Privacy Policy

1. Introduction

This Privacy Policy sets out how Honne Technologies Ltd uses and protects your personal data. Honne Technologies Ltd respects your privacy and is committed to protecting your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data when you use our software system (the “Software”, “System”, or “App”) to make bookings for services provided by third-party suppliers (the “Supplier”). By using the Software, you agree to the terms of this Privacy Policy. If you do not agree with these terms, please do not access or use the Software.

Controller

Honne Technologies Ltd is the controller and responsible for your personal data (collectively

referred to as “we”, “us” or “us” in this privacy policy).

2. Information We Collect

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together under the following types of personal and non-personal information collected when you use the Software:

a. Personal Information

  • Contact Information: Your name, title, date of birth, email address, phone number, and other contact details;
  • Booking Information: Details about the services you book through the Software, including the date, time, and Supplier associated with your booking;
  • Payment Information: Payment details such as credit card information or other payment method details required to process bookings. Payments are typically processed by the Supplier or a third-party payment processor.

b. Non-Personal Information

  • Usage Data: Information about your interactions with the Software, including activity logs, log-in and log-out time, your IP address, cookies, and analytics; 
  • Device Information: Data about the device you use to access the Software, such as device model, operating system version, and unique device identifiers.
  • Technical Data: includes internet protocol (IP) address, login data, browser type and version, time setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use in using the Software.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

a. Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you use the software which may include:

making bookings;

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us feedback or contact us.

b. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4. How We Use Your Information

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

a. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

b. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

c. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

d. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below a description of the ways we plan to use the various categories of your personal data and the legal bases we rely on to do so.

a. To provide and maintain the Software: Ensuring the functionality of the Software, processing transactions, and improving user experience. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our software updated and relevant, to develop our business and to inform our marketing strategy.

b. To Facilitate Bookings: We collect and share relevant information with the Supplier to confirm and manage your bookings. This is for the performance of a contract with you, is necessary to comply with a legal obligation and is necessary for our legitimate interests (to keep our records updated and manage our relationship with you).

c. To Communicate with You: We use your contact information to send booking confirmations, updates, and support communications. This is for the performance of a contract with you, is necessary to comply with a legal obligation and is necessary for our legitimate interests (to keep our records updated and manage our relationship with you).

d. To Process Payments: Your payment information is used to complete transactions related to your bookings. Payment details are typically handled by the Supplier or a third-party payment processor. This is for the performance of a contract with you, is necessary to comply with a legal obligation and is necessary for our legitimate interests (to keep our records updated and manage our relationship with you).

e. To Improve the Software: We analyse usage data to understand user behaviour and improve the functionality and performance of the Software. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

f. To Comply with Legal Obligations: We may use your information as necessary to comply with applicable laws and regulations.

5. Sharing Your Information and Disclosure of Your Personal Data

We do not sell your personal information to third parties. However, we may share your information in the following ways:

a. With Suppliers: When you make a booking, we share your contact and booking information with the relevant Supplier to confirm and fulfil your reservation.

b. With Service Providers: We may share information with third-party service providers who assist in operating the Software (i.e.: hosting, analytics, payment processing). These providers have access to your information only to the extent necessary to perform their services.

c. For Legal Purposes: We may disclose your information if required by law, regulation, or legal process, or in response to a valid request from law enforcement or other authorities.

6. Third-Party Suppliers

Please note that when you book services through the Software, the actual service is provided by a third-party Supplier, not us. This means the Supplier may have its own privacy practices and policies regarding how it handles your data. We recommend reviewing the Supplier’s privacy policy before completing a booking.

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.

7. Payment Information

When you make a booking that requires payment, your payment information is processed securely by a third-party payment processor or the Supplier directly. We do not store your payment details, but we facilitate the transfer of payment information to the relevant third-party payment provider or Supplier.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Once your personal data is no longer needed, we securely delete or anonymise your data.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see paragraph 10 below for further information.

9. Security of Your Information

We take reasonable measures to protect your personal information from unauthorised access, alteration, disclosure, or destruction. 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. However, no data transmission over the internet or storage system can be guaranteed to be 100% secure. We cannot guarantee the absolute security of your information.

10. Your Data Protection Rights
You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

a. Request access to your personal data (commonly known as a “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.

b. 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.

c. Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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, at the time of your request.

d. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

e. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

f. Request the transfer of your personal data to you or to a third party. 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.

g. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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.

To exercise these rights, please contact us at team@honne.io. We may ask for verification of your identity before processing your request.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

11. International Data Transfers
If you access the Software from outside Northern Ireland, please be aware that your personal information may be transferred to, stored, or processed in other countries where we or our service providers operate, where data protection laws may differ. By using the Software, you consent to such transfers, which are conducted in compliance with applicable data protection laws. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring safeguards are in place in that we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

12. Children’s Privacy
The Software is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that a child under the age of 18 has provided personal information, we will delete such data immediately.

13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. It is your responsibility to review this policy periodically to stay informed about how we protect your information.

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, for example a new address or email address.

14. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal information, please contact us at:

  • By Post to: Honne, 37 Letter Road, Aghnablaney, Leggs, Enniskillen, Fermanagh, BT93 2BB
  • By Email to:  team@honne.io