This Privacy Policy applies to www.hypoworry.com operated by Hypoworry (“we”, “us”, “our”). In this Privacy Policy we explain what Personal Data we collect from our clients and from our website and other online users (hereinafter “you”), as well as information that we collect automatically during your visits to our website (e.g., information collected via cookies).

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU counterpart the General Data Protection Regulation (“GDPR”).

Legal basis for processing

Our legal basis for collecting and using your Personal Data as described in this Privacy Policy depends on the Personal Data involved and the specific context in which we collect it. Generally, your Personal Data will be collected and processed by us on one or more of the following legal bases:

• Your consent,
• Compliance with contractual obligations,
• Compliance with legal obligations, and
• On the basis of our legitimate interests.

If you have any questions or need more information about the legal basis for the collection of your Personal Data, please contact us at [email protected].

Information we collect

We may ask you for Personal Data when you

• Use our website and services,
• request, services, support, or information,
• book appointments,
• apply for a job with us,
• participate online or otherwise in marketing activities (such as our referral program),
• subscribe to marketing and promotional emails or other materials,
• interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties); or
• Contact us

Categories of Personal Data we collect may include both Personal Data and Special Category Data. “Personal Data” means any data, such as your name, telephone number, email address, IP (“Internet Protocol”) address or location data. Whereas, “Special category data”is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

Further, we may also collect demographic data, such as age, gender, your interests, and preferences. Lastly, we may also ask you for other information that we need to process payment for our services.

In order to provide you with a more consistent and personalised user experience in your interactions with Hypoworry, data collected through one source may also be linked to other data collected by Hypoworry through other sources. This may include data that helps us identify you when you access our website through several different devices.

Data Automatically Collected by Us

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

To provide our website, we use the services of Veridyen who processes all data to be processed in connection with the operation of this website and your email exchanges with Issy, on our behalf. The legal basis is our legitimate interest.

Data from third party sources

We may obtain data about you from third-party sources, such as marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

Our use of Personal Data

Hypoworry may use your Personal Data for the following purposes:

• Providing you with our services and support, and conducting transactions you request,
• Sending notifications to you, including information about the status of your transaction, including information about the services as well as order confirmations, about specific Counsellin programs in which you may wish to participate, about solutions and services available from Hypoworry,
• Enabling you to use our website,
• Providing support to respond to your online inquiries,
• Customise, analyse and optimise our solutions, services (including content to gauge usage trends and determine the effectiveness of our marketing campaigns), technologies, notifications and business relationships with you,
• Better understanding our clients and website users,
• Personalising content and implementing your preferences,
• Enforcing our terms and conditions, and separate contracts (if any) with you,
• Prevention of fraud and other prohibited or unlawful activities,
• Protecting the security and integrity of our websites, businesses, and services; and
• Other functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Retention of your data

We will retain your personal data as necessary in connection with the purposes described in this Privacy Policy, for as long as you are actively working with us, and in accordance with the UK`s Retention Periods, HMRC and other applicable laws for up to 6 years.

International transfers

Hypoworry may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your personal data may be transferred to countries outside the UK. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the personal data we transfer.

Sharing of personal data by us.

We may share your Personal Data with Hypoworry business partners for the purposes described in this Privacy Policy, including, without limitation, to carry out transactions you request or to respond more quickly to your needs in our operations. Our business partners may contact you with information about Hypoworry and Hypoworry services and offerings. We will only share your Personal Data with Hypoworry affiliates and business partners who have agreed to protect your Personal Data and to use it only for the purposes Hypoworry has specified.

With your consent, we may disclose your Personal Data for any purpose.

In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Hypoworry (or a part of Hypoworry) is sold to or merged with another company; or if Hypoworry has reason to believe that disclosure is necessary to protect Hypoworry, its clients or the public.

In all cases other than those described above, Personal Data will not be disclosed by us to third parties for their own marketing purposes without your consent.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us using [email protected].

Access Request and updating your Personal Data

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same using [email protected].

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

Your rights

Under the UK`s DPA and the GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to deletion
• Right to information
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the personal data we hold about you, or if you wish to request the erasure or rectification of personal data we hold about you, or to exercise any of your other rights as a data subject, please contact us.

How we protect your Personal Data

Hypoworry takes all reasonable steps to protect your Personal Data from misuse, alteration, and loss, and from unauthorised access, alteration, or disclosure. To this end, we use the following means, among others:

• Use of encryption when collecting and transmitting sensitive data such as credit card information, technical and organisational measures to ensure the continuous integrity, availability and fail-safety of processing systems and services,
• Restricting physical access to our sites,
• Restricting access to data we collect about you,
• Ensuring appropriate safeguards are in place at our facilities and those of our business partners to ensure the security of your personal data; and,
• where required by law, deleting or anonymizing Personal Data.

Collection and Use of Children’s Personal Information

Hypoworry takes the privacy of children very seriously. We do not knowingly collect Personal Data from children through our website.

Contact

If you have any questions, comments or concerns about this Policy or about exercising your privacy rights with respect to personal information as permitted by applicable law, please contact us.

Hypoworry LTD

284 Chase Road A Block Unit 221, 2nd Floor, London, United Kingdom, N14 6HF

Web: www.hypoworry.com

E-Mail: [email protected]

This Privacy Policy was last updated on Monday, 22 May, 2023