Privacy Policy
This privacy policy sets out how The Hironator uses and protects your personal data.
1) Important information and who we are
Privacy policy
This privacy policy gives you information about how Richard Hiron trading as The Hironator collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter or purchase a service from us or through an organisation that we work in conjunction with.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Richard Hiron trading as The Hironator is the controller and responsible for your personal data (collectively referred to as “The Hironator”, “we”, “us” or “our” in this privacy policy).
The Hironator works through law firms that will have their own privacy notices and data protection arrangements. We will let you know which law firm will be the controller for your data when you purchase a service with us. Otherwise, The Hironator is the controller for data gathered and processed through this website and therefore responsible for it.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the us using the information set out in the contact details section (paragraph 10).
2) The types of personal data we collect about you
- Identity Data includes first name, last name, any previous names, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- 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.
- 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, device ID and other technology on the devices you use to access this 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 interact with and 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.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3) How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing information to be sent to you;
- complete a survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data is collected from the following parties:
- analytics providers such as Google based outside the UK;
- advertising networks such as LinkedIn, Instagram or Facebook based inside or outside the UK; and
- search information providers such as LinkedIn, Instagram or Facebook based inside or outside the UK.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as The Justice Platform Ltd t/a Legl based inside the UK.
- Identity and Contact Data is collected from data brokers or aggregators such as business networking contacts based inside or outside the UK.
- Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4) How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
- Purposes for which we will use your personal data
- We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Use | Type of data | Legal basis and retention period |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you in relation to providing legal and advisory services, such as situations in which we assist you with drafting or advising you on employment-related contractual paperwork, such as contracts of employment, staff handbooks and settlement agreements. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements. |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you in relation to providing legal and advisory services, such as situations in which we assist you with drafting or advising you on employment-related contractual paperwork, such as contracts of employment, staff handbooks and settlement agreements. (b) Necessary for our legitimate interests, such as to recover debts due to us and to inform you of our range of services when you have provided explicit, informed consent that you would like to hear further about those services from us. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (in all other situations). |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you in relation to providing legal and advisory services, such as situations in which we assist you with drafting or advising you on employment-related contractual paperwork, such as contracts of employment, staff handbooks and settlement agreements. (b) Necessary to comply with a legal obligation, specifically in relation to requirements placed on us by our regulator. (c) Necessary for our legitimate interests, to keep our records updated and manage our relationship with you, specifically in relation to whether you wish to hear from us in relation to our range of services and the way in which we conduct business. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (in all other situations). |
To enable you to complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you in relation to providing legal and advisory services, such as situations in which we assist you with drafting or advising you on employment-related contractual paperwork, such as contracts of employment, staff handbooks and settlement agreements. (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business). We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once the survey work has been completed or anonymise it as soon as possible after you have provided the survey feedback if that would serve the same or a similar legitimate interest protecting your personal data. |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for 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) (b) Necessary to comply with a legal obligation to ensure compliance with laws as they change from time to time relating to data privacy and data security. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once the administration and protection functions have been completed or anonymise it as soon as possible after the administration or protection work has been completed if that would serve the same or a similar legitimate interest protecting your personal data. |
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). For example, with your consent, we may suggest additional services or enhancements to existing services that you might find helpful based on your situation. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (if you are a client or in all other situations). |
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). For example, based on your searching requirements, we may use the data that we gather as a result to ensure search engine optimisation efficiency to ensure that visitors to our website with similar interests are able to find us. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (if you are a client or in all other situations). |
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Consent, having obtained your prior consent to receiving direct marketing communications. The trust and security that visitors to our website place in legal services is important to us and, therefore, we would prefer to receive your consent to receiving further information about us and our services. Such information will not be provided without your specific, informed consent to receiving such information from us. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (if you are a client or in all other situations). |
To carry out market research through your voluntary participation in surveys |
| Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). Our messaging is important to us in ensuring that visitors to our website come to us for the right reasons, so that they can ensure that we are the right fit for them service-wise and that they do not spend their valuable time coming to us for the wrong reasons. Therefore, understanding why visitors to our website come to us helps us to ensure that we are sending out the right message and, therefore, making optimum use of their time. We will retain this data for 7 years after the completion of your case in accordance with our regulator’s requirements (if you are a client) or will remove it once you have informed us that you no longer wish to hear from us (if you are a client or in all other situations). |
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at r.hiron@thehironator.co.uk.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct and confirmation of next steps relating to services that you wish us to provide for you.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see Cookie Policy.
5) Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Specific third parties such as Woodstock Legal Services Ltd trading as Woodstock Legal Services, Radshaw Solicitors Ltd trading as Radshaw Solicitors, Setfords Law Ltd trading as Setfords Solicitors, and The Justice Platforms Ltd trading as Legl.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6) International transfers
7) Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8) Data retention
How long will you use my personal data for?
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being clients for regulatory purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9) Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us (see Contact details in paragraph 10.
No fee usually required
What we may need from you
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.
Time limit to respond
10) Contact details
- Email address: r.hiron@thehironator.co.uk.
- Postal address: 2A Annerley Road, Bournemouth, Dorset, BH1 3PG.
- Telephone number: 07495 281508.
11) Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12) Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 20th June 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
13) Third-party links
This website may include links to third-party websites, 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 policy of every website you visit.
