Hexr Privacy and Cookies

 

  1. Purpose of this Privacy Policy

 

  • We, HEXR Limited, are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or which you provide to us, will be processed by us or on behalf of us.
  • This website is not intended for children and we do not knowingly collect data relating to children.
  • So that you are fully aware of how and why we are using your data, it is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
  • This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

 

  1. INFORMATION ABOUT US AND OUR DPO
    • HEXR Limited, a company registered in England and Wales under company number 10999327 and with our registered office at 18 Finsbury Square, London, EC2A 1AH (trading under the name “Hexr”), is the data controller and responsible for personal data collected from you under this Privacy Policy. Our ICO registration number is A8476380.
    • HEXR is referred to as "we", "us" or "our" in this Privacy Policy.
    • 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:
    • Email address: hello@hexr.com
    • Postal address: Richard Apletree, HEXR Limited, 15B St George’s Mews, London.

 

  1. CHANGES TO THIS PRIVACY POLICY
    • We may amend this Privacy Policy from time to time and it was most recently updated on 7 January 2020. You should print a copy of this Privacy Policy or save it to your computer or other device for future reference.

 

  1. YOUR DUTY TO INFORM US OF CHANGES
    • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us via our DPO, whose details are set out here.

 

  1. 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 responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

  1. How we may collect and process your personal data
    • 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) and the following provisions to do apply to 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, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Biometric Data includes (only) your head scan. We also record the GPS position of your scan so that we can identify where you had the scan (and can contact the provider if necessary).
    • Background Data includes any information that you provide regarding what type of cycling you do (mountain, road, commuting, time trial), how many hours you cycle in a typical week and your other relevant hobbies (eg skiing, sailing, climbing).
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes 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 includes your username and password, purchases or orders made by you.
    • 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 and our third parties and your communication preferences.
    • We also collect, use and may share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
    • We do not collect any Special Categories of Personal Data (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 other biometric data) about you other than your head scan.

 

  1. IF YOU FAIL TO PROVIDE PERSONAL DATA
    • 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. In this case, we may have to cancel your order but we will notify you if this is the case at the time.

 

  1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
    • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.

 

  • We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a)     Creating bespoke helmet

 

(b)    Manage payments, fees and charges

(c) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Biometric and Background

(c) Financial

(d) Transaction

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

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

 

(a) Identity

(b) Contact

(c) Technical

 

(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

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

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)

 

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

 

(a) Technical

(b) Usage

 

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)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you unless you have asked us not to

 

(a) Identity

(b) Contact

(c) Background

(d) Technical

(e) Usage

(f) Profile

(g) Marketing and Communications

 

Consent – please see Marketing section below

 

  1. MARKETING
    • We strive to provide you with choices regarding use of your personal data, particularly around marketing and advertising.
    • You will only receive marketing communications from us if you have requested this information from us.
    • We will also get your express opt-in consent before we share your personal data with any third party for marketing purposes.
    • 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 our DPO at any time, whose details are set out here.
    • Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in relation to your order, which we will generally need to retain for the standard period set out in clause 15.

 

  1. COOKIES
    • A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to distinguish you from other users of our website. 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 this website.
  • Analytical/performance cookies. They 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.
  • 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, store items in an electronic shopping basket between visits 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 will use this information to make our website and the advertising displayed on it more relevant to your interests.

 

 

  • You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) this may affect the functionality of the website.

 

  1. 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 our DPO, whose details are set out here.
    • 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.

 

  1. Disclosure of your information
    • We may share your personal data with our employees and the third parties that we appoint to help us run our business. Such parties may process your personal data for the purposes set out in the table at Clause 8 above (only).
    • The key third parties are:
  • Shopify - who process the payments for all orders made on the website. Shopify will use the payment information to process your order in accordance with their own privacy policy – see here for further details: https://www.shopify.com/legal/privacy..
  • We use third parties to provide head scans when you are unable to travel to us. These get turned into personalised helmet designs which are sent to us using an anonymised unique reference number.
  • We use an external logistics partner who are provided with your title, first name, last name and delivery address in order to deliver any orders that you place.
  • We also use a performance marketing provider who have access to your first name, last name and email address.
  • If we are acquired by or merged with, another company, we may also transfer your personal data to purchasers or subsidiaries (and potential purchasers or subsidiaries). This will enable you, for example, to continue your relationship with us despite a change of ownership. The new owners could only use your personal data in the ways as set out in this Privacy Policy.
  • We may disclose your personal information to our professional advisors or if we are under a duty to do so in order to comply with any legal obligation.
    • 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.

 

  1. Where we store your personal data
    • Our external third parties may be based outside the EEA, in which circumstances 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 shall ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • To countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • 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 Europe and the US.
    • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. Security
    • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk.
    • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
    • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    • 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, regulatory, tax, accounting or other requirements.
    • By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers and if you purchase a helmet, we must also retain the headscan for five years after the helmet was manufactured for the purposes of the helmet certification. If you have registered with us but not placed an order, then we will (unless you request otherwise) hold your headscan for two years and your Identity Data, Contact Data, Background Data, Technical Data, Usage Data and Marketing and Communications Data preferences for six years.
    • In some circumstances you can ask us to delete your data: see clause 16 below for further information.
    • In some circumstances we will 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.

 

  1. Your rights
    • Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
  • 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:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • 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 our services to you. We will advise you if this is the case at the time you withdraw your consent.
    • If you wish to exercise any of the rights set out above, please contact our DPO, whose details are set out here.
    • 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 could 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 could 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.
  1. QUERIES AND COMPLAINTS
    • You have the right to make a complaint about how we have processed your personal data to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact our DPO in the first instance, whose details are set out here.
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