Privacy Policy

This privacy policy (hereinafter the “Privacy Policy“) details the way in which the company Herta UK Ltd. (hereinafter, “Herta“), a company with registered office at 16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH and registered in the Companies House under number 13932742 collects and processes personal data of users (hereinafter the “Users“, “You“, “Your“) for the following purposes:

  • visit or use the features and services offered on the Herta website accessible from the URL address (hereinafter the “Site“);
  • visit or use Herta social media applications;
  • customer relations: consumer services, events at points of sale, events organized by Herta.

Constitutes personal data any information relating to the User, a natural person identified or who can be identified, directly or indirectly, by reference to an identification number or to one or more elements which are specific to this person (hereinafter referred to as “Personal Data“).

Herta respects the right to privacy of Users by complying with current legislation.

This Privacy Policy explains to You how Your Personal Data is collected, used and possibly transmitted to third parties by Herta (“Herta“, “We“, “Us“, “Our“). It also describes how You can access and update Your Personal Data and make certain choices about how it is used.

Sources of personal data

The Policy applies to Personal Data that we obtain from or about You, through the methods described in Question #2 – “What Personal Data do we collect and how?”, from the following sources:

  • Website: the online sites that we operate under Our own domain names/URLs and the mini-sites/pages/accounts that we have created on third party social networks such as Facebook (the “Websites”).
  • Emails, text messages and other electronic messages: this includes electronic communications exchanged between You and Herta.
  • Consumer services: any communication on your part with Our consumer service (letters, calls, emails).
  • Offline registration forms: printed or digital registration forms and other similar types of forms through which we collect Personal Data from consumers, by mail, during in-store events or as part of other events.
  • Advertising interactions: interactions with the advertising banners of Our brands (for example if You interact with one of Our advertising banners on a third party site, We may receive information about this interaction).
  • Data from other sources: information about You that we collect through social networks (for example Facebook or Google), market research (when the responses are not anonymized), Herta’s promotional partners, from public sources, etc,.

What Personal Data do we collect and how?

Depending on how you interact and communicate with Herta (online, offline, by telephone, etc.), We may collect different types of information from You as described below:

  • Personal contact details: this includes any information You give to Us so that We can contact You personally, such as Your name, postal address, email address or telephone number.
  • Demographic information and interests: this is information about Your demographic or behavioral characteristics. This includes, for example, your date of birth, your age, where you live (e.g. your postcode), your favorite products, your hobbies and interests as well as information about your household and lifestyle.
  • Website Usage/Interaction Information: When You browse and interact with Our websites or Our newsletters, we use automatic data collection technologies to collect certain information relating to Your actions. This includes information such as which links You click, which pages or content You view and for how long, and other similar information, as well as statistics about Your interactions such as content response times, download errors and duration of visits to certain pages. This information is captured using automated technologies such as cookies (browser cookies, flash cookies) and web beacons, and is also collected using third-party tracking devices.
  • Market research and consumer feedback: this includes information that You agree to share with us about your experience as a User of Our products and services.
  • Calls to Consumer Service: Communications with our consumer service can be recorded or listened into, in accordance with applicable laws, for local operational needs (e.g. for quality or training purposes).

What uses do we make of Your Personal Data?

You will find in the table below the list of purposes pursued by Herta when collecting and processing Your Personal Data and the different types of Personal Data that are collected for each purpose. Please be aware that some of the uses listed below may not apply to some people.

What uses?

Principles on which this use is based

Consumer services and/or customer relations center: We use Your Personal Data to respond to Your requests. This involves knowing certain personal contact details and information relating to the nature of your request (order status, technical problem, question/complaint about a product, general question, etc.).

  • Compliance with Our contractual obligations
  • Legal obligations
  • Our legitimate interests

Marketing communications, games, competitions and other promotions: with your consent we use Your Personal Data to provide You with information about Our products or services (for example, as part of marketing or promotional communications/campaigns).

  • Your consent
  • Compliance with Our contractual obligations
  • Our legitimate interests

Third-party social networks: We use Your Personal Data when You use third-party social network functions, such as the “Like” function, in order to serve You advertisements and interact with You on these third-party social networks. To learn more about how these features work, the profile data We obtain about You and how to opt out of this use of Your Personal Data, you should read the privacy policies of the relevant third-party social networks.

  • Your consent (where necessary)
  • Our legitimate interests

Other general uses (internal study or market study, analysis, security, etc.): In accordance with applicable laws, we use Your Personal Data for other general commercial purposes, in particular to carry out internal studies or market and measure the effectiveness of Our advertising campaigns. We also use Your Personal Data to ensure the security of Our operating systems, Our networks and security systems.

  • Compliance with Our contractual obligations
  • Your consent (when necessary)
  • Legal obligations
  • Our legitimate interests

Does Herta disclose Your Personal Data and why?

We may share Your Personal Data with different groups of third-party companies:

Service providers: these are external companies that we use to help us carry out our activities (identity verification, operation of the Site, market research, assistance services, management of promotions, development of the Site, analysis of data, consumer services and/or customer services, etc.). These service providers, and certain members of their staff, are authorized to use Your Personal Data on Our behalf only for the specific tasks for which they have been requested, following Our instructions, and are required to protect the confidentiality and security of Your Personal data.

Third party companies using Personal Data for their own marketing purposes: except where You have given your consent, we do not sell Your Personal Data to third party companies for their own marketing purposes. If applicable, the identity of these third party companies will be communicated when your consent is requested.

How long will Your Personal Data be kept?

Your Personal Data will be retained by Herta only for as long as is reasonably necessary for the purposes described in this Policy and for the period permitted by applicable laws.

On this regard, HERTA will retain copies of your Personal Data in a form that allows for identification only for as long as:

  • We maintain an ongoing relationship with you (e.g. where you are included in our mailing list and have not unsubscribed);
  • Your Personal Data are necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,

The duration of:

  • any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and
  • an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who may bring a claim at the end of the applicable period),

In addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional time necessary in connection with that claim.

Beyond the retention periods mentioned above, Your Personal Data will either be securely deleted from all Herta databases or anonymized.

How does Herta store and/or transfer Your Personal Data?

We use all necessary technical and organizational measures to guarantee the confidentiality and security of Your Personal Data. Please note, however, that these measures do not concern the information that You choose to share in public spaces, in particular on third-party social networks.

Persons with access to Your Personal Data: Your Personal Data will be processed by Our staff or Our dedicated service providers, and only for the purposes which were described to You when Your Personal Data was collected.

Measures taken in operating environments: We store Your Personal Data in operating environments where appropriate security measures are implemented to prevent unauthorized access. We comply with applicable standards to protect Your Personal Data. Unfortunately, the transmission of information via the Internet cannot be completely secure, and although we make every effort to protect Your Personal Data, we cannot guarantee the security of Your data during transmission via Our websites or applications.

Transfer of your Personal Data: Because of the international nature of our business, we may need to transfer your personal data within the Herta group.

What are Your rights and how to exercise them?

Access to Your Personal Data: You, Your descendants, representatives and/or agents have the right to access, consult and request a physical or electronic copy of the information. You also have the right to request information about the origin of Your Personal Data.

You can exercise these rights:

We will ask You to attach to Your request a copy of Your identity document or any other proof of identity. If the request is submitted by someone other than You, without proof that the request is legally made on your behalf, the request will be rejected.

Please be aware that any identifying information provided to Us will be processed only in accordance with, and to the extent permitted by, applicable laws.

Other rights (e.g., modification or deletion of Personal Data): You, Your descendants, representatives and/or agents may (i) request the deletion, portability, rectification or modification of Your Personal Data; (ii) Object to data processing; (iii) limit the use and disclosure of Your Personal Data; and (iv) withdraw Your consent to any of Our processing activities of Your Personal Data.

Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.

We hope to be able to answer any questions and queries You may have regarding how We process Your Personal Data. However, if We are unable to allay all Your fears, You also have the right to file a complaint with the competent data protection authorities.

Who are the data controllers and how can I contact them?

To ask questions, share Your comments about this Policy and Our practices regarding the protection of Personal Data, or to file a complaint for non-compliance with the privacy laws in force, You can contact Our data protection officer by e-mail at the following address:

We will process and investigate any complaints relating to how We manage Your Personal Data (including a complaint that We have infringed Your rights under applicable privacy laws).