BACKGROUND

The H.O.L Group understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our staff, customers, suppliers and other business contracts and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; and
“Our Site”	means any website bearing the HOL Group logo and owned by Us.

Information About us
1. HOL TRADING HOLDINGS LTD is a limited liability company registered in England & Wales under company number 12321064.
2. HANGERS OF LONDON LTD is a limited liability company registered in England & Wales under company number 03210572.
3. HOL GROUP (UK) LTD is a limited liability company registered in England & Wales under company number 10506625.
4. HOL SOURCING LIMITED is a limited liability company registered in England & Wales under company number 12311304.
5. HOL MANAGEMENT SERVICES LTD is a limited liability company registered in England & Wales under company number 11719392.
6. Registered Address: 103 Kings Cross Road, London, WC1X 9LP
What Does This Privacy Policy Cover?
This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What Is Personal Data?
1. Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
2. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
3. The personal data that we use is set out in clause 5, below.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in clause 11.
2. The right to access the personal data we hold about you. Clause 10 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in clause 11 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in clause 11 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in clause 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in clause 11.
What Personal Data Do You Collect and How?
1. Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see clause 14 for more information about Our use of Cookies and similar technologies Our Cookie Policy which may be found at the footer of each page of Our Site. We do not collect any “special category” or “sensitive” personal data or personal data relating to children or data relating to criminal convictions and/or offences.
2. The Company provides notice of the category and type of personal data that is collected, held, and processed by the Company (including the collection method or source of such personal data, and the nature and purpose of processing together with the retention periods / duration of the personal data) by posting such details at the following URL: https://hol- group.com/dpa-personal-data. Any changes will also be posted at this location.
How Do You Use My Personal Data?
1. Under the Data Protection Legislation, We must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, or because it is in Our legitimate business interests to use it. The nature and purpose for using each type of personal data can also be found at the following URL: https://hol- group.com/dpa-personal-data.
2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, or telephone, or text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
3. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in clause 11.
4. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
5. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The duration that we will keep your personal data can be found at the following URL: https://www.hol-group.com/dpa-personal-data.
How and Where Do You Store or Transfer My Personal Data?
1. We only store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
2. We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
3. We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
  1. we will transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission; and
  2. the transfer to a third country will be safeguarded by a legally binding contract with such external third parties that contain contractual clauses agreed and approved by the European Commission or are authorised by a competent supervisory authority for the transfer of personal data to third countries or such. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission; and
  3. where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
4. Please contact us using the details below in clause 11 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
5. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
  1. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  2. procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
Do You Share My Personal Data?
1. We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
2. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
3. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
4. If any of your personal data is shared with a third party, as described above, we will take
  steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in clause 8.
5. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in clause 8.
How Can I Control My Personal Data?
1. In addition to your rights under the Data Protection Legislation, set out in clause 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
1. You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
2. You may restrict our use of Cookies. For more information, see clause 14 and our Cookie Policy which can be found at the following URL: https://hol-group.com/cookie-policy.
How Can I Access My Personal Data?
1. If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
2. All subject access requests should be made in writing and sent to the email or postal addresses shown in clause 11.
3. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
4. We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do You Use Cookies?
1. Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We] have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
2. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for content control and display. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
3. All Cookies used by and on Our Site are used in accordance with current Cookie Law.
4. Before Cookies are placed on your computer or device, you will be shown a prompt at the bottom of the page requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
5. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
6. Our Site uses analytics services provided by Google and Bing. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
7. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
8. In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
9. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
10. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. For more information and further details on the first-party Cookies, third-party Cookies and analytics service(s) used by Our Site, see our Cookie Policy which can be found at the following URL: https://hol-group.com/cookie-policy.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Managing Director):

Email address: privacy@hol-group.com. Telephone number: +44 (0)20 8885 3055.

Postal Address: 103 Kings Cross Road, London, WC1X 9LP.
Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on Our Site.

This Privacy Policy will be reviewed annually and updated as necessary. The management team endorses this policy and is fully committed to its implementation.