Hook Technology Website Privacy Notice

Last updated 23rd May 2024

1. About this notice

Hook Technology Limited is committed to protecting and respecting your privacy. This notice describes how we collect, use and otherwise process personal information relating to you, or that you provide to us:

(i) when you engage with us as a customer or supplier;

(ii) when you visit or use:

• our website at hook.co (the “Website”);
• any of our software applications (“Apps”) and;
• our social media pages; and

(iii) when you apply for a job with us.

Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this notice carefully to understand our practices regarding personal information.

By engaging with us via any of the means set out above, you acknowledge you have read and understood the practices described in this notice.

For the purposes of this notice, all references to the Website shall include a reference to the Apps, and references to “Hook”, “we”, “us” or “our” are to Hook Technology Limited, a company registered in England and Wales under company registration number 12362866 with our registered office at 80 Cheapside, London, EC2V 6EE.

For the purposes of data protection laws, the data controller is Hook. Hook is registered with the UK Information Commissioner’s Office (ICO): ZA884685.

In this notice, the terms “personal data (or information)”, “processing”, “data controller” and “data processor” shall have the meaning ascribed to them in the UK General Data Protection Regulation.

2. What personal data do we collect?

The type of information we collect from you will depend upon the type of interaction you have with us.

Broadly speaking, the types of personal data that we collect may include:

• if you are a customer or supplier of Hook: your first and last name, job title, email address, postal address, telephone number and the details of the transactions which you conduct with us;
• if you are a job applicant: your full name, contact details (including address, phone number and email address), identification details, employment history and education history, References, and information from your LinkedIn or other social media profiles. We have a specific privacy notice for job applicants: https://apply.workable.com/hook-technology/gdpr_policy/?lng=en;
• if you are a visitor to our Website: technical information like your IP address, geographical location, browser type, and length of visit and pages viewed; and
• if you otherwise interact with us: personal data you provide to us such as when you register or create an account with us or when you communicate with us through email or our social media pages.

You are under no obligation to provide any such data. However, if you choose to withhold requested information, we may not be able to properly engage with you and we may have to cancel a contract we have entered into with you.

3. How do we use personal data?

We use personal data for the purposes of our legitimate interests as follows:

• to communicate with you and respond to your queries;
• to provide you with information, products or services that you request from us;
• for the purposes of recruiting staff for our business;
• to understand that ways in which our Website is being accessed and used;
• to ensure that content from the Website is presented in the most effective manner for you and for your computer;
• to market our Apps to you and others, including by email and other direct marketing channels and via online targeted advertising on other websites and platforms;
• as part of our efforts to keep the Website safe and secure; and
• to develop and improve our products and services.

4. Lawful basis for processing

We will only process the personal data provided to us where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal data. In almost every case, the lawful basis will be one of the following:

• Our legitimate business interests: Where we have a legitimate interest to use personal data regarding you or individuals connected with your business in relation to the operation of our business. Also, where it is necessary for system administration purposes and for internal operations, including survey purposes.
• Performance of an agreement with you (or in order to take steps prior to entering into an agreement with you): For example:
  • where you have provided your information in order to receive details in relation to our services; or
  • where you have provided your payment information in order to receive our services.
• Compliance with the law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
• Consent: Where you have given consent for us to process your personal data for a specific purpose.

5. How do we share personal data with third parties?

We may disclose personal data relating to you in certain circumstances including the following:

• suppliers and other service providers that we engage to help us run our business, such as IT services suppliers and analytics and search engine service providers that assist us in the improvement and optimisation of the Website and Apps;
• advertising partners that help us promote our Apps on other websites and platforms, including on search engines and social media platforms;
• our professional advisors, including lawyers, accountants, tax advisors and auditors;
• law enforcement bodies, courts of law or as otherwise required or authorised by law; and
• regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies.

We may also disclose personal data to third parties:

• in the event that we sell our business or assets, in which case we may disclose your personal data to the prospective buyer or buyer of such business or assets;
• if we restructure our business, or if we integrate our business with another group of companies, in which case personal data held by us will be disclosed to the new owner to be used in the same ways set out in this notice; and
• if we are under a duty to disclose or share personal data relating to you in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions on which we supply services to you and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Before Hook discloses any personal data to suppliers and other service providers, we take steps to ensure that the recipient will protect personal data in accordance with applicable privacy laws and in a manner consistent with this notice.

6. External Links

Although the Website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.

The Website may, from time to time, contain links to and from the websites of our distributors, partners, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

7. Social Media Platforms

Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.

8. Where do we store personal data?

The personal data that we collect from you may be transferred to, and stored at, locations outside the United Kingdom (“UK”), for example in Ireland in the European Economic Area (“EEA").

Whenever we transfer your information outside of the UK or EEA, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” or UK “International Data Transfer Agreement” or “UK Addendum”) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances. If you would like further information, please contact us using the contact details at the end of this privacy notice.

9. How do we protect personal data?

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to Website; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.

All information you provide to Hook is stored on secure servers. The safety and security of your information and any personal data relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Hook takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.

10. Your rights

You have the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We also want to make sure that personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate.

Where provided for by applicable laws, you have the right, in certain circumstances:

• to request the erasure of personal data relating to you that we hold;
• where the processing of your personal data is based on your consent, to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
• not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;
• to request the restriction of processing of personal data relating to you that we hold;
• to object to our processing of personal data relating to you that we hold; and
• to request the transfer of your personal data to you in a machine-readable format that you can share with another data controller.

Requests in this section should be sent by email or by writing to us using the contact details set out at the end of this notice.

11. Marketing

We will only send you marketing material where permitted by law or where we have obtained your consent. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may receive marketing communications from us if you have requested information from us or engaged with us and you have not opted out of receiving that marketing.

Third-party marketing: We are committed to protecting and respecting your personal data. We will not sell or rent your personal data to any third parties. We will not share your personal data with third parties for marketing purposes.

Opting out of marketing: You can opt out of receiving marketing emails by following the instructions with the email or by sending an email or by writing to us using the contact details set out at the end of this notice.

If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.

Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com/”.

12. 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. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of online payment services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed.

We use the following cookies (and similar technologies) on the Website:

Cookie Name _ga

Provider of Cookie Google

Purpose of Cookie Statistical analysis of page use, page interactions and paths to evaluate and develop our Website

Privacy Notice Google Cookie Technologies

Cookie Name _gid

Provider of Cookie Google

Purpose of Cookie Used to distinguish users

Privacy Notice Google Cookie Technologies

Cookie Name _gat

Provider of Cookie Google

Purpose of Cookie Used to throttle request rate

Privacy Notice Google Cookie Technologies

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit a site/page. And some services and functionalities may not work properly at all.

You can manage/delete cookies as you wish - for details, see aboutcookies.org.

13. Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://prighter.com/q/14347898258

14. Changes to this notice

Hook reviews and amends its privacy notice from time to time. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page occasionally to review any updates or changes to this privacy notice. This helps you be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed.

15. Contacting Us

If there are any questions regarding this privacy notice, you may contact us using the information below.

Hook Technology Limited, 80 Cheapside, London, EC2V 6EE

Email: contact@hook.co

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Alternatively, if you are located in the EU, you may lodge a complaint to your national Data Protection Authority. The contact information for such authorities can be found at this web address: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en