hackworth :

Data processor registry

You have a right to be informed about how we process your personal data. One of our core organizational values is transparency, and in that spirit, we attempt to go above and beyond the required level of detail when we tell you how your data are used.

This page serves as a registry of every third-party data processor ("service provider") whose services we use when processing your personal data. For each processor, we include all of the ways in which we process your data with that service provider, the purposes of the processing, under what lawful basis we justify its use, details about whether your data may be transferred outside the UK or EEA (and, if so, how it is protected), the retention period, how to withdraw your consent (and whether it's applicable), and more.

In some cases, we may use the same service provider for processing different personal data, potentially under a different lawful basis, with a different retention period, etc. When this happens, we will create a distinct entry in the registry for each type of processing we perform using that provider's services.

When possible, we will provide links to our data processing agreements (DPAs) with these service providers, in addition to any relevant documentation from the service provider about how your data is processed, how international transfers are protected, etc. (Note that these are third party links. We are not responsible for their accuracy, and they are provided on a best-effort basis.)

We will keep this page up to date as our processing needs change and we add or remove service providers. We will note, for each provider, when we last updated the information in the registry, so that you may be informed when we make such changes.

We hope this level of transparency helps inform your choices about what personal data you wish to share with us.

Service providers who do not process personal data

You may notice that our Cookie Policy mentions some third-party cookies that we use from providers who are not listed in this registry (for example, LinkedIn). In these cases, these are either service providers whose cookies do not collect any personal data, or for whom we are not the data controller, meaning that they do not share any personal information they collect from you with us. As these service providers do not serve as data processors for us, they don't appear here in the data processor registry.

Contact us

If you have any questions about this registry, or if you believe any of the information listed here to be insufficient or incorrect, please contact us at [email protected].

Google Cloud EMEA Limited (email)

We use Google Cloud EMEA Limited ("Google") for transactional email services.

Who is the controller? Hackworth Ltd
Who are the recipients of the data? Hackworth Ltd
What is the purpose of the processing?

Google are our email provider. When you send us email to ask a question, request information, or inform us of a problem or issue (transactional email), we use Google's email service to read and, if necessary, reply to your email.

What is the lawful basis of the processing?

Legitimate interests: we have a legitimate interest to provide you with good service, and you have a legitimate interest in receiving prompt and accurate assistance.

Is data transferred outside the UK or EEA?

In some cases, yes. Our data processing agreement (DPA) with Google states that Google will ensure that when data is transferred, it will be transferred either to a country subject to an adequacy decision, or else using appropriate safeguards.

What is the retention period of the data?

At least as long as is required to service the request. We generally delete email once it is no longer needed. We may occasionally keep email for longer if we feel it may be needed at some later date for legal reasons.

Your rights with respect to the processing
  • ✔ Right to be informed
  • ✔ Right of access
  • ✔ Right to rectification
  • ✔ Right to erasure
  • ✔ Right to restrict processing
  • ✘ Right to data portability
  • ✔ Object to processing
How can you withdraw your consent?

Not applicable: consent is not the basis for processing this data.

When was this information last updated? August 29, 2022
Where can you find more information?

Our DPA with Google can be found here: https://workspace.google.com/terms/dpa_terms.html

HubSpot (marketing)

We use HubSpot to process personal data for marketing purposes.

Who is the controller? Hackworth Ltd
Who are the recipients of the data? Hackworth Ltd
What is the purpose of the processing?

We use HubSpot as a customer relationship management system (CRM), which manages the personal data of existing and previous customers, and of individuals who may be interested in our products and services, but who are not yet customers.

When you opt into our collection of your identity, contact, and marketing & communication preferences data through our website, we use this service to send you, by email, marketing information about products, services, and other content that you may be interested in.

What is the lawful basis of the processing?

Consent: you must explicitly opt into this processing by ticking a checkbox and providing the personal data on our website. We will also show you our current Website Privacy Policy when we ask you for this data.

Is data transferred outside the UK or EEA?

In some cases, yes. Our data processing agreement (DPA) with HubSpot states that HubSpot will ensure that when data is transferred, it will be transferred either to a country subject to an adequacy decision, or else using appropriate safeguards.

What is the retention period of the data?

Generally speaking, we retain the data we collect for this purpose until you request that we erase it, at which point we will securely erase it no later than 30 days after we receive your request.

We may periodically review the data we collect for this purpose and delete it if we feel there is no longer any lawful basis upon which to justify storing it.

Note that when you object to this processing of your data or otherwise withdraw your consent, we will stop using it for the purposes of marketing, but we may suppress, rather than erase, your data such that we retain enough of it to ensure that you do not receive marketing communications in the future.

Your rights with respect to the processing
  • ✔ Right to be informed
  • ✔ Right of access
  • ✔ Right to rectification
  • ✔ Right to erasure
  • ✔ Right to restrict processing
  • ✔ Right to data portability
  • ✔ Object to processing
How can you withdraw your consent?

You can withdraw your consent at any time by clicking on the "unsubscribe" link that we include in every email we send you for this purpose.

When was this information last updated? August 29, 2022
Where can you find more information?

Our DPA with HubSpot can be found here: https://legal.hubspot.com/dpa

HubSpot (tracking)

We use HubSpot to process personal data for tracking your use of our websites.

Who is the controller? Hackworth Ltd
Who are the recipients of the data? Hackworth Ltd
What is the purpose of the processing?

We use HubSpot as a customer relationship management system (CRM), which manages the personal data of existing and previous customers, and of individuals who may be interested in our products and services, but who are not yet customers.

When you give your consent by opting into our collection of your identity, contact, and marketing & communication preferences data through our website, and you also give your consent by opting into the HubSpot cookies we use on our website, HubSpot can associate your activity on our websites with your contact data to create a profile about your interests with respect to which of our products, services, and other content you may be interested in.

We use this data to develop our products and services to better serve your needs, which helps us grow our business.

What is the lawful basis of the processing?

Consent: you must explicitly opt into this processing by ticking checkboxes for the HubSpot cookies we use on our websites, where applicable. See our Cookie Policy for details.

Is data transferred outside the UK or EEA?

In some cases, yes. Our data processing agreement (DPA) with HubSpot states that HubSpot will ensure that when data is transferred, it will be transferred either to a country subject to an adequacy decision, or else using appropriate safeguards.

What is the retention period of the data?

Generally speaking, we retain the data we collect for this purpose until you request that we erase it, at which point we will securely erase it no later than 30 days after we receive your request.

We may periodically review the data we collect for this purpose and delete it if we feel there is no longer any lawful basis upon which to justify storing it.

Note that if you have previously consented to our processing of this data by opting into the HubSpot cookies on our websites, and then you later withdraw your consent by opting out of the HubSpot cookies, this does not erase or otherwise restrict our processing of any data we may have collected for these purposes prior to your opting out of the cookies — it only means that we will not collect any additional data from that point, so long as you are still opted out of the cookies. If you would like us to erase or otherwise stop processing the previously-collected data, please make an erasure or restriction request.

Your rights with respect to the processing
  • ✔ Right to be informed
  • ✔ Right of access
  • ✔ Right to rectification
  • ✔ Right to erasure
  • ✔ Right to restrict processing
  • ✔ Right to data portability
  • ✔ Object to processing
How can you withdraw your consent?

You can withdraw your consent at any time by removing or opting out of the HubSpot cookies on our websites. See our Cookie Policy for details.

When was this information last updated? August 29, 2022
Where can you find more information?

Our DPA with HubSpot can be found here: https://legal.hubspot.com/dpa

For more information on how HubSpot track personal data via your browser, see here: https://knowledge.hubspot.com/account/how-does-hubspot-track-visitors

Please also see our own Cookie Policy for details of what specific HubSpot cookies we set on our websites.

Momentive

We use Momentive's SurveyMonkey service to process personal data for surveys.

Who is the controller? Hackworth Ltd
Who are the recipients of the data?

Hackworth Ltd and, if you are participating in a survey with a prize or other incentive to participate and consent to it, a third party (to be named specifically in the terms and conditions of the survey), who will receive your contact details for the purposes of processing your prize or incentive.

What is the purpose of the processing?

We use SurveyMonkey to gather and process responses to surveys that we may run from time to time on our websites. We use the data from these surveys to understand our customers' (and potential customers') needs — in the aggregate — as they relate to our products and services.

Any aggregated data we create and process as a result of personal data submitted to us in a SurveyMonkey survey is anonymized such that all personally identifying information is removed from the aggregated data. The aggregated data cannot be used to identify any individual. For example, the aggregated data may contain such information as, "20% of our respondents use Python to teach programming in their classrooms."

If, in addition to having given your consent for us to use your survey responses to create aggregated data, you also consent to a subsequent 1-to-1 personal interview with us, we may also use any identity and contact data that you provide as part of the survey to contact you to arrange such an interview. Any personal data collected during that interview will be processed according to the terms and conditions of that interview, which will be provided to you prior to the interview, but in general, that data will not be subject to the terms of this data processor (Momentive).

If the survey includes a prize or other incentive, then we will also, only after having received your explicit consent, provide your contact details to a specified third party for the purposes of processing the delivery of your prize or incentive. In these cases, we will take all reasonable measures to ensure that the third party does not use your contact details for any other purpose, but in general this will be subject to the privacy policy and terms of service of that third party, which you should review before consenting to the prize or incentive.

What is the lawful basis of the processing?

Consent: you must explicitly opt into this processing by ticking a checkbox(es) indicating that you have read our Website Privacy Policy and the terms and conditions of the survey, including any sharing of your contact details with any specific third parties we use to process prizes or incentives, if applicable.

Your consent will also not be given unless you explicitly opt into SurveyMonkey's cookies, which are used to track your responses and to ensure that you only participate at most once in a given survey.

Is data transferred outside the UK or EEA?

Probably yes. Momentive's guidance to its data controllers indicates that "most European customer data lives on servers in the US" (see https://help.surveymonkey.com/en/policy/data-processing-agreements-eu/#storage). However, when they store personal data in the US, they use the Standard Contractual Clauses (SCCs) and other appropriate safeguards to transfer the data there, as permitted by the GDPR. (See https://help.surveymonkey.com/en/policy/data-processing-agreements-eu/#agreement.).

What is the retention period of the data?

We will retain the personal data collected during these surveys for at most 30 days after the survey is finished, at which point we will securely erase it.

Your rights with respect to the processing
  • ✔ Right to be informed
  • ✔ Right of access
  • ✔ Right to rectification
  • ✔ Right to erasure
  • ✔ Right to restrict processing
  • ✘ Right to data portability
  • ✔ Object to processing
How can you withdraw your consent?

You can withdraw your consent at any time before submitting your survey results by not finishing the survey, and opting out of and/or removing SurveyMonkey's cookies, which will remove from your browser state any responses you have provided thus far. See SurveyMonkey's cookie policy for details: https://www.surveymonkey.com/mp/legal/survey-page-cookies/

If you have already completed the survey and you wish to withdraw your consent after the fact, you can contact us at any time and inform us that you with to withdraw your consent. We will then securely erase your personal data no more than 30 days after you have informed us of your wish to withdraw consent.

Please note that if you have opted into receiving any incentive or prize as a result of completing the survey, we reserve the right not to send you this incentive or prize in the event that you withdraw your consent, per the terms and conditions of the survey.

When was this information last updated? August 29, 2022
Where can you find more information?

Our DPA with Momentive/SurveyMonkey can be found here: https://www.surveymonkey.com/mp/legal/data-processing-agreement/

Momentive's specific information on international transfers can be found here: https://help.surveymonkey.com/en/policy/data-processing-agreements-eu/#storage

When the SurveyMonkey survey is not hosted directly on one of our websites, but instead via a link from one of our websites to SurveyMonkey's own site, you should read SurveyMonkey's survey page cookie policy, which can be found here: https://www.surveymonkey.com/mp/legal/survey-page-cookies/

Finally, when participating in one of our surveys, you should read that survey's separate terms and conditions, which will be provided to you when you consent to participating.