Privacy Policy

Welcome To Our Privacy Policy

This privacy notice tells you about the information we collect from you when you use our website. It was recently reviewed in accordance with the with the EU General Data Protection Regulation (GDPR) which will come into effect on the 25th May 2018.

When you use our services, you’re trusting us with your personal information. This Privacy Policy will help you understand:

  • what data we’re collecting
  • how we collect it
  • why we need it
  • what we do with it

Your privacy is of the utmost importance to us. We respect the right to privacy of all users and are fully committed to protecting that right.

This is important so we’d advise you to read this Privacy Policy carefully alongside our Terms and Conditions.

Holly and Hugo (owned by Dahlgren Limited) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

 

Table of Contents


What information are we collecting about you?

When users visit and interact with our site, we collect both personal data and non-personal data.

Personal data is typically recorded when users apply for a course or purchase a product. More detailed personal information may be recorded through participation by users in surveys, promotions, offers, queries and requests for information.

Non-personal data is information that is not connected with identity, and routinely gathered through the tracking of statistics and analysis of the traffic to our site and interest shown while visiting our site. Like most companies, we also use cookies to hold data about you which helps your experience as you use the website. You can read more in our cookies policy here.

First of all we’re collecting personal data which is information that identifies you as an individual. This can include all or some of the following, such as:

  • First name
  • Last name
  • Email address
  • Profile picture
  • Country of residence
  • Gender
  • Age group

When you take part in one of our promotions, competitions, draws, sign up for a webinar, event or get downloadable free materials related to our courses, we ask for:

  • First name
  • Email address

When you sign up for a course for the first time, we ask for details such as:

  • First Name
  • Last Name
  • Email address
  • Country
  • Age Group

If you sign up with Facebook then we can access your:

  • First name
  • Last name
  • Gender
  • Age
  • Email
  • Profile picture

 We may collect your phone number if you signed up to Facebook with your phone as well as other public information (please revert to Facebook to understand what the other public information may be).

If you sign up with Google+ we have access to your:

  • First name
  • Last name
  • Email
  • Profile picture

When you complete a course and request any hard copy documents:

  • Full address

How do we collect this information?

There are various ways we can get this information:

  • Communication Data: This includes any information you send to us, such as through the contact form on our website, email, text, social media messaging, social media posting or any other communication that you send us. We use this information so we can communicate with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data: This includes data relating to any purchases of courses or related services. This information could be your name, title, email address, and purchase details. We process this data to supply the courses, course material and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. Once you have completed the course, we may need your billing address or delivery address to send your certificates to you. We do not keep your bank card details as this is collected by a secure payment gateway, either Paypal or Stripe.
  • User Data: This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data: This includes data about your use of our website and online services such as your IP address, your username, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business, and to grow our business and to decide our marketing strategy.
  • Marketing Data: This includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to take part in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • Cookies: We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookies policy for more details about this.
  • Third Parties: We may receive data from third parties such as search information providers and analytics providers like Google based outside the EU, social media campaigns like Facebook based outside the EU, or providers of technical, payment and delivery services, like data brokers or aggregators. For example, if you elect to connect your social media account to your website account, certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile or your friends’ profiles.

Why do we want this information?

Any information collected by us is used for the sole purpose of delivering and improving our services, products, and overall student experience. It helps us to tailor our service to suit you.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver courses or other services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@hollyandhugo.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.


How do we use your personal information?

We use this data so we can send you useful information, such as:

  • to complete your purchase by being able to process your payments, have your course or other purchase delivered to you, get in touch with you regarding your purchase and to provide you with related customer service
  • if you are studying or have taken one of our online courses, we can send you details of our other products and services which we think will interest you
  • to manage your account that you hold with us
  • to allow you to use the full range of features on our website including access to your Virtual Campus
  • to send you emails with updates and announcements concerning our courses, promotions and any other news to keep you informed about our services
  • to get back in touch with you if we have not heard from you in a while
  • to send you advertising/promotional material from any of our affiliates, and from our partners
  • to personalize your experience by presenting products and offers tailored to your individual needs
  • to allow you to take part in competitions or other promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so it is important that you read the additional rules carefully
  • to answer any of your questions, comments or requests such as sending you newsletters when you sign up for our emails
  • to keep you up-to-date on any information regarding our services and changes to our terms, conditions, and policies
  • to permit you to post comments and share information on our social media pages and blogs. Don’t forget that any information you disclose through social media is public information and so will be available to other visitors to our pages. Take care what personal information you want to share which is visible to the wider world
  • so that you can take part in social sharing, including live social media feeds
  • to help us provide a better service for you by analyzing our customers and their needs. We’ll use your data for our business purposes so we can develop new courses and related products, enhance our websites, improve our services, identify user trends, see how successful our promotions are, review customer satisfaction and provide the best customer service possible
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain
  • we may ask for your feedback in surveys or testimonials to help us provide an even better service for you and for other students to know what people think of our courses. Your name, country, picture and the content of your review (but not your email address or IP address) may be publicly displayed on our website. We will do this based on our legitimate interest in marketing our products and services. You may ask us to remove your review at any time

Do you need to take action to receive information from us?

If you are based in EU, you will be asked to give us permission to receive our marketing emails:

  • Yes please, I'd love to get emails with offers, site updates, company news and new products (inc. freebies)
  • No thanks, I don't want to know about offers, site updates, company news and new products (inc. freebies)

If you are not based in EU you will be receiving our emails with offers, site updates, company news and new products with the option to opt out at any time.

You can withdraw your consent at any time and we will stop sending you the information. You can withdraw the consent by:

  • Unsubscribing from the emails (link at the bottom of each email)
  • Removing the consent in edit account details inside your student Virtual Campus

However, you will still be able to receive the following emails or other similar emails even if you haven’t given your consent. This is because we believe it is in your legitimate interest as a student of Holly and Hugo:

  • confirmation email when you register successfully with information on how to access your account
  • when you make a purchase, you’ll receive an email confirming the sale
  • if you’ve forgotten your password, we’ll send an email allowing you to reset it
  • if we don’t receive a subscription payment, we’ll send an email so you can check if there’s a problem with the card
  • notifications if we have to suspend your account if a payment is not received so you can take action
  • alerts that your course is about to expire so you can extend it or complete it before the deadline
  • confirmation email that your ICOES certificate that you ordered is ready to be delivered
  • Documents, handouts, e-books, free videos, etc related to your course

If you want to withdraw, even from the emails described above as legitimate consent, you can do so by contacting our customer support team. However, you would still receive the following emails:

  • Password reset
  • Purchase confirmation

Is the information safe?

We recognise the importance of your security when using our site. We take every prudent step to protect all information you divulge when making a payment to us. We do not collect or store any payment details i.e. credit or debit card details. All payment transactions are securely done through Paypal or Stripe, independent payment gateways.

We keep all your personal data confidential - only employees who need to access your account for the purpose of delivering our service to you, have access to them. We do not sell or pass your personal data to any third parties unless we receive specific consent from you to do this (e.g. when you are requesting a hard copy certificate to be posted to you from ICOES, we will ask you for your permission to pass your postal address, name and email address to ICOES).

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach in accordance with the rules set in GDPR (General Data Protection Regulation).

We stored all information on our secure servers. When you register, we will ask you to choose a password which enables you to access the online courses and content. You are responsible for keeping this password confidential. We ask you not to share this password with anyone.


Will the data be shared with 3rd parties?

We do not share your personal data with any third party for their marketing purposes. If we partner with a third party whose offer may be of interest to you, we will contact you and ask for your specific consent to communicate further on that partnership.

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services
  • Service providers who provide marketing, sales and analytics support
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets

This website may include links to third-party websites, social media networks, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We keep all your personal data confidential - only employees who need to access your account for the purpose of delivering our service to you, have access to them. We do not sell or pass your personal data to any third parties unless we receive specific consent from you to do this (e.g. when you are requesting a hard copy certificate to be posted to you from ICOES, we will ask you for your permission to pass your postal address, name and email address to ICOES).

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.


How long will we store your personal data?

We will retain your personal data for as long as you have a student account with us. We do not close your account to allow you to access your certificate and/or course materials.

We are also obliged to keep some of your personal data for the purposes of satisfying any legal, tax, accounting, or reporting requirements.

In some circumstances we may use your personal data anonymously for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


What rights do you have concerning your personal information?

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@hollyandhugo.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You can edit your personal details via your profile page whenever you wish.


If the information isn’t accurate, how can you change it?

It is very important that the information we hold about you is accurate and up-to-date. If your personal information changes, you can login to the website and edit your profile or email us at info@hollyandhugo.com


How can you get taken off the mailing list?

You can ask us to stop sending you marketing messages at any time by logging into the website and updating your preferences under your account details OR by following the unsubscribe link on any marketing messages sent to you OR by emailing us at info@hollyandhugo.com at any time.


How can you raise a complaint?

If you have any queries or are unsure about any aspect of how we collect and use your data, we’re happy to help you. Please get in touch with us at info@hollyandhugo.com so we can resolve any issues you have. You have the right to complain to your local supervisory authority but please contact us first so we can resolve the matter quickly and satisfactorily.


Use of cookies

When you use our website to browse our products and services and view the information we make available, a number of cookies are used to allow the website to function, to collect useful information about visitors and to help make your user experience better.

For more information about the cookies we use, please read our Cookies Policy.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly


Contact Details

If you would like any additional information about brand name privacy or security policies, email info@hollyandhugo.com

How to contact Holly and Hugo:

  • IRL +35319038692
  • UK - +442038089357
  • US - +13473322851
  • AU - +61283107668
  • CAN - +17783818514

(Monday to Friday from 9am - 8pm GMT)

Email: info@hollyandhugo.com


How will I know if you change this policy?

We update our Privacy Policy from time to time. If we make any material changes, we’ll let you know by email or post a notification on our website. The revised policy will supersede all previous policies. For that reason, we encourage you to review our Privacy Policy regularly. We will update the date of this document each time it is changed.

This Privacy Policy was last updated on 17th May 2018