Who we are
We are Handheld Community Ltd, a company incorporated in the UK with registered number 12589183 and having our registered office address at 228 Bournemouth Road, Chandlers Ford, Hampshire, SO53 3AF.
We are a controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation.
How to contact us
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Initial enquiries should be directed to our Data Protection Officer as follows:
By post: Customer Enquiries, 228 Bournemouth Road, Chandlers Ford, Hampshire, SO53 3AF
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website () or any other website registered in our name, including any personal data that you may provide through our Website, where we have a contract in place with you (please note that separate terms and conditions may also be applicable here), through your use of our services ("Services") and through your other communications with us.
It is important that you read this privacy notice when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.
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.
This version of our privacy notice was last updated on the 14th of June 2020.
To whom does this privacy notice apply?
This privacy notice applies to:
all individuals who access our Services via our clients as "end users";
all individuals who visit our Website
Information about our website
Our Website from time to time, 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 we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Where you are an end user, our customer operating the venue or organisation by which you access our Services will also be a controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation. Our customers will also have a privacy notice setting out what personal data they collect from you and how they intend to use such personal data. You should consult the relevant customer's privacy notice for more information. We will not be held responsible or liable to you in any way with regard to how our customers process your personal data when you access the Services. This privacy notice only applies to how we process end-user personal data.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Please see our cookie notice for more information regarding what cookies we use.
About the personal data that we collect and process
"Personal data", or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed ("anonymous data").
We do not collect or process special categories of personal data in the course of providing our Services.
This policy summarises the personal data we collect and process, how we use it ("our processing purposes") and why we use it ("the lawful bases of processing").
We may also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate data to calculate the percentage of individuals accessing a specific feature of our Website, or to analyse how individuals use our Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).
We have set out below a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Individuals who access our Services via our clients.
What personal data do we collect?
If you use our link sharing services we may collect the following data:
Engagement data and metrics about the interaction such as clicks, views, and dwell time of the campaigns viewed via the shared link. This data is not linked to any individual and it is not personally identifiable.
If you use our WiFi onboarding services we may collect the following data:
Technical data - this may include internet protocol (IP) address, browser type and version, time zone setting and location, MAC address, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services
Usage data - may include information about how you use the Services
How do we use your personal data?
To process and deliver Services to you including:
Providing information about our Services on request;
Carrying out our Services; and
Dealing with any end-user complaints and receiving feedback
To manage our relationship with you.
To notify you about changes to our terms and conditions or privacy notice.
To improve the user experience and administer the functionality of our Services.
Why do we use your personal data?
Necessary for us to perform the Services.
Necessary for our legitimate interests (to maintain network security and ensure our Services are delivered in the most effective manner for you).
Necessary to comply with a legal obligation.
Any visitor to our Websites.
What personal data do we collect?
Technical data - (including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Websites)
Usage data - (including information about your visit and how you use our Websites)
How do we use your personal data?
To improve the user experience and administer the functionality of our Websites.
To respond to general and specific enquiries.
Why do we use your personal data?
Necessary for our legitimate interests (to maintain network security and Website relevance for visitors to our Website).
Necessary to comply with a legal obligation.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at ().
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
How is your personal data obtained?
We may use different methods to collect personal data from and about you including through:
Automated technologies or interactions. As you interact with our Website or use our Services, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
Direct interactions. You may give us your identity, contact, financial, transactional or similar personal data when you correspond with us by post, phone, e-mail or otherwise, including when you use our Services, complete a form on our Website or otherwise contact us via our Website.
Direct interactions with business contacts, individual clients and client-related individuals. You may give us your identity, contact, financial, transactional and other business related personal data when you correspond with us, including when:
you or your organisation negotiate and/or enter into a contract with us; or
you or your organisation provide services or products to us or your or your organisation receive services from us; or
you provide us with your business card.
Direct interactions with our investors and/or shareholders. You may give us your identity, contact and other business related personal data in the process of investing in Handheld Community Ltd or where you communicate with us as a shareholder in Handheld Community Ltd.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
where you are a business contact, your organisation or business may provide us with your identity and contact data.
where you are a client-related individual, your organisation or business may provide us with your identity and contact data.
we may obtain identity and contact data from publicly available sources such as social media (such as LinkedIn or Twitter), Companies House or other organisations’ websites.
we may obtain contact, financial and transaction data from providers of payment and credit card services.
we may obtain technical data (relating to the use of our Website and Services) from analytics providers or search information providers.
where you are a member of an investment syndicate investing in Handheld Community Ltd the syndicate may provide your personal data to us as part of the transaction.
Failure to provide personal data
Where we need to collect personal data by law, to provide our Services, or under the terms of a contract we have with you (or are trying to enter into with you) and you fail to provide that data when requested, we may not be able to perform the contract or perform our Services. In this case, we may have to cancel a contract (but we will notify you if this is the case at the time) and/or be unable to provide our Services.
If you are an individual consumer or end user, we will only provide you with direct marketing communications where you have consented to receive such communication or you have contacted us directly to request specific information about our Services. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us at .
If you represent another business or organisation, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us at .
Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.
With whom do we share your personal data?
There may be circumstances in which we may also need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis). The third parties to which we may transfer your personal data include:
Your business or organisation, for the purpose of providing our Services to your business or organisation, or receiving products or services from your business or organisation.
Our corporate customers where you are an end user.
Our investors and/or shareholders.
Service providers acting as processors who provide IT and system administration services.
Professional advisers including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Any relevant accreditation body or trade association.
Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, courts or tribunals who require reporting of processing activities in certain circumstances.
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 notice.
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.
Any sharing of your personal data will only take place either where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:
to maintain network and information security;
to provide Services to our clients;
to develop and improve our Services in order to remain competitive;
to establish, protect and defend our legal rights;
to pursue our commercial objectives where this does not override your rights and freedoms as a data subject
We generally do not transfer your personal data out of the European Economic Area (EEA). However, whenever we are required to transfer your personal data out of the EEA (for example where a third party supplier is located outside of the EEA), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (
Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the USA. For further details, see European Commission: EU-US Privacy Shield (
You have provided your explicit consent to the transfer of your personal data outside of the EEA.
The transfer is necessary for the purposes of performing a contract between us and you (the data subject).
Automated decision making and profiling
We do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.
How long do we retain your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Personal data relating to Website users, end users and business contacts will generally not be retained for longer than 12 months unless such data is relevant to ongoing Services. Personal data relating to individual clients and client-related individuals will generally not be retained for longer than 7 years after conclusion of the relevant services unless such data is relevant to any legal, accounting or reporting requirements. Please contact us at for further details about our retention periods.
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 the Information Commissioner's Office of a breach where we are legally required to do so.
Your personal data is protected by legal rights, which include your rights to:
Request access to your personal data (commonly known as a "data 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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, following your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
Request the transfer of your personal data to you or to a third party (data portability). 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. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, please contact us at .
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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data.