PRIVACY NOTICE – HANLEY HEALTH LTD

Last updated October 12, 2022  

This privacy notice for Hanley Health Ltd. (Company’, ‘we’, ‘us’ or ‘our’,), describes how and why we  might collect, store, use, and/or share process’) your information when you use our services Services’), such as when you: 

• Visit our website at http://www.hanleyconsulting.co.uk, or any website of ours that links to this  privacy notice 
• Engage with us in other related ways, including any sales, marketing, or events  

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and  choices. If you do not agree with our policies and practices, please do not use our Services. If you still  have any questions or concerns, please contact us at [email protected].  

SUMMARY OF KEY POINTS  

This summary provides key points from our privacy notice, but you can find out more details about  any of these topics by clicking the link following each key point or by using our table of contents  below to find the section you are looking for.  

What personal information do we process? When you visit, use, or navigate our Services, we may  process personal information depending on how you interact with Hanley Health Ltd. and the  Services, the choices you make and the products and features you use.  

Do we process any sensitive personal information? We do not process sensitive personal  information  

Do we receive any information from third parties? We do not receive any information from third  parties.  

How do we process your information? We process your information to provide, improve, and  administer our Services, communicate with you, for security and fraud prevention, and to comply  with law. We may also process your information for other purposes with your consent. We process  your information only when we have a valid legal reason to do so.  

In what situations and with which types of parties do we share personal information? We may  share information in specific situations and with specific categories of third parties.  

How do we keep your information safe? We have organisational and technical processes and  procedures in place to protect your personal information. However, no electronic transmission over  the internet or information storage technology can be guaranteed to be 100% secure, so we cannot  promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be  able to defeat our security and improperly collect, access, steal, or modify your information. 

What are your rights? Depending on where you are located geographically, the applicable privacy  law may mean you have certain rights regarding your personal information.  

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will  consider and act upon any request in accordance with applicable data protection laws.  

TABLE OF CONTENTS  

1. WHAT INFORMATION DO WE COLLECT?  
2. HOW DO WE PROCESS YOUR INFORMATION?  
3. WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  
4. HOW LONG DO WE KEEP YOUR INFORMATION?  
5. HOW DO WE KEEP YOUR INFORMATION SAFE?  
6. WHAT ARE YOUR PRIVACY RIGHTS?  
7. CONTROLS FOR DO-NOT-TRACK FEATURES  
8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?  
9. DO WE MAKE UPDATES TO THIS NOTICE?  
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?  
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?  
12. WHAT INFORMATION DO WE COLLECT?  

Personal information you disclose to us  

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you register on the  Services, express an interest in obtaining information about us or our products and Services, when  you participate in activities on the Services, or otherwise when you contact us.  

Personal Information Provided by You. The personal information that we collect depends on the  context of your interactions with us and the Services, the choices you make, and the products and  features you use. The personal information we collect may include the following: 

• names 
• phone numbers 
• email addresses  
• job titles  
• usernames  
• passwords  
• contact preferences  

Sensitive Information. We do not process sensitive information.  

All personal information that you provide to us must be true, complete, and accurate, and you must  notify us of any changes to such personal information 

Information automatically collected  

In short: Some information — such as your Internet Protocol (IP) address and/or browser and device  characteristics — is collected automatically when you visit our Services  

We automatically collect certain information when you visit, use, or navigate the Services. This  information does not reveal your specific identity (like your name or contact information) but may  include device and usage information, such as your IP address, browser and device characteristics,  operating system, language preferences, referring URLs, device name, country, location, information  about how and when you use our Services, and other technical information. This information is  primarily needed to maintain the security and operation of our Services, and for our internal  analytics and reporting purposes.  

Like many businesses, we also collect information through cookies and similar technologies. 

The information we collect includes:  

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and  performance information our servers automatically collect when you access or use our  Services and which we record in log files. Depending on how you interact with us, this log  data may include your IP address, device information, browser type, and settings and  information about your activity in the Services (such as the date/time stamps associated  with your usage, pages and files viewed, searches, and other actions you take such as which  features you use), device event information (such as system activity, error reports  (sometimes called ‘crash dumps”), and hardware settings).  
• Device Data. We collect device data such as information about your computer, phone,  tablet, or other device you use to access the Services. Depending on the device used, this  device data may include information such as your IP address (or proxy server), device and  application identification numbers, location, browser type, hardware model, Internet service  provider and/or mobile carrier, operating system, and system configuration information.  
• Location Data. We collect location data such as information about your device’s location,  which can be either precise or imprecise. How much information we collect depends on the  type and settings of the device you use to access the Services. For example, we may use GPS  and other technologies to collect geolocation data that tells us your current location (based 

on your IP address). You can opt out of allowing us to collect this information either by  refusing access to the information or by disabling your Location setting on your device.  However, if you choose to opt out, you may not be able to use certain aspects of the  Services. 

2. HOW DO WE PROCESS YOUR INFORMATION?  

In Short: We process your information to provide, improve, and administer our Services,  communicate with you, for security and fraud prevention, and to comply with law. We may also  process your information for other purposes with your consent.  

We process your personal information for a variety of reasons, depending on how you interact with  our Services, including:  

• To facilitate account creation and authentication and otherwise manage user accounts. We  may process your information so you can create and log in to your account, as well as keep  your account in working order.  
• To respond to user enquiries/offer support to users. We may process your information to  respond to your enquiries and solve any potential issues you might have with the requested  service.  
• To enable user-to-user communications. We may process your information if you choose to  use any of our offerings that allow for communication with another user.  
• To send you marketing and promotional communications. We may process the personal  information you send to us for our marketing purposes if this is in accordance with your  marketing preferences. You can opt out of our marketing emails at any time. For more  information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?’ below). 
• To determine the effectiveness of our marketing and promotional campaigns. We may  process your information to better understand how to provide marketing and promotional  campaigns that are most relevant to you. 
• To save or protect an individual’s vital interest. We may process your information when  necessary to save or protect an individual’s vital interest, such as to prevent harm. 

3. WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?  

In Short: We only process your personal information when we believe it is necessary and we have a  valid legal reason i.e., legal basis) to do so under applicable law, like with your consent, to comply  with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect  your rights, or to fulfil our legitimate business interests. 

If you are located in the EU or UK, this section applies to you. 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal  basis we rely on in order to process your personal information. As such, we may rely on the  following legal basis to process your personal information: 

• Consent. We may process your information if you have given us permission (i.e. consent) to  use your personal information for a specific purpose. You can withdraw your consent at any  time. Click here to learn more.  
• Performance of a Contract. We may process your personal information when we believe it is  necessary to fulfil our contractual obligations to you, including providing our Services or at  your request prior to entering into a contract with you.  
• Legitimate Interests. We may process your information when we believe it is reasonably  necessary to achieve our legitimate business interests and those interests do not outweigh  your interests and fundamental rights and freedoms. For example, we may process your  personal information for some of the purposes described in order to:  

o Send users information about special offers and discounts on our products and  services  

o Support our marketing activities  

• Legal Obligations. We may process your information where we believe it is necessary for  compliance with our legal obligations, such as to cooperate with a law enforcement body or  regulatory agency, exercise or defend our legal rights, or disclose your information as  evidence in litigation in which we are involved.  
• Vital Interests. We may process your information where we believe it is necessary to protect  your vital interests or the vital interests of a third party, such as situations involving potential  threats to the safety of any person. 

If you are located in Canada, this section applies to you.  

We may process your information if you have given us specific permission (i.e. express consent) to  use your personal information for a specific purpose, or in situations where your permission can be  inferred (i.e. implied consent). You can withdraw your consent at any time.  

In some exceptional cases, we may be legally permitted under applicable law to process your  information without your consent, including, for example:  

• If collection is clearly in the interests of an individual and consent cannot be obtained in a  timely way 
• For investigations and fraud detection and prevention For business transactions provided  certain conditions are met  
• If it is contained in a witness statement and the collection is necessary to assess, process, or  settle an insurance claim  
• For identifying injured, ill, or deceased persons and communicating with next of kin  • If we have reasonable grounds to believe an individual has been, is, or may be victim of  financial abuse  
• If it is reasonable to expect collection and use with consent would compromise the  availability or the accuracy of the information and the collection is reasonable for purposes  related to investigating a breach of an agreement or a contravention of the laws of Canada  or a province  
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the  court relating to the production of records 
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was  produced  
• If the collection is solely for journalistic, artistic, or literary purposes  
• If the information is publicly available and is specified by the regulations 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?  

In Short: We may share information in specific situations described in this section and/or with the  following categories of third parties. 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:  

• Cloud Computing Services Communication & Collaboration Tools  
• Data Analytics Services  
• Data Storage Service Providers  
• Performance Monitoring Tools  
• Sales & Marketing Tools  
• Website Hosting Service Providers  

We also may need to share your personal information in the following situations:  

• Business Transfers. We may share or transfer your information in connection with, or during  negotiations of, any merger, sale of company assets, financing, or acquisition of all or a  portion of our business to another company. 
• When we use Google Maps Platform APIs. We may share your information with certain  Google Maps Platform APIs (e.g. Google Maps API, Places API). We obtain and store on your device (‘cache’)  your location. You may revoke your consent anytime by contacting us at the contact details  provided at the end of this document. 

• Affiliates. We may share your information with our affiliates, in which case we will require  those affiliates to honour this privacy notice. Affiliates include our parent company and any  subsidiaries, joint venture partners, or other companies that we control or that are under  common control with us.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  

In Short: We may use cookies and other tracking technologies to collect and store your information.  

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or  store information. Specific information about how we use such technologies and how you can refuse  certain cookies is set out in our Cookie Notice.  

6. HOW LONG DO WE KEEP YOUR INFORMATION? 

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this  privacy notice unless otherwise required by law.  

We will only keep your personal information for as long as it is necessary for the purposes set out in  this privacy notice, unless a longer retention period is required or permitted by law (such as tax,  accounting, or other legal requirements). No purpose in this notice will require us keeping your  personal information for longer than the period of time in which users have an account with us.  

When we have no ongoing legitimate business need to process your personal information, we will  either delete or anonymise such information, or, if this is not possible (for example, because your  personal information has been stored in backup archives), then we will securely store your personal  information and isolate it from any further processing until deletion is possible.  

7. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organisational and  technical security measures.  

We have implemented appropriate and reasonable technical and organisational security measures  designed to protect the security of any personal information we process. However, despite our  safeguards and efforts to secure your information, no electronic transmission over the Internet or  information storage technology can be guaranteed to be 100% secure, so we cannot promise or  guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat  our security and improperly collect, access, steal, or modify your information. Although we will do  our best to protect your personal information, transmission of personal information to and from our  Services is at your own risk. You should only access the Services within a secure environment. 

8. WHAT ARE YOUR PRIVACY RIGHTS?  

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and  Canada, you have rights that allow you greater access to and control over your personal information.  You may review, change, or terminate your account at any time. 

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data  protection laws. These may include the right (1) to request access and obtain a copy of your personal  information, (i) to request rectification or erasure; (iii) to restrict the processing of your personal  information, and (iv) if applicable to data portability. In certain circumstances, you may also have the  right to object to the processing of your personal information. You can make such a request by  contacting us by using the contact details provided. 

We will consider and act upon any request in accordance with applicable data protection laws.  

If you are located in the EEA or UK and you believe we are unlawfully processing your personal  information, you also have the right to complain to your local data protection supervisory authority.  You can find their contact details here: 

https://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.  

If you are located in Switzerland, the contact details for the data protection authorities are available  here: https://www.edoeb.admin.ch/edoeb/en/home.html.  

Withdrawing your consent: If we are relying on your consent to process your personal information,  which may be express and/or implied consent depending on the applicable law, you have the right  to withdraw your consent at any time. You can withdraw your consent at any time by contacting us  by using the contact details provided. 

However, please note that this will not affect the lawfulness of the processing before its withdrawal  nor, when applicable law allows, will it affect the processing of your personal information conducted  in reliance on lawful processing grounds other than consent.  

Opting out of marketing and promotional communications: You can unsubscribe from our marketing  and promotional communications at any time by clicking on the unsubscribe link in the emails that  we send, or by contacting us using the details provided. You will then be removed from the  marketing lists. However, we may still communicate with you — for example, to send you service related messages that are necessary for the administration and use of your account, to respond to  service requests, or for other nonmarketing purposes. 

Account Information  

If you would at any time like to review or change the information in your account or terminate your  account, you can:  

• Contact us using the contact information provided.  

Upon your request to terminate your account, we will deactivate or delete your account and  information from our active databases. However, we may retain some information in our files to  prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or  comply with applicable legal requirements.  

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you  prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you  choose to remove cookies or reject cookies, this could affect certain features or services of our 

Services. To opt out of interest-based advertising by advertisers on our Services visit  http://www.aboutads.info/choices/ 

If you have questions or comments about your privacy rights, you may email us at  [email protected] 

9. CONTROLS FOR DO-NOT-TRACK FEATURES  

Most web browsers and some mobile operating systems and mobile applications include a Do-Not Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data  about your online browsing activities monitored and collected. At this stage no uniform technology  

standard for recognising and implementing DNT signals has been finalised. As such, we do not  currently respond to DNT browser signals or any other mechanism that automatically communicates  your choice not to be tracked online. If a standard for online tracking is adopted that we must follow  in the future, we will inform you about that practice in a revised version of this privacy notice. 

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to  your personal information  

California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who  are California residents to request and obtain from us, once a year and free of charge, information  about categories of personal information (if any) we disclosed to third parties for direct marketing  purposes and the names and addresses of all third parties with which we shared personal  information in the immediately preceding calendar year. If you are a California resident and would  like to make such a request, please submit your request in writing to us using the contact  information provided.  

If you are under 18 years of age, reside in California, and have a registered account with Services,  you have the right to request removal of unwanted data that you publicly post on the Services. To  request removal of such data, please contact us using the contact information provided below and  include the email address associated with your account and a statement that you reside in  California. We will make sure the data is not publicly displayed on the Services, but please be aware  that the data may not be completely or comprehensively removed from all our systems (e.g.  backups, etc.).  

CCPA Privacy Notice 

The California Code of Regulations defines a ‘resident’ as:  

(1) every individual who is in the State of California for other than a temporary or transitory purpose  and 

(2) every individual who is domiciled in the State of California who is outside the State of California  for a temporary or transitory purpose 

All other individuals are defined as ‘non-residents’. If this definition of ‘resident’ applies to you, we  must adhere to certain rights and obligations regarding your personal information. 

We may collect other personal information through instances where you interact with us in person,  online, or by phone or mail in the context of:  

• Receiving help through our customer support channels 
• Participation in customer surveys or contests, and  
• Facilitation in the delivery of our Services and to respond to your enquiries.  How do we use and share your personal information?  

Hanley Health Ltd, collects and shares your personal information through: 

• Targeting cookies/Marketing cookies  
• Social media cookies  
• Beacons/Pixels/Tags  
• Social media plugins: Vimeo and Twitter. We use social media features, such as a ‘Like’  button, and widgets, such as a ‘Share’ button, in our Services. Such features may process  your Internet Protocol (IP) address and track which page you are visiting on our website. We  may place a cookie to enable the feature to work correctly. If you are logged in on a certain  social media platform and you interact with a widget or button belonging to that social  media platform, this information may be recorded to your profile of such social media  platform. To avoid this, you should log out from that social media platform before accessing  or using the Services. Social media features and widgets may be hosted by a third party or  hosted directly on our Services. Your interactions with these features are governed by the  privacy notices of the companies that provide them. By clicking on one of these buttons, you  agree to the use of this plugin and consequently the transfer of personal information to the  corresponding social media service. We have no control over the essence and extent of  these transmitted data or their additional processing.  

More information about our data collection and sharing practices can be found in this privacy notice. 

You may contact us by email at [email protected], or by referring to the contact details  at the bottom of this document.  

If you are using an authorised agent to exercise your right to opt out we may deny a request if the  authorised agent does not submit proof that they have been validly authorised to act on your behalf. 

Will your information be shared with anyone else?  

We may disclose your personal information with our service providers pursuant to a written contract  between us and each service provider. Each service provider is a for-profit entity that processes the  information on our behalf. 

We may use your personal information for our own business purposes, such as for undertaking  internal research for technological development and demonstration. This is not considered to be  ‘selling’ of your personal information.  

Hanley Health Ltd. has not sold any personal information to third parties for a business or  commercial purpose in the preceding twelve (12) months. Hanley Health Ltd, has disclosed the  following categories of personal information to third parties for a business or commercial purpose in  the preceding twelve (12) months:  

• Category A. Identifiers, such as contact details like your real name, alias, postal address,  telephone or mobile contact number, unique personal identifier, online identifier, Internet  Protocol address, email address, and account name.  
• Category G. Geolocation data, such as device location.  

The categories of third parties to whom we disclosed personal information for a business or  commercial purpose can be found under section 4. 

Your rights with respect to your personal data  

Right to request deletion of the data – Request to delete  

You can ask for the deletion of your personal information. If you ask us to delete your personal  information, we will respect your request and delete your personal information, subject to certain  exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or  her right to free speech, our compliance requirements resulting from a legal obligation, or any  processing that may be required to protect against illegal activities.  

Right to be informed — Request to know  

Depending on the circumstances, you have a right to know:  

• whether we collect and use your personal information 
• the categories of personal information that we collect 
• the purposes for which the collected personal information is used 
• whether we sell your personal information to third parties 
• whether we sell your personal information to third parties 
• the categories of personal information that we sold or disclosed for a business purpose • the categories of third parties to whom the personal information was sold or disclosed for a  business purpose 
• the business or commercial purpose for collecting or selling personal information.  

In accordance with applicable law, we are not obligated to provide or delete consumer information  that is de identified in response to a consumer request or to re-identify individual data to verify a  consumer request.  

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights  

We will not discriminate against you if you exercise your privacy rights. 

Verification process  

Upon receiving your request, we will need to verify your identity to determine you are the same  person about whom we have the information in our system. These verification efforts require us to  ask you to provide information so that we can match it with information you have previously  provided us. For instance, depending on the type of request you submit, we may ask you to provide  certain information so that we can match the information you provide with the information we  already have on file, or we may contact you through a communication method (e.g. phone or email)  that you have previously provided to us. We may also use other verification methods as the  circumstances dictate. 

We will only use personal information provided in your request to verify your identity or authority to  make the request. To the extent possible, we will avoid requesting additional information from you  for the purposes of verification. However, if we cannot verify your identity from the information  already maintained by us, we may request that you provide additional information for the purposes  of verifying your identity and for security or fraud-prevention purposes. We will delete such  additionally provided information as soon as we finish verifying you.  

Other privacy rights 

• You may object to the processing of your personal information 
• You may request correction of your personal data if it is incorrect or no longer relevant or  ask to restrict the processing of the information.  
• You can designate an authorised agent to make a request under the CCPA on your behalf.  We may deny a request from an authorised agent that does not submit proof that they have  been validly authorised to act on your behalf in accordance with the CCPA.  
• You may request to opt out from future selling of your personal information to third parties.  Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible,  but no later than fifteen (15) days from the date of the request submission 
• You may request to opt out from future selling of your personal information to third parties.  Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible,  but no later than fifteen (15) days from the date of the request submission.  

To exercise these rights, you can contact us by email at [email protected], or by  referring to the contact details at the bottom of this document. If you have a complaint about how  we handle your data, we would like to hear from you.  

11. DO WE MAKE UPDATES TO THIS NOTICE?  

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.  

We may update this privacy notice from time to time. The updated version will be indicated by an  updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we  make material changes to this privacy notice, we may notify you either by prominently posting a 

notice of such changes or by directly sending you a notification. We encourage you to review this  privacy notice frequently to be informed of how we are protecting your information.  

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?  

If you have questions or comments about this notice, you may contact our Data Protection Officer  (DPO), Paul Harvey, by email at [email protected], by phone at +44 (0) 7742879868, or  by post to: 

Hanley Health Ltd.  

Paul Harvey  

Bay 4, Pennyroyal Court  

Station Road  

Tring  

England 

HP23 5QY  

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?  

Based on the applicable laws of your country, you may have the right to request access to the  personal information we collect from you, change that information, or delete it. To request to  review, update, or delete your personal information, please submit a request using the contact  details provided.