Holman Fenwick Willan LLP (“HFW”)
Upskill Online Limited trading as Olive Media (“Olive”)
Enrolment Site (https://hfw.connectedrms.com), HFW Client Academy Site (https://hfwclients.academyhq.com) and HFW Academy Site (https://hfw.academyhq.com) (each a "Site", together "the Sites")
Online training courses accessed through the Sites (each, a “Course”)
Privacy Policy
1. The Sites
You may enrol for a Course on the Enrolment Site and then access and complete a Course on the HFW Academy Site or the HFW Client Academy Site.
The Sites are owned by Olive and operated by Olive on behalf of HFW (together referred to as "we", "our" or "us").
We care about your privacy. This Policy, which applies to the Sites, (together with our Website Terms of Use and any other documents referred to in the Sites) explains how we collect and use your information. Please read it carefully.
For questions about this Policy, or if you want to enforce your rights:
(a) if your question or request relates principally to the Enrolment Site, please contact HFW's Privacy Officer, Justin Glenister, at justin.glenister@hfw.com or +44 (0)207 264 8223;
(b) if your question or request relates principally to the taking of a Course on the Academy Site, please contact Olive’s Privacy Officer, John King, at jking@olivemedia.co or +353 87 8298186;
(c) if your question or request relates to the Academy Site but is not related to taking a Course, please contact HFW's Privacy Officer, Justin Glenister, at justin.glenister@hfw.com or +44 (0)207 264 8223.
Menu (make titles collapsible and expandable)2. Who we are
HFW is a limited liability partnership registered in England and Wales (with registered number OC343361) and is authorised and regulated by the Solicitors Regulation Authority. The firm’s registration number is 509977. HFW's registered office is Friary Court, 65 Crutched Friars, London EC3N 2AE. HFW is registered with the UK Information Commissioner's Office, with registration number Z1842662.
Olive is a limited company incorporated in Ireland with company number 470792, whose registered office is at Unit 5, Red Cow Business Park, Clondalkin, Dublin, D22 HC81. Olive is registered as a data controller with the UK Information Commissioner's Office, with registration number ZA313568.
For the purpose of applicable data protection laws:
(a) HFW is the data controller of your Personal Information collected through the Enrolment Website.
(b) Olive and HFW are joint data controllers of your Personal Information collected through the HFW Client Academy Website and the HFW Academy Website.
“Personal Information” in this Policy means "Personal Data" as defined in the EU General Data Protection Regulation 2016/679(EU). In summary, it means information that identifies you, whether directly or indirectly, including for example your name, gender, address, email address, phone number and any other information that you may voluntarily submit to us, as well as any online identifiers such as your clickstream data or IP address.
3. When do we collect information about you?
We collect Personal Information when you visit a Site, when you enrol for a Course and register for HFW Client Academy login details or for HFW Academy login details, when you email, call or write to us, or provide us with information in any other way, including by interacting with us via social media such as Facebook or Twitter.
We also collect information when you take a Course or otherwise use our apps, or if your company has provided your details to us to enable us to provide you with access to and use of our courses or apps.
4. What types of personal information do we collect and process?
Each time you visit a Site we may automatically gather the following information:
(a) technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; and
(b) information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), what web pages you visited on the Site and how long you spend on each page, page interaction information (such as scrolling, clicks and mouse-overs), page response times, download errors, traffic data, location data, weblogs, history of resources accessed on the Site, methods used to browse away from the page and information on what websites you visited before accessing the Site.
We also process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course:
(c) Information about you, including your name, job title, address, email and other contact details;
(d) Information about the company you are associated with;
(e) Information about your use of our mobile applications, including information about which pages you view;
(f) Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate your entitlement to a certificate;
(g) Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide.
5. Why do we collect and use your information, and what are our lawful grounds for doing so?
We use your Personal Information for the following purposes:
(a) To process and respond to requests, enquiries and complaints received by you, in accordance with our legitimate interest to provide you with a responsive service.
(b) To track your progress through a Course, to assess your performance in assessments and to determine whether you have reached the standard which is required if you are to earn a certificate.
(c) To provide services and products requested by you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.
(d) To communicate with you about services and/or products provided to you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.
(e) To update our records and for audit purposes, in accordance with our legitimate interest to operate a business which offers training courses.
(f) To prevent or detect fraud, in accordance with our legitimate interest to do so.
(g) Where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities.
(h) To analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
(i) To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
(j) If you make enquiries through a Site and agree in the contact form to receiving email updates we will send you such updates on the grounds of your consent.
(k) To enable third parties to carry out any of the purposes set out above on our behalf. For this we use our legitimate interest to run our business as efficiently as possible.
6. Where we store your Personal Information
The Personal Information we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) as it may be processed by staff or service providers outside the EEA who work for us.
We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy, and that adequate measures are in place if the country in question is not deemed to provide the same level of protection for your data and rights as you would enjoy within the EEA.
For a list of HFW's offices outside of the EEA please see HFW's website here: http://www.hfw.com/Our-Offices-and-Global-Work.
Personal data may on occasion be accessed by Olive's service providers located in India and Nepal. Contracts are in place with these service providers, incorporating the European Commission's approved model clauses, to ensure that any personal data involved is safe.
7. Disclosure of your Personal Information
We may disclose your Personal Information to companies within our corporate group. We will not share Personal Information collected through a Site with unrelated third parties, except as provided in this Policy.
We may disclose to your employer details concerning your progress in taking the Course, up to and including the award of a certificate.
We may share Personal Information with companies that we contract with to perform services for us, such as assisting us with administering or troubleshooting a Site, assisting us with the design of our courses, assisting us with our mailing campaigns, providing us with electronic or physical storage services, or other relevant data processing activities. We will only share your information in these circumstances if it is necessary to do so in order for our service providers to perform the service for us. These companies are not authorised to keep or use your Personal Information for any other purpose.
We may disclose your Personal Information to selected third parties such as law enforcement agencies or our professional advisors if we are under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use or other related contracts with you or your company.
If we sell all or any part of our business, the parties which buy it may have access to your Personal Information.
8. How long do we keep your information?
We hold your Personal Information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. Personal Information collected through a Site may be kept as follows:
. We employ the services of Google Analytics and Hotjar (the Analytics Companies). Further information concerning the nature of the services which they provide to us is set out in our Cookie Policy here: (Cookie Policy). The Analytics Companies keep anonymised information concerning your visits to the Sites on their servers, in accordance with their respective privacy policies here: https://www.google.com/intl/en/policies/privacy/ and https://www.hotjar.com/privacy
. We will keep your information for at least as long as our relationship with you is active, and for any further period as required by our retention policy.
If you would like more detailed information about our retention policy, please email us at justin.glenister@hfw.com, or jking@olivemedia,co or use one of the other methods in the "Contact us" section below.
9. Security
We aim to ensure that your Personal Information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, technical and organisational measures to safeguard and secure the Personal Information we collect. Our service providers are required to do the same.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information once we receive it, we cannot guarantee the security of your data transmitted to a Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access.
10. Cookies
Each Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse a Site and also allows us to improve the Sites. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy [Cookie Policy].
11. Links to other websites
A Site may contain links to the websites of other companies and organisations which may be of interest (“Third Party Sites”).
Once you have used these links to leave the Site in question, we do not have any control over how other companies use your Personal Information collected through such Third Party Sites. We cannot therefore be responsible or liable for the protection and privacy of any Personal Information which you provide whilst visiting them.
Third Party Sites are governed by their own privacy policies. Please be careful when accessing Third Party Sites and make sure that you check the applicable privacy policies.
12. Controlling your Personal Information
You have the right to ask us not to process your Personal Information for marketing purposes.
You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your Personal Information, by clicking "unsubscribe" in any of our marketing emails to you, or by contacting our Privacy Officer at any time at: justin.glenister@hfw.com.
We will not sell to third parties your Personal Information collected through a Site.
13. Access to your Personal Information, deletion, restriction, rectification and transfer
You have the right to request details (and a copy of) the Personal Information we hold about you and to ask us to delete, restrict (stop using), correct (rectify) or transfer (port) your Personal Information. Our response to your requests may depend on which legal grounds we are using to process the data in question (see section above). For more information about your rights under the General Data Protection Regulation please see the UK Information Commissioner's Office guidance here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You can exercise your rights by sending us a written request using our contact form, or by contacting our Privacy Officer, Justin Glenister: by email at justin.glenister@hfw.com; by telephone at +44 (0)207 264 8223; or by post at HFW, Friary Court, 65 Crutched Friars, London EC3N 2AE, United Kingdom.
With each request please include identification information (a copy of your passport or driving licence and a recent utility bill). Please be as specific as possible in your request about your requirements, so that we can respond to you as quickly as possible.
14. Complaints to the ICO
If you are unhappy with us, our service, or with the way that we treat your Personal Information please contact us. You also have the right to contact the UK data protection authority, the Information Commissioner's Office (ICO), or your local data protection authority if you are not based in the UK.
You can contact the ICO through its website at https://ico.org.uk/global/contact-us/, or on its helpline on 0303 123 1113 (if calling from the UK) or +44 1625 545 745 (if calling from outside of the UK).
15. Changes to this privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate and feasible, notified to you by email.
Please check back frequently to see any updates or changes to our Privacy Policy.
16. Contact us
If you have any questions or comments about this Policy, or if you wish to exercise your rights, please contact HFW’s Privacy Officer:
| By email: | justin.glenister@hfw.com |
| By telephone: | +44 (0)207 264 8223 |
| By post: | Justin Glenister, HFW, Friary Court, 65 Crutched Friars, London EC3N 2AE, United Kingdom |
Or you may contact Olive’s Privacy Officer for queries or requests relating to taking a Course:
| By email: | jking@olivemedia.co |
| By telephone: | +353 (0) 87 829 8186 |
| By post: | John King, Upskill Online Limited, Unit 5, Red Cow Business Park, Clondalkin, Dublin, D22 HC81 |