Hera Elite (“We” or “Our” or “Ours”) are committed to protecting and respecting your privacy.
“Member” means any person with whom We have entered into a contract for the provision of the Hera Elite services (the “Services”.)
This policy applies to information We collect or you provide when We are acting as data controller with respect to the personal data of Our Members.
This policy explains how We collect, use and the circumstances in which We may disclose Your information.
All Your personal information will be held and used in accordance with the Data Protection Act 1998 (“the Act”) as amended.
We are the data controller of Your personal information for the purposes of the Act.
We also support and follow the Data Protection Principles. Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:
• be processed fairly, lawfully and transparently;
• be collected and processed only for specified, explicit and legitimate purposes;
• be adequate, relevant and limited to what is necessary for the purposes for which it is
• be accurate and kept up to date. Any inaccurate data must be deleted or rectified
• not be kept for longer than is necessary for the purposes for which it is processed; and
• be processed securely.
We are accountable for these principles and must be able to show that we are compliant.
Before providing any Service, all Members will sign an Agreement. The Agreement makes clear that:
• We are legally obliged to protect all personal data held and processed on Members.
Where personal data is processed on the Member, We confirm that We will process it securely
and will limit the people who have access to it to those with a specific need to do so.
In addition, We confirm that We will only process personal data on Members for as long
as it is necessary or relevant to do so.
• You give your consent to Hera to process your personal data in accordance with
In addition, by visiting Our Website or using Our Services, you consent to Our collection,
If We change these policies We will post the changes on Our Website or otherwise notify You
to keep You aware of what personal information We collect, how We use it and the circumstances in which We may disclose it.
When You visit Our Website or use Our Services, You may provide us with personal
information, such as Your name, address, age, marital status, email address, telephone
number, bank details and other sensitive personal information that we need to collect in order
to provide you with the Services. We have given more information about the categories of
Members Information that we collect and use below. You may provide this information in the
course of meetings and discussions with Us, when You subscribe to any of Our newsletters or
when You correspond with us by email, telephone or otherwise.
3.1 Members information includes the following:
Account Data being details of Your name and address and other contact data (including
without limitation email and telephone numbers.) These may be processed for the purposes
of operating our Website and providing the Services to You. The legal basis for processing
this information is that it is required in order that the contract for the provision of Services
may be carried out.
Personal Profile Data
Personal Data can be split into general personal data to support your profile as well as special
personal data, also to support your profile and help us provide you with a better Service.
General Personal Data being details of Your name and address, mobile and telephone
numbers, gender, date of birth, relationship status, photographs, details of Your education,
hobbies and interests and Partner Profile (as defined in the Agreement that we have with You
for the provision of the Services) being sought may be processed for the purposes of
operating our Website and providing the Services to You. The legal basis for processing this
information is that it is required in order that the contract for the provision of Services may be
Special categories of personal data’ are types of personal data consisting of information as
• your racial or ethnic origin;
• your political opinions;
• your religious or philosophical beliefs;
• your trade union membership;
• your genetic or biometric data;
• your health;
• your sex life and sexual orientation; and
• any criminal convictions and offences.
We may hold and use any of these special categories of your personal data in accordance with
Service Enquiry Data
We may process information in any enquiry that You send to us regarding the Services.
Service Enquiry Data may be processed for the purposes of marketing, offering and selling
the Services to You. The legal basis for processing this information is that it is required in
order that the contract for the provision of Services may be carried out.
Membership Relationship Data
We may process information relating to relations with You and Our Members (which includes
without limitation and by way of example only, Your name and contact details). The source
of such data will be You. Membership Relationship Data may be processed for the purposes
of managing, communicating and keeping records of Our communication with Members and
promoting the Services. The legal basis for processing this information is that it is required
in order that the contract for the provision of Services may be carried out.
Members Transaction Data
We may process transaction information relating to relations with Our Members (which
includes without limitation and by way of example only, details of the payments made by You
for the Services and details of the payments method(s) used by You for the payment of the
Services). Transaction data may be processed for the purposes of providing You with the
Services. The source of such data will be You. The legal basis for processing this
information is that it is required in order that the contract for the provision of Services may be
Members Notification Data
We may process information that You provide Us with relating to You for the purpose of
receiving email and other forms of notifications and for the purpose of receiving newsletters .
The source of such data will be You. The legal basis for processing this information is that it
is required in order that the contract for the provision of Services may be carried out.
3.2 Our Use of Members Information.
As well as in the course of providing the Services, We may use and process Your and
Members Information for the following purposes:-
a) obtaining and maintaining indemnity insurance, the legal basis for which is protecting Our
business against usual business and commercial risks;
b) in order that We may comply with any legal obligation to which We are subject, in order to
protect Our interests, Your interests or those of a third party;
c) in connection with any legal dispute with You, including for the purposes of making or
defending any claim, the legal basis for which is protecting Our rights, Your rights and the
rights of others.
d) We will share your personal data with other Members in order to provide Services. We
require all those who have your personal data to keep your personal data confidential and
secure and to protect it in accordance with the law and our policies. They are only permitted
to process your data for the lawful purpose for which it has been shared and in accordance
with our instructions.
4. How to deal with data breaches
We have robust measures in place to minimise and prevent data breaches from taking place.
Should a breach of personal data occur (whether in respect of you or someone else) then we
must take notes and keep evidence of that breach. In addition, if the breach is likely to result
in a risk to the rights and freedoms of individuals then we must also notify the Information
Commissioner’s Office within 72 hours.
If you are aware of a data breach you must contact the Data Protection Officer immediately
and keep any evidence you have in relation to the breach.
5. Subject access requests
Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we
hold about them. This request must be made in writing. If you receive such a request you
should forward it immediately to the Data Protection Officer who will coordinate a response.
If you would like to make a SAR in relation to your own personal data you should make this
in writing to the Data Protection Officer. We must respond within one month unless the
request is complex or numerous in which case the period in which we must respond can be
extended by a further two months.
There is no fee for making a SAR. However, if your request is manifestly unfounded or
excessive we may charge a reasonable administrative fee or refuse to respond to your request.
When you visit Our Website We may also collect technical information about your computer,
including its IP address, browser type, operating system and geographical location as well as
information about Your visit including URLs of pages visited and clickstream to, through and
from Our Website.
We also collect information about how You use our newsletters, for example,
whether You open it and which links You click on.
experience We can.
Using your information
We use information We hold about you in the following ways:
• To ensure that content from Our Website is presented in the most effective way for
You and Your computer or device
• To notify You about changes to our Services
• To provide You with information on Services, events and updates that You request
from Us or which We feel may be of interest to You where you have signed up to
receive Our newsletters and events information. You can unsubscribe from these
communications by following the instructions contained in this policy.
We may pass Your information to third party organisations in the following circumstances:-
• If We buy or sell any business or assets, in which case We may disclose Your
information to the seller or buyer;
• If We or substantially all of Our assets are acquired by a third party, in which case
Your information will be one of the transferred assets
• If We are under a duty to disclose or share Your information to comply with any legal
obligation or in order to enforce or apply our terms and conditions and other
agreements or protect the rights, property, or safety of our customers, or others.
We may share your information with Our trusted service providers including Our Website
hosting provider and other IT service providers. This includes exchanging information with
other companies and organisations for fraud protection and credit risk reduction.
If You would like us to stop processing Your information in this way. or would like Us to
amend or delete the information We hold about You, You can contact us on the contact details
set out below.
7. Where we store your Personal Information
All data and information that We collect from You is stored on our secure servers or that of
our suppliers/service providers and may be transferred to and stored at a destination outside
the European Economic Area (“EEA”). You consent to our transferring and storing your
information outside the EEA. We will take all steps reasonably necessary to ensure that your
information is treated securely and in accordance with this policy. Please note that we cannot
prevent third parties from using or misusing personal data..
We maintain the highest standards of security, however the transmission of information via
the internet is not completely secure. Whilst We will do our best to protect Your information,
We cannot ensure the security of Your personal data during transit to Our Website. Any
information You submit is sent at Your own risk. Once We have received Your information
(by whichever means) We will use strict procedures and security features to prevent
9. Retaining and Deleting Personal Data
We will not keep Your personal data for longer than we need to for the purposes of
performing the Services.
Personal data that we collect from or which is provided by You will not be stored for any
longer than 6 years.
10. Your Rights
As well as other rights under stat protection legislation, You have the following rights in
respect of Your personal data:
a) the right to access your data;
b) the right to have your data rectified;
c) the right to have your data erased
d) the right to restrict processing of your data;
e) the right to object to data processing;
f) the right to data portability;
g) the right to complain; and
h) the right to withdraw consent to processing of your data
Please contact Our Data Protection Officer if you wish to exercise any of your rights above.
Right to Access
You have the right to ask us to confirm whether We process Your personal data and the right
to access this and to receive a copy of it. You may also ask for details of the purpose for
which We are processing personal data, the categories of data and the those people who have
received such personal data. We will supply you with a copy of the personal data that we
hold about You on request, provided that the rights of other Members are not compromised
by doing so. We will supply the first copy of such personal data free of charge, but reserve
the right to make a charge for subsequent requests.
Right to Rectification
You have the right to request that any inaccurate personal data that We hold about You is
corrected or further additional personal information about You be added.
Right to have Personal Data Erased
There are number of situations in which You may require personal data that We hold about
You to be erased. This will include:-
– Where holding such personal data about You is no longer necessary;
– You withdraw consent;
– You object to processing under applicable data protection law.
Please note that You may not require personal data that We hold about You to be erased
where We require such information for the purposes of providing You with the Services and
for the purposes of making or defending any claim, the legal basis for which is protecting
Our rights, Your rights and the rights of others.
Right to Restrict Processing of Personal Data
You may have the right to restrict the processing of Your personal data in certain situations.
By way of example and not by way of limitation, such situations may include:-
– You do not believe that the personal data that We hold about You is accurate;
– We do not need Your personal information;
– You have objected to certain types of data processing.
Where data processing has been restricted, We may continue to retain Your personal data but
We will only process it with Your consent for the purposes of making or defending any claim,
the legal basis for which is protecting Our rights, Your rights and the rights of others.
You have the right to object to data processing of Your personal data for the purposes of
If You are unhappy with the way in which We have processed your data, or You believe that
our processing of Your personal data has breached applicable data protection laws, You have
the right to complain.
If you wish to make a complaint about the processing of your data, you should firstly raise
this with the Data Controller (the organisation) and if unresolved should be escalated to the
Information Commissioner’s Office which is the supervisory authority for data in the UK.
You can do this be contacting the Information Commissioner’s Office directly. Full contact
details including a helpline number can be found on the Information Commissioner’s Office
website (www.ico.org.uk). This website has further information on your rights and our
10. Data Protection Officer
Our data protection officers contact details are:
Our principal business address is at [ Berkeley Square house, Berkeley Square, W1J 6BD
London. Hera-elite Limited is a company incorporated in England & Wales under CRN
You can contact us by the following methods:
– By post to our business address set out above;
– By email [firstname.lastname@example.org]