This Research privacy Policy (the \"Policy\") is intended to provide you with information
\nabout what personal data Holden collects about you and how it is used.
\nThis Policy describes how we may obtain personal data, the types of personal data we may obtain, how we use, share and protect the personal data, the rights of data subjects with respect to their personal data, and how to contact us about our privacy practices.
\nWe may revise this Privacy Policy at any time, without notice to you. You are responsible for reviewing it regularly. Your access of the Sites following the posting of changes means you agree to abide by those changes.
\nThis Privacy Policy was last revised on March 30, 2022.
\nHolden collects personal data about its members and those that participate in our Activities. We use this personal data to provide you with services as described below. We do not sell personal data to anyone and only share it with third parties who are facilitating the delivery of our services or when you give us explicit additional permission.
\nWe may process the following types of personal data about Representatives:
\n• Names, postal or e-mail addresses, fax numbers, and phone numbers
\n• Employment information (e.g., job titles) relating to Representatives
\n• Communication preferences
\nAs a matter of practice, we will not collect any sensitive (special category) personal data relating to Representatives. To the extent that there is a need for us to process sensitive personal data, we will obtain the Representative's prior written consent.
\nWe use different methods to collect data from and about you including through:
\nDirect interactions. You may give us your Identity, Contact, Profile and Marketing and Communications data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
\nSubscribe to our service or publications;
\nRequest marketing to be sent to you;
\nTake part in market research;
\nApply for a job;
\nEnter a competition, promotion or survey; or
\nGive us some feedback.
\nAutomated technologies or interactions. As you interact with our website, we may collect technical and or usage data about your equipment, browsing actions and patterns via ‘cookies’. To manage the different cookies that will apply to such interaction, you can select “Cookie Settings” when you enter our website(s) which will provide you with a number of options.
\nThird parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
\nThe site may make use of two types of cookies. “Cookies” are small data files, typically made up of a string of text and numbers, which assign you a unique identifier. A “client cookie” may be sent to your browser so that our systems remember your requests and keep track of the pages you view on our site and which services you use (e.g., the pages you view, the links you click and other actions you take on the site). A “server cookie” may be maintained on our systems to recognize you when you return to the site. This information allows us to better administer the site and provide a more tailored and user friendly service to you.A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the site may not function properly if the ability to accept cookies is disabled.
\nWe may use cookies that allow us to recognise people who have previously visited our website and use this information to match the right people with the right message when we advertise online. This may affect how third-parties, like Google, show you ads on sites across the Internet.
\nLearn more about cookies
\nHolden strives to have in place appropriate means to protect your information. However, in providing your information over a public or third party network, you do so at your own risk. Holden makes no representation or warranties with regard to the sufficiency of its security measures.
\nThis data is used to manage our contact with you, so that, for example, multiple attempts to contact you regarding the same services are eliminated or you are not re-contacted after informing us you are not interested in our services.
\nThe legal bases we rely upon to offer these services to you are:
\nWhere we have a legitimate interest (i.e., we have a valid business reason) and we have carefully balanced your individual rights against this need:
\nTo fulfil a contractual obligation that we have with you; and/or
\nYour consent for direct marketing.
\nWe will only process your personal data for the purpose it was first collected. If we process the personal data for a new purpose we will ensure it is either compatible with your original purpose, or gain your consent.
\nAny of the information we collect from you may be used in one of the following ways:
\n• To personalize your experience
\n(your information helps us to better respond to your individual needs)
\n• To improve our website
\n(we continually strive to improve our website offerings based on the information and feedback we receive from you)
\n• To improve customer service
\n(your information helps us to more effectively respond to your customer service requests and support needs)
\n• To process transactions
\nYour information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
\n• To send periodic emails
\nThe email address you provide for order processing, will only be used to send you information and updates pertaining to your order.
\nHolden does not sell, rent, or trade member’s personal data. We may share your personal data only with:
\nAffiliates of Holden to whom it is reasonably necessary or desirable for Holden to disclose the personal data
\nService providers that Holden has retained to perform services on its behalf, such as, but not limited to, IT service providers. Service providers are not permitted to use the personal data for their own purposes and are prohibited from onward transfer of the personal data without our written consent in each instance
\nLaw enforcement and other government authorities if required by law or reasonably necessary to protect the rights, property, and safety of others or ourselves. This includes lawful requests by public authorities, including to meet national security or law enforcement requirements
\nOur clients or carefully selected partners, which will, where possible be anonymised data only. No identifiable personal data will be shared without your consent.
\nWITHIN Holden,Holden endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only in ways that are consistent with your relationship with Holden and the practices described in this Privacy Policy. Because of the global nature of our business, there may be times when we need to transfer your Personal Data to a country outside of the country you reside.
\nHolden uses cloud and physical servers in the UK, EU, USA, India and Australia. UK and EU Personal Data will only be stored and processed in UK, EU or USA.
\nSTANDARD CONTRACTUAL CLAUSESFor transfers outside of the EEA and UK, Holden uses EU Standard Contractual Clauses or UK International Data Transfer Agreements to additionally safeguard data from the EEA and UK to countries outside of these locations.
\nSUPPLIERS AND CONTRACTORSAs laid out in this Privacy Policy, we may from time to time share limited information with carefully selected partners. This may involve transferring your personal data to countries outside the EEA, the UK, or Switzerland and is done within the legal restrictions of the General Data Protection Regulations (GDPR), and with Holden remaining in contractual control of the data including standard EEA, UK, and Swiss data protection clauses.
\nWe maintain appropriate technical and organizational security safeguards designed to protect Representatives' personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. We update and test our security technology on an ongoing basis. We limit access to your personal data to those employees who need access to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal data.
\nWe store personal data for as long as necessary to fulfil the purposes for which we collect the data (see \"How we use the Personal Data we obtain\"), except if required otherwise by law. Your personal data may be kept for 10 years after the working relationship has ceased.
\nAs our organization, membership and benefits change from time to time, this Privacy Policy and our Terms of Use is expected to change as well. We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy and Terms of Use at this Site. We may e-mail periodic reminders of our policy and terms and will e-mail members of material changes to it, but you should check our Site frequently to see the current Privacy Policy and Terms of Use that are in effect and any changes that may have been made to them.
\nYou may request information about:
\nthe purpose of the processing;
\nthe legal basis for that processing;
\nthe categories of personal data and the data subject concerned;
\ninformation on the type or identity of third parties to which your data may be disclosed to and the protection provided;
\nthe source of the personal information (if you didn’t provide it directly to us); and
\nhow long it will be stored.
\nYou have a right to:
\naccess your personal data
\nhave inaccurate personal data rectified
\nrequest erasure of personal data
\nrestrict the processing of your personal data
\nobject to the processing your personal data
\ndata portability
\nopt out of data being transferred to a third party, unless there is a legal reason to do so (see \"How we may share Personal Data\")
\nopt out of direct marketing
\nopt out of automated decision making
\nTo exercise your rights, you can write the Data Protection Officer at team@holdendata.com
\nReasonable access to your personal data will be provided at no cost to you upon your request. Holden will provide the information to you within the legal time frame(one month). If for some reason access is denied, Holden will provide an explanation as to why access has been denied.
\nIf you have questions about this Privacy Policy, please email Holden’s Data Protection Officer at team@holdendata.com
\nFor all other questions regarding your account, preference changes, compensation for surveys or our services, please e-mail team@holdendata.com
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