Heur Ltd respects your privacy and is committed to protecting your personal information.

This privacy policy explains how we collect, use, disclose and protect personal information relating to:

• Visitors to our website.

• People who contact us or enquire about our services.

• Newsletter subscribers and marketing recipients.

• Business contacts, prospective clients and suppliers.

• Job applicants.

• Representatives and employees of our clients and suppliers.

Our website is www.heur.co.uk.

Heur Ltd is an ecommerce agency registered in England and Wales.

Company number: 12236415

Registered office:
5th Floor
167-169 Great Portland Street
London
W1W 5PF

For data protection purposes, Heur Ltd is the controller of the personal information described in this privacy policy.

Privacy enquiries, rights requests and data protection complaints can be sent to:

Email: hello@heur.co.uk

Post: Heur Ltd, 5th Floor, 167-169 Great Portland Street, London, W1W 5PF

When you interact directly with Heur, we will normally be the controller of your personal information.

As part of our ecommerce, CRM, performance marketing and consultancy services, we may also process personal information on behalf of our clients.

Where a client determines why and how that information is used, the client is the controller and Heur acts as its processor under a written agreement. In those circumstances, the client’s privacy policy appliesand questions or rights requests should normally be directed to the clientconcerned.

The personal information we collect depends on how you interact with us.

Information you providedirectly

This may include:

• Your name.

• Your work email address and telephone number.

• Your job title and employer.

• Information you submit through our contact forms.

• Details about your business, requirements or proposed project.

• Communications sent by email, telephone, social media or other channels.

• Newsletter subscriptions and marketing preferences.

• Information relating to a client or supplier relationship.

• Feedback, complaints and requests relating to personal information.

The fields marked as required on our forms are neededso that we can respond to your request. You do not have to provide optional information.

Website and Device Information

When you use our website, we may collect:

• Your IP address.

• Browser and device type.

• Operating system.

• Approximate location derived from your IP address.

• Pages visited and links selected.

• Referring website or campaign.

• Date, time and duration of visits.

• Cookie identifiers and similar technical information.

Further information is provided in the Cookies section below and in our Cookie Policy.

Business Contact Information from Other Sources

For business development and relationship management,we may obtain professional information from:

• Publicly available company websites.

• Professional networking platforms such as LinkedIn.

• Business directories.

• Referrals and introductions.

• Conferences, networking events and industry events.

• Our clients, suppliers and commercial partners.

This may include your name, employer, job title, work contact details and publicly available professional information.

Job applicants

If you apply for a role with Heur, we may collect:

• Your name and contact information.

• Your CV and cover letter.

• Employment history and qualifications.

• Portfolio or work examples.

• Interview notes and assessment information.

• Salary expectations, availability and right-to-work information.

• References, where appropriate.

• Other information that you choose to provide as part of your application.

Please avoid providing sensitive personal information unless it is relevant to your application or we have asked you to provide it.

We use personal information to:

• Communicate with clients and suppliers.

• Deliver and manage our services.

• Administer contracts and projects.

• Manage meetings, reporting and commercial relationships.

• Maintain appropriate business and financial records.

We rely on our legitimate interests in operating our business and managing professional relationships. We may also rely on contractual necessity or a legal obligation where applicable.

Newsletter Subscriptions

If you subscribe to our newsletter, we use your information to send ecommerce insights, company updates, invitations and other marketing communications.

We normally rely on your consent. You may withdraw that consent at any time by using the unsubscribe option in an email or contacting us.

Withdrawing consent does not affect processing that took place before consent was withdrawn.

Business-to-Business Marketing

We may contact relevant business professionals about Heur’s services, content or events where permitted by law.

Depending on the circumstances, we rely on:

• Your consent.

• Our legitimate interests in promoting our services and developing relevant business relationships.

Where we rely on legitimate interests, we consider whether the communication is relevant to your professional role and balance our interests against your rights and expectations.

We comply with the Privacy and Electronic Communications Regulations where they apply.

You can object to direct marketing at any time. Every marketing email will include an unsubscribe or opt-out method.

Operating and Improving Our Website

We use website and technical information to:

• Operate and secure the website.

• Diagnose technical problems.

• Understand how the website is used.

• Improve website content, navigation and performance.

• Measure the effectiveness of marketing activity.

• Prevent misuse, fraud and security threats.

Depending on the technology and purpose involved, we rely on consent, legitimate interests or an applicable exception under the Privacy and Electronic Communications Regulations.

Recruitment

We use applicant information to:

• Assess applications.

• Communicate with applicants.

• Arrange and conduct interviews.

• Make recruitment decisions.

• Verify information and obtain references.

• Comply with employment and legal obligations.

We rely on taking steps before potentially entering into an employment contract, our legitimate interests in recruiting suitable employees and our legal obligations.

Legal, Regulatory and Security Purposes

We may use information to:

• Comply with laws, court orders and regulatory requirements.

• Establish, exercise or defend legal claims.

• Maintain records demonstrating our compliance.

• Protect Heur, our staff, clients and systems.

• Investigate suspected misuse, fraud or security incidents.

We rely on our legal obligations and our legitimate interests in protecting our business and legal rights.

Our website uses cookies and similar technologies.

These may include:

• Strictly necessary technologies required for the website to function or remain secure.

• Functional technologies that remember preferences or improve how the website operates.

• Analytics technologies that help us understand website use and improve performance.

• Advertising or measurement technologies used tounderstand marketing effectiveness or deliver relevant advertising.

Where consent is required, we will not use the relevant technology until you have made a choice through our cookie controls.

Certain limited analytics or functionality technologies may be used without consent where a specific legal exception applies. Where werely on such an exception, we will provide clear information and an easy way to object.

You can review or change your choices through thecookie settings tool available on our website.

Our Cookie Policy provides further information about the technologies used, their providers, purposes and durations.

We may share personal information with carefully selected recipients where this is necessary and lawful.

These may include:

• Website hosting, form and content-management providers.

• Email, calendar and business communication providers.

• Customer relationship management and marketing platforms.

• Analytics, advertising and website-measurement providers, subject to your cookie choices.

• Cloud hosting, storage, security and IT support providers.

• Recruitment platforms, advisers and reference providers.

• Professional advisers, including accountants, lawyers, auditors and insurers.

• Contractors and consultants working with Heur.

• Government bodies, regulators, courts and law-enforcement authorities.

• A purchaser, investor or adviser involved in a possible sale, restructuring or investment in Heur.

We do not sell or rent personal information.

Where a supplier processes information on our behalf,we require it to protect the information and use it only for the agreedpurposes.

Some organisations, such as social media or advertising platforms, may act as independent controllers for some of their activities.Their own privacy policies will apply to that processing.

Some of our suppliers and technology providers may process personal information outside the United Kingdom.

Where this involves a restricted international transfer, we use an appropriate legal mechanism. This may include:

• UK adequacy regulations.

• The UK International Data Transfer Agreement.

• The UK Addendum to the European Commission’s Standard Contractual Clauses.

• Another transfer mechanism permitted under UK data protection law.

We also take steps to ensure that appropriate protection is provided for the information.

You may contact us for further information about the safeguards used for a particular transfer.

We use appropriate organisational and technical measures designed to protect personal information against accidental loss, destruction, alteration, unauthorised access or disclosure.

Access is limited to people who reasonably need the information for their work.

Our employees, contractors and service providers are subject to appropriate confidentiality and security requirements.

No internet transmission or storage system can be guaranteed to be completely secure. If a personal data breach occurs, we will assess it and make any required notifications.

We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, including legal, regulatory, accounting and reporting requirements.

Our normal retention periods are:

Enquiries

If you contact us but do not become a client, we normally retain the enquiry for up to 12 months after our last substantive communication, unless there is a reason to retain it for longer.

Client and Supplier Records

Contracts, invoices and key commercial records are normally retained for up to six years after the end of the relevant relationship or financial period, subject to applicable tax, accounting and legal requirements.

Operational project information may be deleted earlier when it is no longer required.

Marketing Information

We retain active marketing information until you unsubscribe, object or we determine that it is no longer relevant.

After an opt-out, we may retain a minimal suppression record so that we can continue to respect your preference.

Job Applications

We normally retain unsuccessful applications for up to six months after the recruitment process ends.

With your permission, we may retain your application for up to 12 months so that we can consider you for future roles.

Information relating to successful applicants will be handled in accordance with our employee privacy arrangements.

Website and Cookie Information

Retention periods for website identifiers and cookiesare provided in our Cookie Policy.

We may retain information for longer where required to resolve a complaint, investigate an incident, meet a legal requirement or establish, exercise or defend a legal claim.

Depending on the circumstances, you may have the right to:

• Ask for access to the personal information we hold about you.

• Ask us to correct inaccurate or incomplete information.

• Ask us to delete your information.

• Ask us to restrict how your information is used.

• Object to processing based on legitimate interests.

• Object to direct marketing.

• Ask to receive certain information in a portable format.

• Withdraw consent where processing is based on consent.

• Complain about the way your information has been handled.

These rights are not absolute and may not apply in every situation.

We may need to request information to confirm your identity before acting on a request. We will only request information that is reasonably necessary.

There is normally no fee for exercising your rights. However, the law allows us to charge a reasonable fee or refuse a request in limited circumstances.

We normally respond within one month. Where legally permitted, we may extend this period for a complex request and will tell you if this happens.

To exercise a right, email hello@heur.co.uk.

You have the right to object at any time to our use of your personal information for direct marketing.

You can:

• Use the unsubscribe link in a marketing email.

• Reply to the communication asking us to stop.

• Email hello@heur.co.uk.

We will stop using your information for direct marketing, although we may retain a minimal record of your opt-out.

If you have concerns about how we have used your personal information, please contact us at hello@heur.co.uk and make clear thatyou are raising a data protection complaint.

We will:

• Provide a clear route for making a complaint.

• Acknowledge your complaint within 30 days.

• Investigate the matter appropriately and without unduedelay.

• Keep you informed where the investigation is ongoing.

• Explain the outcome without undue delay.

We would appreciate the opportunity to address your concern directly.

You also have the right to complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: ico.org.uk/make-a-complaint

Our website and services are intended for business users and are not directed at children.

We do not knowingly use the website to collect personal information from children. If you believe a child has provided personal information to us, please contact us.

Our website may contain links to websites, platforms orsocial media services operated by other organisations.

Those organisations control their own use of personal information. We recommend reviewing their privacy policies before providing information or using their services.

This privacy policy does not cover third-party websites or services.

We keep this privacy policy under review and may update it to reflect changes to our services, systems or legal obligations.

The latest version will be published on our website. Where a change materially affects how we use personal information, we will take reasonable steps to bring it to the attention of affected individuals before the new use begins.

Questions about this privacy policy or Heur’s use of personal information should be sent to:

Email: hello@heur.co.uk

Post:
Heur Ltd
5th Floor
167-169 Great Portland Street
London
W1W 5PF