Last updated: 20 June, 2018
TH Europe Limited (registered number 08742627) a fully owned subsidiary of Technology Holdings Worldwide Inc , and trading as ‘Technology Holdings Worldwide’ (“us”, “our”, “we”) are committed to protecting and respecting your privacy.
This Policy covers our collection, processing and use of personal data when you use any of our Website.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.
By visiting or otherwise using our Website, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Websites know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.
Please note that our Website is not directed at children under the age of 13 (each a "Child" together "Children") and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child, you may contact us at email@example.com and request that we cease processing information about your Child.
What is personal data?
Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.
By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.
Data we collect from you when you use the Website
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you; use the Website to upload or send personal data (by contacting us to find out more about our services, filling out an enquiry form, subscribing to our e-mails or newsletter, or similar activities in which you volunteer data about yourself); contact us by post, telephone, email or SMS, we may collect, store and use the personal data that you disclose to us.
The information we collect from you may include your title, name, address, e-mail address, company, job title, birthday, phone number, financial and credit card information – but will depend on precisely what details you volunteer to us as you interact with the Website.
Automated Collection of Data
We may also collect information about you when you visit the Website through the use of technologies such as cookies. The following are examples of information we may collect:
We use the data described above for several different reasons. Firstly we use it to ensure that the Websites work properly and that you are able to receive the full benefit of them. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.
Third Party Resources
We also use the services of third parties to help us to collect various data about you and the way that you use the Website in order to enable us to better understand your interests – both so that we can service content to you that we think will be of interest to you, and so that we can ensure that you are shown adverts delivered by third parties which are more likely to be of interest to you.
For details of the cookies that we use on the Website, what those cookies do, and the privacy policies of the third parties which provide them (where relevant) please see our Cookies Policy.
Please note that, while you have to option to consent to specific individual cookies that, unless specifically set out in our Cookies Policy, we rely on our legitimate interests as our condition for processing your personal data on the basis set out in this section (specifically that we have a legitimate interest in optimising the Websites’ content and ensuring that you are served with relevant commercial communications as you use them).
Where we provide services to you (or where you are employed by an organisation to which we provide services) we will use your personal data for the purpose of providing those services. This may include providing your details to other parties to M&A transactions in which you are materially involved, for more information on which please see below.
Sharing your information
Depending on how and why you provide us with your personal data we may share it in the following ways:
We will not share your information with third parties in order for that third party to provide direct marketing communications to you unless you have provided your consent for that use.
We may also disclose your personal information to third parties in the following events:
We send you e-mail marketing messages if we identify you as an individual who may be interested in our services (either as the buyer or seller of a business). We send e-mail marketing messages only to individuals who we have identified as active and influential in industry sectors in which are active, and we send those messages on the basis that they are likely to be relevant to the kind of individuals who we identify.
We only send these e-mails where we are lawfully entitled to rely on the legitimate interest described above as our reason for doing so and all e-mails contain functionality allowing recipients to unsubscribe from future mailings.
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.
As noted above, we use providers of ‘cloud’ storage solutions to assist us in storing and archiving our documents. Accordingly, where we receive your details as part of providing services to you, or where we hold details of your contact details to enable us to send you e-mail marketing communications, we will transfer your personal data to those providers for storage.
Links to third party sites
Where we provide links to third party websites that are not affiliated with Technology Holdings Worldwide such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
We will hold your personal information on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive e-mail marketing from us we will retain your e-mail address on file should you ever ‘opt-out’ of receiving e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Technology Holdings Worldwide may store your personal data on secure servers either on our premises or in secure third party data centres.
Please note that some of our service providers (and members of our company group) may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing.
Where we transfer your data outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. For the majority of our cloud storage providers we rely on their ‘binding corporate rules’ to ensure the security of the transfer. For transfers within our company group we rely on the EU’s standard contract clauses. If you would like more information about how the mechanism via which your personal data is transferred, please contact firstname.lastname@example.org.
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Website or any part of our IT infrastructure (such as a shared drive or data-room) you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
In particular Technology Holdings Worldwide may process your data on the basis of a legitimate interest where we send you e-mail marketing messages. We send these kind of messages to individuals who we have identified as active and influential in industry sectors in which are active, and we send those messages on the basis that they are likely to be relevant to the kind of individuals who we identify as potential clients and/or investors.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at email@example.com and telling us which communications you would like us to stop sending you.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at firstname.lastname@example.org.