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Privacy and Data Protection Policy

Important information and who we are

Welcome to Havas Market Limited Privacy and Data Protection Policy (“Privacy Policy”).

At Havas Market Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

  • Customers
  • Website users
  • Suppliers
  • Business contacts
  • Employees/Staff Members
  • Third parties connected to your customers
  • and any other individuals that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Who is Your Data Controller

Havas Market Limited is your Data Controller and responsible for your Personal Data.

Any inquiries about your data should either be sent to us on email at [email protected] or sent in a letter to Data Protection Officer, Havas Village London, 3 Pancras Sq, London, N1C 4AG  United Kingdom.

You have the right to make a complaint at any time 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 us in the first instance.

Third parties and suppliers

Havas Market Limited use external providers which may have access to your personal data. These third parties provide services such as hosting, technical connections in our applications or may help us to process your personal data as described in this Policy. Havas Market Limited has signed agreements with such providers in accordance with GDPR requirements.

Types of Data / Privacy Policy Scope

“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).

We may collect, use, store and transfer different kinds of Personal Data which we will only use when the law allows us to. Examples provided below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us at [email protected]

  • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth, job title.
  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
  • Transactional Data: This is information of details and records of all payments you have made for our services or products (including STRIPE payments for Amazon Support services).
  • Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
  • Customer Support Data: This includes feedback and survey responses.
  • Usage Data: information about how you use our website, products and services.

We do not collect any Special Categories of Personal Data about you (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 biometric data). Nor do we collect any information about criminal convictions and offences.

The Legal Basis for Collecting Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main legal bases we rely on are:

  • “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
  • “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
  • “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
  • “Legitimate Interest”: We may collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedoms or interests.

Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

How we process your personal data

Havas Market Limited respects the rights of each individual to have their privacy and personal data protected. Havas will observe the following principles when processing your personal data:

  • Processing your personal data fairly, lawfully and in a transparent manner;
  • Collecting your personal data for specified, legitimate purposes and not processing further in ways incompatible with those purposes;
  • Collecting your personal data which is relevant to and not excessive for the purposes for which it is collected and used.  We may render personal data anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
  • Maintaining your personal data accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete;
  • Keeping your personal data only as long as it is necessary for the purposes for which it was collected and processed;
  • Processing your personal data in accordance with the individual’s legal rights;
  • Taking appropriate technical and organizational security measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal data;
  • Processing your personal data only if it is lawful in accordance with a legal basis including if you have unambiguously given your consent to such process.

Data Retention

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Links to third-party websites

Havas Market Limited websites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the Havas Market Limited website. We do not control those third-party websites or their privacy practices, which may differ from our practices.

We do not endorse or make any representations about third-party websites. The personal data you choose to provide to or that is collected by these third parties are not covered by this Policy. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal data.

We may also provide social media links that enable you to share data with your social networks and to interact with Havas Market Limited on various social media sites. Your use of these links may result in the collection or sharing of data about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the data that may be collected, used, and shared by those sites. If you post, comment, indicate interest, or share personal data, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal data you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Havas Market Limited have control over.

Your data protection rights

Right of access: As data subjects you may inquire about the nature of the personal data Havas Market Limited processes about you. You will be provided access to your personal data regardless of the location of the data processing and storage.

Right to rectification: If your personal data is inaccurate or incomplete, you may request that the data be amended.

Right to object: You have the right to object at any time to the processing of your personal by Havas.

Right to erasure: You can ask for the deletion of your personal data when it is allowed by applicable data protection laws and regulations.

Right to restriction of processing: You have the right to require a restriction of the processing of your personal data when it is authorized by applicable data protection laws and regulations.

Right to data portability: If you meet the conditions settled by the applicable data protection laws and regulation, you   have the right to receive a subset of your personal data and to transmit them from Havas to another data controller. You can also require the direct transmission from Havas to another controller when it is technically feasible.

Right to lodge a complaint: You have the right to lodge a complaint with the competent supervisory authority.

All requests for aforementioned rights, and any questions regarding this Data Protection Policy, may be sent to [email protected]

Changes to this Policy

Havas Market Limited reserves the right to modify this Policy as needed, for example, to comply with changes in laws, regulations, our practices and procedures, or requirements imposed by data protection authorities.

Last update: July 2023