Privacy Policy Version 1.04 – Last updated 10/12/2019
Who we are and Our Commitment to Your Privacy
Our company is registered in the name of The HILSE LTD under the Company House regulations. We have a website https://thehilse.co.uk that you can access once registered as a client or a host family or a School Representative, relevant to the Privacy Policy you are about to read.The HILSE LTD is committed to protecting the privacy of our potential and existing customers. The HILSE privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) handled by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other means as described below (in the “The HILSE Products”).We are unable to provide you with the services you have requested when the personal information is not provided by you, this is the main reason why we require your data. The other reason why we collect personal information is to carry out analytics to increase our company performance and our services to you.The HILSE LTD is the controller for the processing of your Personal Data as set out in this Privacy Policy that can be found at https://thehilse.co.uk/privacy-policy/. Being the controller means that The HILSE LTD is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.
Personal Data
“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:
Name and contact details (e.g. postal and email address, telephone number)
Account information (e.g. user name, profile picture or social media account ID)
Country of residence
Birth date
Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data
Directly from you: Information is received directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:
Offline: We collect Personal Data from you offline, for example when you contact us by phone, or enrol in a product or service or provide information to us in writing.
Online: We collect your Personal Data through our website https://www.thehilse.co.uk or email, for example when you sign up for a newsletter or a brochure, enrol in a product or service. We also collect Personal Data:
Through cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.
In particular for the https://www.thehilse.co.uk WordPress website: If you have an account and you log in to the site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”
From other sources. We may receive your Personal Data from other sources; social media platforms, including but not limited to; Facebook, Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to The HILSE accounts, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us.
If you browse our site https://www.thehilse.co.uk. We collect information only if you have registered and we have enabled you to access. Once registered, we may record details about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the The HILSE Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the The HILSE Products, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so.
How do we use Personal Data?
Your Personal Data will be processed by The HILSE for the purposes of completing your booking, providing you with the products and services that you have ordered, for customer service, administrative services or as otherwise necessary to perform the contract between you and us or as further described in this policy.
We may also use Personal Data:
For statistical purposes, calculating usage levels, and helping diagnose server problems with The HILSE Products as well as to ensure that The HILSE Products function properly.
To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring The HILSE Products experience and content based on your past activities on The HILSE Products. For example, depending on what The HILSE Product you have searched for on our website, or in previous browsing, the offer presented to you on The HILSE Products may be limited to a specific course length or location.
To market our products and services, including special promotions based on your interests, for example through email which maintains mailing lists and schedules. All such email communication will include a clear unsubscribe message.
How do we share Personal Data?
We share your Personal Data with our corporate affiliates, business partners and service providers mostly based in Italy and the UK:
Our corporate affiliates are for example the local schools in the UK that provide some of the services that you have ordered, or one of the principal associations that is offering space to host The HILSE’s programme. We also share some of your information with our host families and vice versa share the host families’ details with the students’ family.
Business partners are for example transportation companies, insurance companies, or accommodation providers; course leaders, activity leaders or other contractors for management of any of our programmes.
Service providers, such as providers of IT systems, for example for managing customer relations or payments; or providers of software and services for digital marketing automation and analytics.
We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
On what do we base our right to collect and use Personal Data?We base our right to collect and use your Personal Data in order to provide you with the services or products that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your Personal Data, such as for the marketing of products or services similar to the one(s) you have already purchased from that same legal entity.We use sensitive Personal Data based on your explicit consent (in the contract you sign while enrolling to on of our services and programmes). Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”.To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as marketing of products and services provided by The HILSE, we base this on your consent.
Security
We use appropriate organisational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.
Unsubscribe
If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by emailing us at anna@thehilse.co.uk. In your request, please indicate that you wish to stop receiving marketing communications from us or that you wish to be completely deleted from our client list. However, if you are registered for a programme your details cannot be deleted.Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.
Third Party Sites
This Privacy Policy does not address, and we are not responsible for the privacy, information or other practices of any third parties, including any third party operating any site to which The HILSE Product contain a link. The inclusion of a link on The HILSE Products does not imply endorsement of the linked site by us or by our affiliates.Additionally, we may provide you with access to third-party functionality that permits you to share your activities on The HILSE Products to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.
How long do we keep your personal information?
We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.We will store limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent.
If you are under the age of 16
If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use The HILSE Products.
Sensitive Data
We collect sensitive Personal Data only when you enrol in one of our programmes. Sensitive Personal Data is data related to health or medical condition, and criminal background. This type of data is sometimes necessary (for example in order to provide you with the services and products you have ordered and in relation to your insurance). We always ask your explicit consent to such processing and we promise to treat this information securely.
Updates To This Privacy Policy
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will email you if substantial changes are made to be noticed. Where required by law, we will seek your prior consent to any change.
Your Rights
You have a right to, once per calendar year, contact us and find out more about your personal data that we store. You have a right to receive your Personal Data in a machine-readable format and you have a right to transfer your personal to another data controller.You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.
Contact Us
If you would like to have a copy of the information The HILSE holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at the address The HILSE Ltd, 39 The Avenue, Liphook, GU30 7QS, UK.If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.
