Updated: November 2022
Hanzo Archives Limited and Hanzo Archives, Inc understand that your privacy is important and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.hanzo.co or any other site operated by a Hanzo company (“Our Site(s)”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law based upon your individual entitlements (such as GDPR as a European citizen and CCPA in the state of California).
1. Definitions And Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“CCPA” means California Consumer Privacy Act of 2018 passed on 3rd January 2018;
“Cookie” means a small text file placed on your computer or device by Our Site(s) when you visit certain parts of Our Site(s) and/or when you use certain features of Our Site(s). Details of the Cookies used by Our Site(s) are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site(s). This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 OR EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Hanzo Archives Limited, a limited company registered in England under company number 05410483, whose registered address is No 1 Leeds, Whitehall Road, Leeds, England, LS12 1BE or Hanzo Archives, Inc with a corporate address at One Liberty Plaza, 165 Broadway Fl. 23rd, New York, New York 10006.
2. Information About Us
2.1 Our Site(s) is owned and operated by Hanzo Archives Limited, a limited company registered in England under company number 05410483 and whose registered address is No 1 Leeds, Whitehall Road, Leeds, England, LS12 1BE.
2.2 Our VAT number is 912 8708 19.
2.3. Our Data Director is Chris Johnson, and can be contacted by email at email@example.com or by post at Hanzo Archives, Inc, One Liberty Plaza, 165 Broadway Fl. 23rd, New York, New York 10006.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a European citizen data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 If in Europe, for further information about your rights, you may be able to contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
4.5 The California Consumer Privacy Act of 2018 (CCPA) gives all consumers from the state of California control over the personal information that qualifying businesses collect about them. These new privacy rights for California consumers include for example:
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to opt-out of the sale of their personal information; and
- The right to non-discrimination for exercising their CCPA rights.
Businesses who meet one of the three requirements are required to give consumers certain notices explaining their privacy practices. The CCPA applies to many businesses, although at this stage not US, that said as a responsible business we comply with many of its requirements as a matter of good international business practice e.g. see below where we explain what data we collect and why.
5. What Data Do We Collect?
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and once in effect the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Sites;
6.2.3 Personalizing and tailoring your experience on Our Site(s);
6.2.4 Supplying Our products and/or services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalizing and tailoring Our products and/or services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by sending us an email opting out;
6.2.8 Market research;
6.2.9 Analyzing your use of Our Site(s) and gathering feedback to enable Us to continually improve Our Site(s) and your user experience.
6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and/or telephone, text message, or post with information, news and offers on Our products/services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore only be retained for the prescribed period in consideration of the laws concerning record recording obligations or shorter if required under this policy. As a default under GDPR We do not envisage keeping any date longer than the 6 year standard period as prescribed by company legal record legislation.
7. How And Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Depending upon your location Your data will only be stored in either the USA or in Europe as made necessary by the services being provided.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site(s).
7.4 Our Site(s) are not directed at or intended to be used by children under the age of 18. We do not collect or process any personal information directly from children under the age of 18. We will never use or disclose any personal information of a child under the age of 18 for marketing or advertising purposes.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.3 We may compile statistics about the use of Our Site(s) including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
UK & Europe
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10.3 As a citizen in North America you may have rights under individual state laws as further set-out either herein or in statute. As already mentioned the CCPA does not apply to Hanzo formally but typically as an ethical international business we comply with many of its provisions.
10.4 Furthermore, a number of third-party services exist that may supplement the protection of your privacy both online and through paper/telephone services. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right To Withhold Information
11.1 You may access certain areas of Our Site(s) without providing any data at all. However, to use all features and functions available on Our Site(s) you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Usually in Europe, under GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
13.2 All Cookies used by and on Our Site(s) are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a notice with opt-in action requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site(s) may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
13.4 Certain features of Our Site(s) depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site(s) may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following first party Cookies may be placed on your computer or device:
__hs_do_not_track This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot. (Expires: 2 years)
__hs_testcookie This cookie is used to test whether the visitor has support for cookies enabled. (Expires: Session cookie)
hs_ab_test This cookie is used to consistently serve visitors the same version of an A/B test page that they’ve seen before. (Expires: Session cookie)
hs_lang_switcher_choice This cookie is used to consistently redirect visitors to the language version of a page in the language they’ve selected on this top-level private domain in the past (if such a language version exists).
<id>_key When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login. The cookie name is unique for each password-protected page.
hs-messages-is-open (TTL 30 minutes) This cookie is used on the visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity
hs-messages-hide-welcome-message (TTL 1 day) When you dismiss the welcome message in your messages tool, a cookie is set to prevent it from appearing again for one day.
13.6 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.8 The analytics service(s) used by Our Site use(s) the following Cookies:
__hstc The main cookie for tracking visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). (Expires: 2 years)
hubspotutk This cookie is used for keeping track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts. (Expires: 10 years)
__hssc This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. (Expires: 30 min)
__hssrc Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session. (Expires: None. Session cookie)
messagesUtk This cookie is used to recognize visitors who chat with via the messages tool. If a visitor leaves the site before they are added as a contact, they will have this cookie associated with their browser. If a chat history exists with a visitor and they return to the site later in the same cookied browser, the messages tool will load conversation history with that visitor.
14. Contacting Us