Privacy Policy
YOUR RIGHTS
Heritage Portfolio Limited is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:
Right of access and rectification
You can request access to your personal data. You may also request rectification of inaccurate personal data, or to have incomplete personal
data completed. You can request any available information as to the source of the personal data and you may also request a copy of your personal data being processed by Heritage Portfolio Limited.
Right to be forgotten
- Your right to be forgotten entitles you to request the erasure of your personal data in cases where:
- the data is no longer necessary
- you choose to withdraw your consent
- you object to the processing of your personal data by automated means using technical specifications
- your personal data has been unlawfully processed
- there is a legal obligation to erase your personal data
- erasure is required to ensure compliance with applicable laws
Right to restriction of processing
You may request that processing of your personal data be restricted in the cases where:
- you contest the accuracy of the personal data
- Heritage Portfolio Limited no longer needs the personal data, for the purposes of the processing
- you have objected to processing for legitimate reasons
Right to data portability
You can request, where applicable, the portability of your personal data
- that you have provided to Heritage Portfolio Limited, in a structured, commonly used, and machine-readable format and you have the right to transmit this data to another Controller without hindrance from Heritage Portfolio Limited where:
the processing of your personal data is based on consent or on a contract: - and the processing is carried out by automated means.
You can also request that your personal data be transmitted to a third party of your choice (where technically feasible).
Right to object to processing including direct marketing
- You can object to us using your Personal Data for direct marketing.
- You can also contact us to object to how we are using your Personal Data for any other reason, but we may not have to stop using it for this purpose.
Right to Withdraw Consent
If We process your personal data since your consent, you can withdraw your consent at any time.
Right not to be subject to automated decisions
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal affect upon you or significantly affects you. You have the right to object to processing including direct marketing which uses profiling.
Right to lodge a complaint
Within the EU, You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages.
You have also the right to lodge your Complaint before the courts where the Heritage Portfolio Limited entity has an establishment or where you have your habitual residence. In the UK you have the right to lodge a complaint with the Information Commissioner or lodge a Complaint before the courts.
You can use this form to make a request. This electronic system allows you to log in and see the progress of your request, see and send messages and review your documents securely. This system is called One Trust and after making the request you will be sent details about how to log on.
Alternatively, you can also send your request by email to DSAR.UKandIE@sodexo.com, in writing to 310 Broadway, Salford, M50 2UE or by calling Sodexo People Centre on 0845 603 3644 and asking for DSAR team. The team will liaise with you about how you to contact you about your request and receive information. Please note that it is usually necessary to arrange a telephone appointment to discuss your request once it has been made. You can also contact the DPO at this address or by email to DataProtection.UKandIE@sodexo.com.
If you wish to unsubscribe to marketing emails communications, you can also do so by using the unsubscribe function on the email.
LINKS AND SOCIAL
Links to other websites should not be considered as navigation tracking and we decline any responsibility concerning the Personal data protection practices implemented by these third-party companies, each of which acts as a separate Controller of your Personal data on their own perimeter. Once you leave our Site or click on the logo/link to one of these social networks, it is your responsibility to check the privacy policy applicable to that other platform.
When you click on social media icons, we may have access to the Personal data that you have made public and accessible via your profiles on the social networks in question. If you do not want us to have access to your Personal data published in the public spaces of your profile or your social accounts, then you should use the procedures provided by the social networks in question to limit access to this information.
CHANGES TO OUR PRIVACY POLICY
Any changes We may make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by e-mail.
Annex 1:
INFORMATION ABOUT THE PROCESSING OF YOUR PERSONAL DATA
Obtnaided from | Purpose of the Processing | Personal data collected | Legal basis of the Processing | Retention of the Personal data |
|---|---|---|---|---|
Website and application management | ||||
For more information on the processing of your Personal data in the specific context of Cookies we invite you to consult our Cookie Policy. | ||||
Account creation and Management Directly (from webforms/calls /emails.) or from a provider/previous provider of the service. | Send an initial communication via email to invite you to register and use our Sites and Services | Identity data | In order to take steps | If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and Services, and you are still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated. |
Register you as a user and create an account for you on our Site | Identity data Contact data Financial data Transaction data Technical data | Performance of a contract to which the data subject is party Legitimate Interest Legal Obligation | We will keep your Personal data in your customer account (s) until you delete your account or as necessary for legal accounting obligations or legal limitation period. | |
Customer and Client Relationship Management | Manage and monitor our relationships with existing and potential customers and clients. Carry out the service provided by us or a client of ours/previous provider- steps to enter contract or perform/fulfil the contract. | Contact data Identity data Transaction data | Contract and legitimate interest | We will keep your Personal data for the duration of our commercial relationship, after which only the data necessary for pre-litigation or litigation purposes will be archived until the legal prescription is acquired. The usual limitation period in civil and commercial matters is six (6) years. In the event of a dispute, this data is kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies. |
Contract Performance | Respond to your requests for information, searches, newsletter, and other content. | Identity data Contact data Transaction data Technical data Profile data Usage data Marketing data | Legitimate interest and consent | We will send you our newsletter until you unsubscribe. |
Access whether you are eligible for certain products and Services | Contact data Identity data Technical data Usage data Profile data | Contract Legitimate interest | We will keep your Personal data for the period necessary to carry out those checks. | |
Process and deliver your order | Identity data Contact data Financial data Transaction data Technical data Profile data Usage data | Contract Legitimate interest | We will keep your Personal data for the duration of our commercial relationship, after which only the data necessary for pre-litigation or litigation purposes will be archived until the legal prescription is acquired. The usual limitation period in civil and commercial matters is six (6) years. In the event of a dispute, this data is kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies. | |
Comply with legal obligations | Identity data Contact data Financial data Transaction data Technical data Profile data Usage data Marketing data | Legal obligations | We will keep your Personal data for the duration of the procedure, plus the period of acquisition of legal requirements. The usual limitation period in civil and commercial matters is six (6) years from the end of the contract. | |
Marketing Mangament | Conduct surveys and gather statistics | Identity data | Legitimate interest | We will keep your data for a period of three (3) years from the last contact you initiated. |
Manage, organize and improve of the competitions and related promotional operations | Identity data | Consent Legal obligations Legitimate interest | We will keep your data for a period of three (3) years after the end of the competition or the last contact you initiated. | |
Send commercial communications about products and services that may be of interest to you | Identity data | Consent Legitimate Interest | We will keep your data for a period of three (3) years after the end of the competition or the last contact you initiated. | |
Profile your Personal data to use internally to help us understand your motivations, values, and needs. | Identity data Contact data Financial data Transaction data Technical data Profile data Usage data Marketing data | Consent Legitimate interest | If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and services, and still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated. | |
Running | Running and improving our business, business development, recovering payments, keeping accounting records, security, health and safety, fraud prevention customer service, statistical analysis and marketing including segmenting, bids, acquiring and disposing of businesses, governance. | Identity data | Legal obligation Legitimate Interests | The usual limitation period in civil and commercial matters is six (6) years from the end of the contract. |
Supplier Management running | Identity data Contact data Financial data Transaction data Technical data Profile data Usage data Marketing data | Legal Obligation Legitimate Interests | The usual limitation period in civil and commercial matters is six (6) years from the end of the contract. | |
- Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
- Contact Data includes billing address, delivery address, email address and telephone numbers. For clients and suppliers this includes contacts within your organisation and may include publicly available information such as Companies House.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or enquired about and for suppliers, products and services we have purchased or enquired about from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
CONTRACT AND PROVIDING SERVICES
This means things like, carrying out our obligations arising from contracts we’ve entered into or a third party we are fulfilling a contract for, managing our relationship and notifying you about changes to our services or that we have taken over a service.
LEGAL OBLIGATIONS
This is things like keeping records for tax purposes and complying with statutory requirements.
LEGITIMATE INTERESTS
This means things like running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, health and safety or security requirements such as managing CCTV. Where we manage CCTV on site a separate policy will set out details regards the CCTV used. It can also mean enabling you to take part in a prize draw, competition or complete a survey. Studying how customers use our products and services to develop our business. We may use profile data to establish what you want or may of interest to you and decide which offers or services may be relevant to you (we call this marketing). For example we may market an event to individuals who live near a venue based on the geographical data we hold about you.