We are HPO Technologies Limited.
If you have any questions about this notice please contact us at data@hpotechnologies.com or by writing to Grosvenor Arch, Battersea, London, England, SW11 8AB.
This notice was last updated on 01 October 2024
When does this notice apply?
This notice applies to the personal data that we process both:
- In our role as data controller – in circumstances where we determine how and why your personal data is used. This includes:
- For customers: The personal data we collect from you as our customer.
- For end users: The personal data we collect when you interact with us in certain contexts online, for example, when you access or use our services, or when you communicate with us via email. It also includes the personal data we collect when you interact with us in certain contexts offline, for example, when you communicate with our sales or support service teams in person, via phone, or by mail.
- For prospective employees of HPO Technologies: The personal data we collect from you as a candidate.
- In our role as data processor – in circumstances where we act as a service provider to our customers who have asked you as an end user to use our services as part of your role (for example as an employee or recruit), and our customer is the data controller. If you have questions about our processing of your personal data in your capacity as a data processor, please contact your employer directly.
How do you use my data?
As a data processor:
- When you use our services as an end user we will collect the data you provide to us directly and data from connected devices and apps, which may include health information inferred from your metrics such as your heart rate, height and weight. We collect and use your personal data to provide our services under our contract with your employer and collect and use your health data with your explicit consent.
As a data controller:
- When you create and log into your account as a customer we will collect your details as a representative of the customer: your name, email address, phone number, employer name, employer address and payment details. We collect this to take steps to enter into a contract with you as a customer and allow you to purchase our services.
- When you create your account as an end user we will collect your name, email address and phone number. We collect this in order to take steps to enter into a contract with you to use our services.
- When you enable location tracking as an end user we will collect and process your location information while you are using our services to provide you with location activity tracking. We collect your location information with your consent and you can disable location tracking at any time.
- To send you, as a customer or end user, marketing information. Where you have previously expressed an interest in our products or services (and not opted-out of marketing) we will use your name and email address to send you updates because it is in our legitimate interests to promote our services we think you might be interested in. Where you have opted in via our website to receive updates on our services including offers, promotions and new options, we will process your personal data to provide you these updates in line with the preferences you have provided and will only use your personal data in this way with your consent. You can withdraw your consent to marketing at any time by contacting us at data@hpotechnologies.com or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.
- When you contact us as a customer or end user either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
- When you use our website as a customer or end user and consent to our use of cookies we will collect information about how you use our website. We may use your personal data contained within this information to improve our website and to better understand how people use it. More details on the information we collect and how we do this is set out in our Cookie Policy below.
- When you apply for a job with us as a candidate we may collect your name, contact details, recruitment information (e.g. right to work documentation and references), test results, qualifications, accreditations and any additional personal data we may receive from our recruitment partners. We will use your personal data to assess your suitability for our available roles. We do this to perform our contract obligations or to take steps at your request, before entering into a contract. Where we process your right to work documentation, we will do so to comply with our legal obligations.
- If our business is sold we process your personal data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal data in this way, the buyer of our business may not be able to provide services to you.
Who do you share my data with?
- We share the personal data we collect as a data processor with your employer. Your employer may use this personal data for the purposes of assessing your performance in your role, including making decisions about changes to your training and recruitment. If you have any questions about how the personal data we collect as a data processor is used, you must contact your employer directly.
- Business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you.
- Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our, our customers' and others' rights.
- Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.
Where do you store my data?
We store your data on our servers / third party servers which are based both in the UK and outside of the UK. When working with third parties we may need to transfer your personal data outside of the UK and / or EU.
Whenever we transfer your personal data outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this notice as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at data@hpotechnologies.com for more information about this.
How long do you keep my data for?
For the personal data we process as a data controller we will only retain your personal data for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
For the personal data we process as a data processor for our customers we will retain your personal data in accordance with our contract with our customer. Please contact your employer if you have any questions about how long they will retain your personal data or how long we will retain it on their instructions.
In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.
What are my rights under data protection law?
You have various other rights under applicable data protection laws, including the right to:
- access your personal data (also known as a “subject access request”);
- correct incomplete or inaccurate data we hold about you;
- ask us to erase the personal data we hold about you;
- ask us to restrict our handling of your personal data;
- ask us to transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with us or the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU you can find your relevant supervisory authority here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
If you would like to exercise your rights in connection with the personal data we process as a data controller, please contact us at data@hpotechnologies.com.
If you would like to exercise your rights in connection with the personal data we process as a data processor for your employer as our customer, please contact them directly. We cannot provide you with access to your personal data, delete your personal data or facilitate any of your other rights until your employer as our customer instructs us to do so.