@hdc-americas.com


Crispian P. Emberson
President
30 August 2016

Reviewed annually.
Next review date 30 August 2019