Nicholas Horsthuis

Privacy Policy

Last updated January 2024

This Policy is issued by N Horsthuis (together, “we”, “us” or “our”), identified as Controller(s) in the Glossary section below and is addressed to individuals outside our organisation with whom we interact, including visitors to our websites (our “Sites”) (together, “you”). Defined terms used in this Policy are explained in the Glossary section below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law or regulation. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

Consent

Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Data Subject

Any person whose personal data is being collected, held or processed.

Personal Data

Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Personal Data Breach

Breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Processor

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

Processing

Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Use of Cookies

What are Cookies

Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the website or a third-party to recognize you and make your next visit easier and the website more useful to you. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How this website uses Cookies

When you use and access our website, we may place a number of cookie files in your web browser.

We use cookies for the following purposes:

Essential Cookies:

We use these cookies to remember information that changes the way our website behaves or looks, such as a user's preferred language or the region in which they are located. Disabling these cookies will affect the functionality of the website and may prevent users from fully experiencing our website.

Performance and Analytics Cookies:

We use these cookies to understand how visitors interact with our website by collecting and reporting information anonymously. This data helps us understand and analyse how well the website performs and where it needs improvement.

Marketing Cookies

These are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser. However, be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will result in disabling all functionalities and features of our site. Therefore, it is recommended that you do not disable cookies.

Collecting Personal Data

Collection of Personal Data: We collect, use, store and process Personal Data about you; We ensure that it has a legal basis for processing the Personal Data of Data Subjects.

We collect Personal Data from a variety of sources as follows:

Where we directly request you to provide us with the information and you provide it to us either verbally or in writing (for example, where you contact us via email or telephone, or by any other means);
In the ordinary course of our relationship with you (for example, in the course of managing your transactions or during the on-boarding process);
From third parties who provide it to us (for example, your employer; our customers; credit reference agencies; and law enforcement and regulatory authorities);
From third parties, where you purchase any of our products or services through such third parties;
When you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

We create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law and regulation.

The categories of Personal Data about you that we may Process, subject to applicable law, are as follows:

Personal Details

given name(s); preferred name(s); nickname(s), gender; date of birth; age;

Contact Details

address; telephone number; email address; and social media profile details;

Electronic Identifying Data

IP addresses; cookies, activity logs, online identifiers, unique device identifiers, and geolocation data.

Purposes for which we may Process your Personal Data, subject to applicable law are:

Provision of Products and Services to you

administering relationships and related services; performance of tasks necessary for the provision of the requested services: communicating with you in relation to those services;

Marketing / Prospecting

communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law: and maintaining and updating your contact information where appropriate; Our main channel of communication is through email and we conduct marketing in adherence with the Privacy and Electronic Communications Regulation. This allows for business-to-business marketing on an opt-out basis in so long as a lawful means of processing has been established. Our lawful basis for processing in this instance is Legitimate Interests as well as the client’s Consent. We may also contact you by telephone from time to time to follow up on an interest you have expressed in a course or to verify contact information. If you wish to unsubscribe click on the unsubscribe link available on any email communication that has been sent to you or email, info@horsthuis.co.uk

Operation of our Site

operation and management of our Site; providing content to you: and other information to you: and communicating and interacting with you via our Sites;

IT Operations

management of our communications systems, operation of IT security/IT security audits;

Investigations:

detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;

Legal Compliance:

compliance with our legal and regulatory obligations under applicable law, including the recording of telephone lines where required;

Legal Proceedings

establishing, exercising and defending legal rights;

We lawfully process the Personal Data of Data Subjects for the aforementioned purposes as:

The Processing is necessary for:

Compliance with a legal obligation;
The detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law and regulation;
Establishment, exercise or defence of legal rights;
The purposes of the legitimate interests pursued by the controller except where such interests are overridden by the interests or fundamental rights and freedoms of the data subjects;

Processing your sensitive personal data may be necessary:

For reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.
In connection with any contract that you may enter into with us, or which we are required to take prior to entering into a contract with you; or
We have a legitimate interest in carrying out the processing for the purpose of improving our products or services (to the extent that such legitimate interest is not overridden by your interests or fundamental rights and freedoms).

Disclosure of Personal Data to Third Parties

We may disclose your Personal Data to other entities for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law.

In addition, we may disclose your Personal Data to:

You and where appropriate, your family, your associates and your representatives;
Anti-fraud services;
Governmental, legal, regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
Accountants, auditors, financial advisors, lawyers and other outside professional advisors to us, subject to binding contractual obligations of confidentiality;
Third Party Processors (such as payment services providers) located anywhere in the world, subject to the requirements noted below in the section entitled International Transfer of Personal Data;
Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
Any relevant third-party acquirer(s) if we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation);

International Transfer of Personal Data

Because of the international nature of our website, we may need to transfer your Personal Data to third parties, as noted in the section “Disclosure of personal data to Third Parties” above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located.

Where we transfer your Personal Data to other countries, in accordance with our regulatory requirements:

Adequacy decisions;
Suitable standard contractual clauses; and / or
Other valid transfer mechanisms.
If you would like further information regarding the safeguards applied to international transfers of Personal Data, please use the contact details provided below

Storage and Retention

Personal Data of Data Subjects is stored for a period necessary to meet the purpose for which it was collected. In addition, personal data of data subjects will be stored for a period necessary to meet legislative and regulatory requirements including retention time periods. Even when you cease to do business with us, we must retain some of your personal data in case of queries or claims.

Data Security

We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. We also take steps to ensure that only persons with appropriate authorisation can access your personal information.

You are responsible for ensuring that any Personal Data that you send to us is sent securely.

Data Subject Rights

Under the GDPR, you are afforded a number of rights with regards to your personal data. This includes the right to access, rectification, erasure, and restriction. In addition, you have the right to request for a transferable copy of certain data to be transferred to another entity and you may also withdraw your consent with respect to us processing your personal data, however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal.

Please refer to our Terms of Use for more information on the process to exercise your data subject rights and information regarding your right to make an internal or external complaint. If you have any concerns as to how your data is processed, please use the contact details provided below.

Controllers Covered by this policy

N. Horsthuis

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Contact Information

For any questions regarding the Privacy Policy please contact:

Data Controller

info@horsthuis.co.uk