Privacy policy

BackgroundThis  Privacy  Notice  sets  forth  how  Charter HCP  Limited  and  its  affiliates,  together  Controllers  (referred  to  collectively  as  “Charter, CHCP”  “we”,  “us”  or “our”), collect and process certain Personal Data.

 

“Personal  Data”  means  any  data  which  relates  to  a  living  individual  who  can  be  identified  from  that  data  or  from  that  data  and  other  information  which  is  in the  possession  of,  or  is  likely  to  come  into  the  possession  of,  Charter HCP  (or  its  representatives  or  service  providers).  In  addition  to  factual  information, it  includes  any  expression  of  opinion  about  an  individual  and  any  indication  of  the  intentions  of  Charter HCP  or  any  other  person  in  respect  of  an individual.

 

Charter HCP  is  responsible  for  ensuring  that  it  uses  Personal  Data  in  compliance  with  data  protection  laws.  We  respect  the  privacy  of  individuals  and  we are committed to keeping Personal Data secure.

 

This Privacy Notice applies to non-public personal information of individuals outside our organisation with whom we interact, including but not limited to:

 

•current, prospective and former investors and clients (collectively, “Investors”) and their personnel;

•visitors to our website;

•vendors and service providers; and

•visitors to our offices.

 

These  policies  may  be  changed  at  any  time.  Changes  will  be  effective  immediately  upon  posting  onto  our  Website  for  internet  users  or  provided  to  you  if visiting our offices.

 

Your information

 

This  Privacy  Notice  concerns  the  following  categories  of  information  that  we  collect  about  you  when  providing  our  products  and  services  (together,  the “services”) and includes information we receive through our Website.

 

Many  of  the  services  offered  by  Charter HCP  require  us  to  obtain  Personal  Data  about  you  in  order  to  perform  the  services  we  have  been  engaged  to provide.

 

Information  that  you  provide  to  us  will  depend  upon  the  nature  of  the  services  you  are  requesting  though  such  information  may  include  basic  Personal Data (such as full name; job title; company name; company email address; business phone number; business address; city; postcode; country).

 

Information  that  we  collect  or  generate  about  you  includes  a  file  with  your  client  records  and  contact  history  to  be  used  for  enquiry  purposes  so  that  we may ensure that you are satisfied with the services which we have provided to you; and details of site and marketing/communication preferences.

 

Information we may obtain from other sources includes:

Website

 

This  will  include  information  such  as:  number  of  people  visiting  our  Website;  pages  visited;  features  used;  how  long  they  stay  and  the  websites  they  are connecting  from;  collected  on  an  aggregate  basis  on  public  areas  of  our  Website,  or  on  an  individual  basis  on  areas  of  our  Website  that  require  Website visitors to logon using and access code (e.g. user ID and/or password).

 

Cookies

 

When you visit our Website, cookies are used to collect information about the services that you use, and how you use them.

 

Anonymised  data-In  addition  to  the  categories  of  Personal  Data  described  above,  we  may  also  process  further  anonymised  information  and  data  that  is  not processed by reference to a specific individual.

 

How we use your information

 

Your Personal Data may be stored and processed by us for the following purposes:

 

•to understand your needs and interests;

•for the management and administration of our business including to improve the calibre of online information and services offered;

•to assess your application for Charter HCP services, where applicable;

•to understand feedback on Charter HCP  services and to help provide more information on the use of the services quickly and easily;

•to communicate with you in order to provide you with services or information about Charter HCP or its services;•in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;

•for the administration and maintenance of databases storing Personal Data; or

•for  ongoing  review  and  improvement  of  the  information  provided  on  our  Website  to  ensure  it  is  user  friendly  and  to  prevent  any  potential disruptions or cyber-attacks.

 

However,  when  we  use  Personal  Data  we  make  sure  that  the  usage  complies  with  the  law.  The  law  allows  us  and  requires  us  to  use  Personal  Data  for  a variety of reasons, including but not limited to the following:

 

•in order to perform our contractual obligations;

•where we have obtained your consent to use the information;

•where we have legal and regulatory obligations that we have to discharge;

•where we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

•the use of your Personal Data as described is necessary for our legitimate business interests, such as:

 

- allowing us to effectively and efficiently manage and administer the operation of our business;

- maintaining compliance with internal policies and procedures;

- monitoring the use of our copyrighted materials;

- enabling quick and easy access to information on Charter HCP services; and,

- obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

 

We  will  take  steps  to  ensure  that  the  Personal  Data  is  accessed  only  by  our  employees  that  have  a  need  to  do  so  for  the  purposes  described  in  this  Privacy Notice.

 

Disclosure of your information to third parties

 

We  may  share  your  Personal  Data  within  Charter HCP  for  the  purposes  described  above.  We  may  also  share  your  Personal  Data  outside  of  Charter HCP for the following purposes:

 

•with  our  affiliated  companies  or  other  trusted  businesses  or  persons  for  the  purpose  of  processing  personal  data  on  our  behalf  for  the  above  stated purposes;

•with  our  business  partners.  Personal  Data  will  only  be  transferred  to  a  business  partner  who  is  contractually  obliged  to  comply  with  appropriate  data protection obligations and the relevant privacy and confidentiality legislation;

•with  third-party  agents  and  contractors  for  the  purposes  of  providing  services  to  us  (for  example,  our  accountants,  professional  advisors,  IT  and communications  providers).  These  third  parties  will  be  subject  to  appropriate  data  protection  obligations  and  they  will  only  use  your  Personal  Data as described in this Privacy Notice;

•to  the  extent  required  by  law,  for  example  if  we  are  under  a  duty  to  disclose  your  Personal  Data  in  order  to  comply  with  any  legal  obligation (including,  without  limitation,  in  order  to  comply  with  tax  reporting  requirements  and  disclosures  to  regulators),  or  to  establish,  exercise  or  defend  its legal rights; and

•if  we  sell  our  business  or  assets  or  are  acquired  by  a  third  party,  in  which  case  we  may  need  to  disclose  your  Personal  Data  to  the  prospective  buyer for due diligence purposes.

 

International transfers of personal data

 

Charter HCP is  a  global  business  with  customers  and  operations  spread  around  the  world.  As  a  result,  we  may  collect  and  transfer  Personal  Data  on  a global basis. That means that we may transfer your Personal Data to locations outside of your country.

 

Where  we  transfer  your  Personal  Data  to  a  country  outside  the  EEA,  we  will  ensure  that  it  is  protected  and  transferred  in  a  manner  consistent  with European legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

•the  country  might  be  approved  by  the  European  Commission  as  offering  an  adequate  level  of  protection  for  Personal  Data  (e.g.  Israel  is  an  approved country);

•the  recipient  might  have  signed  up  to  a  contract  based  on  “model  contractual  clauses”  approved  by  the  European  Commission,  obliging  them  to protect your Personal Data;

•where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or

•in other circumstances where the law may permit us to otherwise transfer your Personal Data outside Europe.

 

You  can  obtain  more  details  of  the  protection  given  to  your  Personal  Data  when  it  is  transferred  outside  Europe  (including  a  copy  of  the  standard  data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described below.

 

 

Security standards – how we safeguard your information

 

We  work  hard  to  ensure  that  our  systems  are  secure  and  that  they  meet  industry  standards.  Where  appropriate,  we  employ  firewalls,  encryption technology,  user  authentications  systems  (e.g.  passwords  and  personal  identification  numbers)  to  control  access  to  systems  and  data.  

 

We  will  continue  to assess new technology to evaluate its ability to provide additional protection for your Personal Data.

 

Access  to  our  computer  systems  is  controlled  and  restricted.  Physical  access  to  areas  where  Personal  Data  is  gathered,  processed  or  stored  is  limited  to authorised employees.

 

As  a  condition  of  employment,  Charter HCP  staff  are  required  to  follow  all  applicable  laws  and  regulations,  including  in  relation  to  data  protection  law. Unauthorised use or disclosure of confidential client information by a Charter HCP employee is prohibited and may result in disciplinary measures.

 

How long we keep your personal data

 

The length of time we will hold your Personal Data will vary and will depend on:

 

•the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and

•legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

 

Your rights

 

In  all  the  above  cases  in  which  we  collect,  use  or  store  your  Personal  Data,  you  may  have  the  following  rights  and,  in  most  cases,  you  can  exercise  them  free of charge.

 

These rights include:

•the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

•the  right  to  withdraw  your  consent  to  the  processing  of  your  Personal  Data  at  any  time.  Please  note,  however,  that  we  may  still  be  entitled  to  process your  Personal  Data  if  we  have  another  legitimate  reason  for  doing  so.  For  example,  we  may  need  to  retain  Personal  Data  to  comply  with  a  legal obligation;

•in  some  circumstances,  the  right  to  receive  some  Personal  Data  in  a  structured,  commonly  used  and  machine-readable  format  and/or  request  that we  transmit  that  data  to  a  third-party  where  this  is  technically  feasible.  Please  note  that  this  right  only  applies  to  Personal  Data  which  you  have provided directly to Charter HCP;

•the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

•the  right  to  request  that  we  erase  your  Personal  Data  in  certain  circumstances.  Please  note  that  there  may  be  circumstances  where  you  ask  us  to erase your Personal Data but we are legally entitled to retain it;

•the  right  to  object  to,  or  request  that  we  restrict,  our  processing  of  your  Personal  Data  in  certain  circumstances.  Again,  there  may  be  circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and

•the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

 

You can exercise your rights by contacting us using the details listed below

 

This privacy policy applies between you, the User of this Website and Charter HCP, the owner and provider of this Website. Charter HCP takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data

Collectively all information that you submit to Charter HCP via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

 

Data Protection Laws

Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

2. GDPR

The General Data Protection Regulation (EU) 2016/679;

Charter HCP,  we  or us

 Charter HCP, a company incorporated in England and Wales with registered number 10356432 whose registered office is at:

Charter HCP

11th Floor, CityPoint,

1 Ropemaker Street

London EC2Y 9HT,

United Kingdom

User or you

any third party that accesses the Website and is not either (i) employed by Charter HCP and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Charter HCP and accessing the Website in connection with the provision of such services; and

Website

the website that you are currently using, www.charterhcp.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:

  1. the singular includes the plural and vice versa;

  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

  3. a reference to a person includes firms, companies, government entities, trusts and partnerships;

  4. "including" is understood to mean "including without limitation";

  5. reference to any statutory provision includes any modification or amendment of it;

  6. the headings and sub-headings do not form part of this privacy policy.

 

 

Scope of this privacy policy

3. This privacy policy applies only to the actions of Charter HCP and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Charter HCP is the "data controller". This means that Charter HCP determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

  1. name;

  2. contact Information such as email addresses and telephone numbers;

in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

  1. data is given to us by you  ; and

  2. data is collected automatically.

Data that is given to us by you

7. Charter HCP will collect your Data in a number of ways, for example:

  1. when you contact us through the Website, by telephone, post, e-mail or through any other means;

  2. when you register with us and set up an account to receive our products/services;

  3. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);

  4. when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

  1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  1. internal record keeping;

  2. improvement of our products / services;

  3. transmission by email of marketing materials that may be of interest to you

in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:

  1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.

  2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

  3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

 

Who we share Data with

13. We may share your Data with the following groups of people for the following reasons:

  1. any of our group companies or affiliates - to ensure the proper administration of your website and business;

  2. our employees, agents and/or professional advisors - to obtain information from professional advisers;

in each case, in accordance with this privacy policy.

Keeping Data secure

14. We will use technical and organisational measures to safeguard your Data, for example:

  1. access to your account is controlled by a password and a user name that is unique to you.

  2. we store your Data on secure servers.

15. We are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

16. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: tom@charterhcp.com.

17. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

18. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

19. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

 

Your rights

20. You have the following rights in relation to your Data:

  1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

  2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

  3. Right to erase - the right to request that we delete or remove your Data from our systems.

  4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

  5. Right to data portability - the right to request that we move, copy or transfer your Data.

  6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

21. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: tom@charterhcp.com.

22. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

23. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

24. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

 

Changes of business ownership and control

25. Charter HCP may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Charter HCP. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

26. We may also disclose Data to a prospective purchaser of our business or any part of it.

27. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

General

28. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

29. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

30. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

31. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

32. Charter HCP reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.  
 
You may contact Charter HCP by email at tom@charterhcp.com.