Privacy Policy

HAVEYOUSEEN LIMITED, a company registered in England and Wales under company number 08732329, whose registered office is at The Town House, 114-116 Fore Street, Hertford, England, SG14 1AJ hereinafter referred to as "HYS" or "We" have created this privacy statement ("Statement") in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using www.haveyouseen.com (the "Site") and the HYS Services. Unless otherwise indicated, all definitions used in the HYS Participant Licence shall apply to this Statement and for the purposes of this Statement, ‘Personal Data’ shall include financial data. In this Statement, references to "You" and "Your" are references to the HYS Member (or a HYS Visitor to the Site as the case may be). When You use the Site and the HYS Services, You are consenting to the practices set forth in this Statement.

We know that Your privacy is very important to You which makes it very important to us. We aim to be as clear as possible in this Statement in respect of Your Personal Data. This Statement applies inter alia to Your Personal Data that We collect about You when You use the Site, how and when it is used, how We protect it and who has access to it. This Statement incorporates the Cookie Policy, the Website Terms of Use and the HYS Participant Licence by this reference (together the "Licence").

1. YOUR ACCEPTANCE OF THE STATEMENT

This Statement governs Your use of the HYS Services, including any dispute concerning privacy. By using the HYS Services, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site and the HYS Services. We reserve the right to modify this Statement at any time without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes.

2. WHAT INFORMATION IS COLLECTED & HOW?

This Statement governs Your use of the HYS Services, including any dispute concerning privacy. By using the HYS Services, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site and the HYS Services. We reserve the right to modify this Statement at any time without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes.

A. Personal Data (other than financial)
2.1
The Site asks You to provide various types of Personal Data to enhance the quality of the HYS Services We can provide to You and the more accurate the information You provide, the better We are able to respond to Your requirements! As part of the process of using the Site and the HYS Services, We may collect the following types of Personal Data about You (as applicable):
  • Your name, location, gender, social network logins, email, address and other miscellaneous information to verify You;
  • Your visits to the Site and the HYS Content that You download;
  • Your UGC that You may upload or submit to the Site;
  • information about Your computer (including Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Site navigation);
  • information relating to any transactions carried out between You and HYS on or in relation to the Site, including information relating to HYS Commissions earned; and,
  • any other information that You choose to send to us, including any request for further services, general correspondence, reports of a problem with the Site or the HYS Services.
B. Financial Data
2.2
Each monetary transaction in respect of HYS Commissions shall be processed by a third party payment processing partner e.g. PayPal (or any other third party that HYS may use from time to time). You will be required to provide the third party partner with financial data (i.e. Your banking details) in order to authorise payment to You. Your consent is given to HYS to provide Your Personal Data necessary to process Your payments to this third party directly. To make and complete a financial purchase or to receive a payment with e.g. PayPal via our Site, the policies of Paypal shall be applicable as between You and Paypal and can be found here.
2.3
Except as provided herein, We will not share Personal Data with any other third parties without Your prior consent.
C. Other Data
2.4
Other de-personalised data which does not record Personal Data as such, rather information such as the date of Your visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for HYS Members and to draw conclusions upon demographic information.

3. HOW IS THE INFORMATION USED?

3.1
You hereby expressly consent to Your Personal Data being passed on to third party companies or service providers (including HYS Retailers where applicable) for the sole purpose of fulfilling the HYS Services only (including making improvements to the HYS Services) and not for the purposes of those third parties making marketing communications to You, unless You have expressly consented to this being undertaken by a third party (“HYS Partners”). You are under no obligation to provide such Personal Data to us, however, if You choose not to, some of the HYS Services may not be available to You.
3.2
You acknowledge that Your Personal Data may be used by HYS to contact a HYS Member by post, phone or by electronic mail when necessary in connection with Your use of the Site and the HYS Services including Your participation in the HYS Program.
3.3
From time to time, HYS may contact You by electronic mail (or by telephone) by way of sending You various confirmations, notifications, feedback requests or any other newsletter or information or offers regarding upcoming HYS promotions, services or customer surveys pertaining to the HYS Program. If You change Your mind, You can opt out of receiving some but not all of this as some are required as a necessary part of the registration process and for continuing to receive access required by You to the interactive HYS Services. You can opt out of receiving direct marketing communications from HYS as descried below. You can opt out of receiving some of these communications by electing to amend and update Your notification preferences in Your HYS Member Account.
3.4
Your Personal Data is used solely by HYS (and HYS Partners to the extent necessary to fulfil the HYS obligations to You) for the sole purpose of enabling HYS to act as a service provider to You and is not shared with any person or company without Your express consent.
3.5
Any Personal Data that is held with HYS shall be retained in accordance with the Data Protection Act 1998 and related Data Protection Legislation and/ or our retention and destruction policy culminating in its permanent deletion.
3.6
If Personal Data has been passed to third parties with Your consent, You may need to contact them separately if You change Your mind in relation to their use of Your Personal Data.

OPTING OUT: You do not wish to be contacted by HYS in respect of future marketing communications, We will give You the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that We send to You. Alternatively and additionally, You can contact HYS by sending an email to feedback@haveyouseen.com with “URGENT – UNSUBSCRIBE REQUEST” in the subject line or send Your request by post to HYS at the contact address below.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

4.1
To minimise the risk of unauthorised access to Your Personal Data, We use some of Your Personal Data to authenticate You when using the Site and the HYS Services.
4.2
For our daily operations, We may use the services of third parties to provide some of our business and operational functions. Consequently, some of the HYS Services are provided by HYS Partners and We need to disclose Your information to them to provide You with the HYS Services. PayPal may further release Your Data as per the PayPal policies.
4.3
Disclosure of Your Personal Data in Compliance with Laws You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with or via HYS, or to protect the rights, property or safety of HYS, HYS Members or third parties. Further, PayPal may transfer Your Data as per the PayPal policies.
4.4
Transfer of Your Personal Data outside of the EEA From time to time, We may transfer Your Personal Data to a related company, agent or contractor in order to improve our HYS Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Personal Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.
4.5
Transfer of Personal Data in the Event of the Sale of HYS or its Assets In the event that HYS Limited is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of HYS.
4.6
Other Sites and their Privacy Policies and Cookie Policies The Site may contain links to other websites. HYS is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties (including those of PayPal), so You should be careful to read and understand those website policies independently.

5. HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?

5.1
The privacy and protection of Your Personal Data is important to us. In addition, any HYS Member statistics that We may provide to prospective HYS Partners regarding Your usage of the HYS Services are provided in the aggregate only and do not include any individually identifiable data.
5.2
You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any Personal Data You transmit to us, via, to, or from our Site. You accept that HYS cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential Personal Data which You do not wish to communicate by email, please contact HYS by telephone or post to arrange an alternative method of communication. You transmit all such Personal Data at Your own risk.
5.3
Once Your Personal Data is submitted, We use our best efforts to ensure its security on our systems. The Site (and the PayPal system) has security measures in place to protect the loss, misuse and alteration of the Personal Data under our control (and PayPal’s control) where applicable. 128 bit industry standard Secure Server Software (SSL) is used as a minimum standard which encrypts all of Your Personal Data in respect of a Your Payment Details including Your name, and address, so that it cannot be read as it travels over the Internet.
5.4
How long We keep Your Personal Data collected through our Site depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. We may send You direct marketing communications for as long as You do not unsubscribe from receiving the same from HYS.
5.5
Telephone calls: If You call any of the service telephone numbers quoted on this Site, We may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our service standards.

6. COOKIES

For information about cookies and how they are used on this Site, please visit our Cookie Policy.

7. COMPLAINTS OR QUERIES

HYS tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously. We encourage You to bring it to our attention if You think that our collection or use of Personal Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Statement does not provide exhaustive detail of all aspects of HYS’s collection and use of Personal Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below. If You have a complaint or query regarding a PayPal transaction, You can contact Paypal. If You are not happy with the way in which Your Personal Data is being handled by HYS, You can complain to the Information Commissioner whose details can be found at: http://www.ico.org.uk/

8. ACCESS TO YOUR PERSONAL DATA

HYS tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if We hold any Personal Data by making a ‘subject access request’ under the Data Protection Act 1998. If We do hold Personal Data about You, We will let You have a copy of that Personal Data. To make a request to HYS for any Personal Data that We may hold, You need to put the request in writing addressing it to the address provided below. They may be an administrative charge applied in accordance with the applicable legislation.

9. HOW TO CONTACT US

Requests for information about our Statement or a ‘subject access request’ can be emailed to feedback@haveyouseen.com or by writing to:

Haveyouseen Limited

The Town House

114-116 Fore Street

Hertford

England

SG14 1AJ

10. CHANGES TO THIS STATEMENT

We keep our Statement under regular review. This Statement was last updated on 18 June 2014.