Privacy Policy

Hartspring Consultants Ltd (“HCL”) Online Privacy Policy (Last updated November 14^th 2007)HCL has established this Privacy Policy to explain how it protects and manages the personal information that it collects from you (the customer) online.

1.	Consent for Collection, Use and Disclosure

Your use of the HCL site and/or your registration for HCL products and services constitute your consent to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the HCL site.

HCL may occasionally update this Privacy Policy. When it does, HCL will also revise the “last update” date at the top of this Privacy Policy. In addition, HCL will seek a customer’s prior consent, by email, for any new uses or proposed disclosures of information collected from the customer prior to the change. HCL will notify customers by email of changes to this policy that will affect information collected from them in the future. In certain circumstances, however, HCL will not inform and obtain the consent of the customer, such as in connection with an investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order.

A customer may withdraw his or her consent for collection, use and disclosure at any time by sending an email to unsubscribe@hartspring.com. Please note that, if you do, HCL may suspend its provision of products and services to you. When you unsubscribe, if you fall within the guarantee period for any HCL product and you request a refund, the guarantee will be honoured.

2.	Accountability

HCL collects, at the time of your registration and your sign-on to its web site, certain “personal information” (information that personally identifies you) including but not limited to your name, email address, home or work address, telephone number, and information about your computer hardware and software (e.g., IP address, operating system, browser type, domain name, URL, access times, and referring web site addresses).

HCL has implemented this Privacy Policy to protect personal information received from its customers, and to respond to any inquiries. The Privacy Policy also provides that HCL will use appropriate contractual means to establish a comparable level of protection for personal information which is sent for processing by third parties on HCL’s behalf.

HCL has designated responsibility for your personal information to the data manager, who ensures compliance with the principles in this Privacy Policy. Other HCL individuals may be delegated to act on behalf of the data manager.

3.	Purposes for Collecting Personal Information

HCL collects and uses personal information for the following Identified Purposes:

(a)	to understand customer needs regarding HCL’s services;

(b)	to develop and provide our web site and our products and services for our customers;

(d)	to communicate with customers and site visitors, when necessary, and to inform customers of upgrades, as well as of other products and services available from HCL, its affiliates and third parties;

(e)	to allow customers to access limited-entry areas of HCL’s site;

(f)	to personalize some of our services and products for you and to deliver targeted advertisements and offers from HCL and third parties;

(g)	to bill accounts and maintain payment records;

(h)	to comply with any applicable law, regulation, legal process or government request;

(i)	to respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the HCL site or any HCL product or service;

(j)	to protect the services, products or rights of HCL, including but not limited to the security or integrity of the HCL site; and

(k)	to identify and resolve technical problems concerning HCL’s site, products and services.

HCL also uses personal information in an aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes.

If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Identified Purposes, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us.

4.	Limiting the Collection of Personal Information

HCL limits its collection of personal information to only that information which is necessary for the Identified Purposes. HCL does not direct its site to, nor does it knowingly collect any personal information from children under the age of thirteen.

When you visit the HCL web site, a cookie may be placed on your computer or the cookie may be read if you have visited the HCL site previously. HCL uses cookies to allow HCL to determine which products and services you have already purchased so that HCL does not provide redundant information to you, and, if you are an HCL affiliate, to track HCL sales made to customers referred by you so that you can receive compensation under our affiliate program. If you choose to not have your browser accept cookies from the HCL web site, you may not be able to view all the text on the screens, or to experience a personalised visit, or to subscribe to certain service and product offerings on the HCL site.

5.	Disclosure, Processing and Retention

HCL does not sell, rent or disclose your personal information to anyone else, except:

(a)	to someone you have designated to act as your agent, for one or more of the Identified Purposes (listed in Section 2, above);

(b)	to HCL’s employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, acting on HCL’s behalf for any of the Identified Purposes;

(c)

as necessary if HCL has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with HCL’s rights or property, other users of HCL’s web site, products or services, or anyone else that could be harmed by such activities; and

(d)	to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.

In addition, as we continue to develop our business, we or our affiliates may sell or buy other businesses or entities, or we may merge with another company. In such transactions, personal information may be one of the transferred business assets. Also, in the event that HCL or substantially all of its assets are acquired, your personal information may be one of the transferred assets.

Your information may be stored and processed in the United Kingdom, or in any other country in which HCL or its affiliates, subsidiaries or agents maintain facilities. By using this web site, you consent to any such transfer of information outside of your country.

After your account becomes inactive (that is, if you request to be removed from our database), HCL will keep your personal information in its archives. Your information will then be used only as necessary for tax reasons or to prove HCL’s compliance with any applicable law.

6.	Accuracy of Personal Information

HCL will use reasonable efforts to keep customer personal information accurate for the Identified Purposes, and for minimizing the possibility of making inappropriate customer decisions based on such information. Customers are responsible for informing HCL about changes to their personal information. You can do this by calling +44 (0)845 094 2002 or clicking here. HCL will use new or updated personal information it receives from customers to update its own records.

7.	Security Safeguards

HCL will use reasonable efforts to protect customers’ personal information.

8.	Access to Personal Information

HCL will afford you a reasonable opportunity to review the personal information in your file, if you so request by calling +44 (0)845 094 2002, writing to:

Hartspring Consultants Ltd
180 Baldwins Lane,

Croxley Green,

Rickmansworth,

Hertfordshire

England
WD3 3LQ

... or upon request to the Data Manager at admin@hartspring.com

If HCL is not able to provide access to some aspect of a customer’s personal information, it will provide reasons for denying access such as; that by doing so would likely reveal personal information about a third party, or that it is confidential commercial information or attorney–client privileged communications, or that the information relates to a breach of an agreement or a contravention of law, or that its disclosure could reasonably be expected to threaten the life or security of another individual.

Customers have the right to request that inaccurate or incomplete information be amended as appropriate, by contacting HCL or the Privacy Officer as described above. HCL will promptly correct such personal information.

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