Hard To Find Privacy Policy

GDPR - 25th May 2018

1.0 Our core beliefs regarding user privacy and data protection

  • User privacy and data protection are human rights
  • We have a duty of care to the people within our data
  • Data is a liability, it should only be collected and processed when absolutely necessary
  • We loathe spam as much as you do!
  • We will never sell, rent or otherwise distribute or make public your personal information

2.0 Relevant legislation

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.

3.0 Personal information that this website collects and why we collect it

This website collects and uses personal information for the following reasons:

3.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

3.2 Our blog

Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors.

Your comment and its associated personal data will remain on this site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us here using the email address that you commented with.

You must be over 18 years of age before posting a comment on our blog.

NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

3.3 Contact forms and email links

Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Not all mail servers are secured therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.

3.4 Email newsletter

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Maijet who provide us with email marketing services. We consider Mailjet to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within Mailjet's database for as long as we continue to use Mailjet’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

While your email address remains within the Mailjet database, you will receive periodic (approximately twice per month) newsletter-style emails from us.

4.0 How we store your personal information

As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (Magento). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.

Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.

5.0 About this website’s server

This website is hosted by Digital Ocean within a UK data centre.

Some of the data centre’s more notable security features are as follows:

  • Proximity access locks on all external and internal doors
  • Interlocked man-trap doors with biometric iris scanners to gain access into data floors
  • Server cabinets have locked doors (no open racks)
  • Perimeter and internal IP CCTV system monitored 24×7
  • 24×7 on-site security guards with static and mobile patrols
  • All on-site personnel are security vetted to BS7858 standard
  • Only authorised security cleared staff are allowed into the facility

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

6.0 Our third party data processors

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

7.0 Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

8.0 Data Controller

The data controller of this website is: Hard To Find Digital Ltd, a UK Private limited Company with company number 05515214

Whose registered office is:
9-11 Vittoria St
Birmingham
B1 3ND

And whose operating office is:
No. 1 Spencer St.
Birmingham
B18 6DD

9.0 Data Protection Officer

Mr. Justin Bourne
Telephone: 0121-488 84 84
Email: jb@htfw.com

10.0 Changes to our privacy policy

This privacy policy may change from time to time in ine with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

10.1 Change log

14/05/2018 – version 1.0

  • Privacy policy updated

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE nameCOOKIE Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND You session ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.