The Honourable Artillery Company or Armoury House, City Road, London EC1Y 2BQ (HAC) is committed to doing the right thing in how we collect, use and protect your personal data. The HAC is the ‘data controller’, referred to in this policy as ‘the HAC’ ‘we’ or ‘us’, This Privacy Policy:

• Sets out what personal data we may collect from you
• Explains why and how we use your personal data
• Explains who your personal data might be shared with
• Explains how long we might keep your data for
• Explains how we keep your data safe
• Explains your rights and choices in relation to your personal data

Contents

1. When does this Policy apply to me?
2. What data do we process?
3. Why do we process your data?
4. Your Rights
5. Who do we share your data with?
6. How long do we keep your data for?
7. How do we keep your data secure?
8. CCTV, photographs and security searches
9. Website and Social Media
10. Our Data Protection Officer
11. Changes to this Policy

Definitions

‘Personal Data’: information capable of and used to identify an individual;
‘Data Processing’: any activity carried out using personal data (including storage);
‘Data Subject’: the individual to whom the personal data pertains;
‘Data Controller’: the organisation (or individual) who collects and processes your personal data;
‘Data Processor’: a third party individual or organisation that may carry out processing activities on behalf of the Data Controller.

We may collect and process your data in a number of situations. Whenever we process your personal data, we will do so in accordance with this policy. This policy will apply to you when:

• You apply to become and Member of the HAC or make an enquiry about Membership;
• You become a Member of the HAC (and for the duration of your Membership);
• You become a member of the Regiment (but not a Member of the HAC);
• You become a member of the Special Constabulary or another of the HAC’s affiliated Units, Clubs or Societies (but not a Member of the HAC);
• You are a tenant of the HAC in respect of the property owned by the organisation;
• You use our Website or Social Media sites;
• You visit Armoury House and Grounds and use our facilities during an event, conference or training, either as a Member, a Guest or a Corporate Guest or Client;
• You visit Armoury House and Grounds for work (either for the HAC or for a third party) or to access the VirginOne gym on Bunhill Row;
• You stay at Armoury House in our Member’s Guest Rooms;
• You purchase HAC merchandise either in person, over the phone or online;

The HAC processes information relevant to the purposes described below. This may include:

When you are a Member we may process your:

• personal identifying details, including your name, postal address, email addresses, phone number, date of birth and title;
• marital status and family details;
• lifestyle and social circumstances
• information relating to your membership of any of the HAC Squadrons, Clubs or Societies;
• employment and education details;
• payment information;
• military service details;
• dietary requirements in relation to dining or taking refreshment at Armoury House;
• CCTV footage captured of you when you visit Armoury House and Grounds.

Some or all of this may be Special Category Data, subject to additional regulation, which we process for the purpose of administering your membership.

When you are not a Member, but contact us or visit Armoury House and Grounds we may process:

• your personal identifying information, including your name, postal address, email addresses, phone number, date of birth and title;
• information relating to your employment including the name of your employer, your job title and your work contact details;
• information relating to your membership of any club, society or organisation affiliated to the HAC or through whom your visit has been arranged;
• information about your attendance at particular events at Armoury House or Grounds;
• information relating to any dietary requirements you may have where you dine or take refreshments on the premises;
• CCTV footage captured of you when you visit Armoury House and Grounds.

When you are a tenant of the HAC in any of the properties owned and/or managed by the HAC we may process:

• your personal identifying information, including your name, postal address, email addresses, phone number, date of birth and title;
• information relating to your employment including the name of your employer, your job title and your work contact details;
• information relating to the payment of rent and other charges in connection with the use of the property;
• information relating to tenancy or agency references and credit/background checks.

When you use our Website (www.hac.org.uk) or our social media sites we may process:

• Information about your online browsing behaviour on our Website;
• Information about any devices you may have used to access our Website or Social Media sites, including the make, model, operating systems, IP address, browser type and mobile device identifiers.

This section explains in detail how and why we use personal data. We use personal data to:

Administer your Membership
When you apply to become a Member of the HAC or make an enquiry to become a Member, we will need to process certain of your personal data in order to be able to provide you with information about the Membership and your eligibility to join.

When you are admitted as a Member, we will need to process your personal data in order to be able to:

• Administer your Membership and process subscriptions;
• To promote and enable communication with and between our Members;
• To fulfil our Members’ role as advocates for Defence;
• To fundraise for the Charity and its charitable causes and to encourage donations and legacies;
• For the administration of Membership elections;
• To communicate Company updates regarding the governance and administration of the HAC;
• To communicate Company information regarding Membership events;
• To administer gym membership;
• For the administration of HAC Sports Clubs, Societies, Squadrons and other activities;
• to distribute publications and administer our website (including the Membership secure pages);
• to administer activities and the use of the property by members of the Regiment who are not members of the HAC;
• to sell merchandise;
• to assist the Regiment with the administration of their records for their purposes where appropriate for individual members;
• to maintain our own accounts and records;
• to archive permanently for purposes of the Company’s historical record and corporate memory and to answer historical enquiries from members of the public;
• to support and manage our staff and volunteers;
• to maintain security at Armoury House and grounds and at other such locations as may be used by the HAC in its official or ceremonial activities.

Administer your Membership of HAC Clubs and Societies
When you are a member of one of the HAC Sports Clubs, other clubs or Societies, it may be the case that you are not also a Member of the HAC. In that case we may need to process your personal data for the following reasons:

• To administer your membership of the Club or Society you have joined;
• To process subscriptions or other payments;
• To communicate information about the activities of the Club or Society, to distribute publications and administer the relevant sections of the HAC website in connection with the Club or Society you have joined;
• For the administration of the appointments or elections within the Club or Society you have joined;
• To maintain our own accounts and records;
• To support and manage our staff and volunteers;
• To maintain security at Armoury House and grounds and at other such locations as may be used by the HAC in connection with the activities of the Club or Society that you have joined.

When you are a tenant of the HAC
When you are a tenant of the HAC we may need to process your personal data in order to be able to:

• Enter into a tenancy agreement or licence to occupy with you (including taking up references and financial/credit checks);
• Administer and maintain any such tenancy or licence you may have with us;
• Fulfil our obligations in respect of Health, Safety, security and maintenance of any property that you may occupy under any such tenancy or licence you may have with us;
• Process rental payments and/or other charges that may be due under the tenancy or licence you may have with us;
• Communicate with you in relation to your tenancy or licence;
• To maintain security on HAC property;
• To recover any sums due to us or enforce any rights we may have under the tenancy or licence.
  When you visit Armoury House and Grounds
  When you are a Guest or Visitor at Armoury House and Grounds (whether attending at an event, conference or for work), we may need to process your personal data in order to be able to:
• Grant you access to the site;
• Meet our obligations to safeguard your health and safety whilst on site;
• Enable you to access events, conferences, fairs or work events that you may have been invited to attend;
• Maintain security at Armoury House and Grounds.

When you contact us or use our Website
When you contact us via email, telephone, post or in person, or when you use our HAC Website (www.hac.org.uk) we may need to process your personal data in order to be able to:

• Communicate with you and deal with your enquiry;
• Grant you access to our facilities and services;
• Provide you with information about events, products or services that you may have indicated you are interested in;
• Administer and maintain our Website and improve functionality and accessibility;
• Detect potential online security threats that may be posed to our systems and those who access them;
• To gather information about activity on our Website for statistical purposes;
• To prevent inappropriate behaviour on and to protect our staff and other users of our Social Media applications and sites.

WE DO NOT USE AUTOMATED PROFILING OR DECISION MAKING IN RESPECT OF ANY PERSONAL DATA THAT WE PROCESS

Under Data Protection Legislation (including the General Data Protection Regulation 2018 and the Data Protection Act 2018), as a Data Subject you have a number of rights. We have listed an overview of your rights below:

Access to your personal data. You have the right to request a copy of the information that we hold about you. You are entitled to be given a description of what information we hold about you; what we use it for and who we might pass it on to. We are required to answer your request within one month of its receipt at the latest, and occasionally may then need to ask for an extension. We may need to carry out additional identity checks before we release your personal data to you. In most circumstances we will not charge a fee when you wish to access your information. If you would like a copy of the personal data we hold about you, please write to the Data Protection Officer, contact details as below.

Accuracy. We want to make sure that the personal information we process about you is accurate and up to date. You may ask us to correct or remove information that you think is inaccurate and in most circumstances we will correct inaccuracies within one month of you informing us. To help us in this, we would ask you please to keep us informed when your details change by writing to us at the address or email address given below.

Deleting personal data, restricting processing activity or objecting to the processing activity. You may ask us to delete the personal data that we hold about you in part or in full. This is sometimes called an ‘erasure request’ or your ‘right to be forgotten’. There are some circumstances in which we cannot delete all personal data (for example where we have a legal obligation to retain it or because we may need it to defend legal claims), but we will always consider such requests on a case by case basis and where we can comply, in most cases complete the deletion within one month of your request.

In addition, you may ask us to restrict or stop some types of processing activities with some or all of your personal data, or you may object to a particular processing activity. For example, if you are a Member you may wish use to stop sending you membership newsletters. You can do this by changing your communication preferences associated with your membership or by writing to us to outline what types of processing you wish us to restrict. Again, please use the address or email address below.

Ask us to transfer or ‘port’ a copy of your data.
This is your right to obtain and reuse your personal data that you have provided to us for your own purposes across different services. There are rules regarding data portability that may restrict us from complying with any request that we receive under this right. If you have any questions about how we can help you achieve data portability, please contact our Data Protection Office using the address or email address below.

Complain to the Information Commissioner
We’d like an opportunity to resolve any complaints that you may have about data processing by the HAC, which you may do by contacting our Data Protection Officer using the address or email address below. However, you also have the right to complain to the UK Data Protection Regulator (currently the Information Commissioner or ‘ICO’) about how we have used your personal data. The ICO website is the best way of finding out how to do this: www.ioc.org.uk

Who has access to it?
We sometimes need to share the personal information we process with the individual themselves and also with other organisations or individuals within the associated Clubs, Squadrons or Societies within the HAC. Where this is necessary we are required to comply with all aspects of the General Data Protection Regulations (GDPR). What follows is a description of the types of people and organisations we may need to share some of the personal information we process.

Sharing data within the HAC.

When you are a Member of the HAC, a member of the Regiment, a member of the Special Constabulary or a member of one of our associated Squadrons, Clubs or Societies, it may be necessary for us to share your personal data with one or more of these groups in order to administer your membership, promote communication and in connection with the other processing purposes listed above. In some cases we may share data with these organisations or individuals who are acting as our ‘Data Processors’: carrying out processing activities on our behalf. In this case we only provide the personal data to our Data Processors necessary to carry out this function.

Examples of our associated Data Processors in this context are the Veteran Secretaries.
Sometimes we may share your data with these organisations or individuals who may be acting as ‘Data Controllers’ in their own right. In the latter case, you may have provided your personal data to us or to the other Data Controller, and any data that is shared between us is limited to that which is necessary to carry out the respective functions of the associated Data Controllers.

Examples of our associated or ‘joint controllers’ in this context are the Pikemen and Musketeers, Light Cavalry, Sports Clubs and others.

Sharing data with organisations or individuals outside the HAC.
As Member or a Guest, when using our services, using our website, contacting us or where you are visiting Armoury House and Grounds or using our Website or services, it may be necessary for us to share your personal data with our service providers (who are our data processors in this context) in order to deliver our services to you (such as the putting on and delivery of particular events), or in order to maintain security at Armoury House and Grounds. We will only provide the personal data to these service providers that enable them to provide their services.

Examples of our service providers/data controllers in this context are our onsite events and catering providers (Searcys), our onsite security providers and others.

Transferring information overseas

We may need to transfer personal data outside the United Kingdom for a number of reasons. This may be because the data processor or service providers that we use are based overseas or use data storage facilities (such as digital servers) overseas, or where you are a Member of the HAC and may be involved with or active in association with the Boston Association, or are involved with the visit to Vittorio Veneto, Sports Club tours and so on.

Where we share your data with our data processors or with other organisations that may involve a transfer of your personal data outside the United Kingdom or outside the European Economic Area, we will restrict the information that we transfer only to that which is necessary to the purpose, we will check the adequacy of the legislation and security of the territory which is the destination in accordance with current UK law, we will put appropriate safeguards in place where necessary or we may decide not to transfer. We will usually inform you separately where such a transfer is likely to happen or is necessary for the service provision that you have requested from us.

How long we keep or ‘retain’ your data for will depend on the reason for which we have collected and processed your data for. We have listed retention periods according the processing activity below. This is not an exhaustive list and if you have questions about data retention you should contact our Data Protection Officer (see below).

We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep your personal data safe. We only authorise access to employees who need it to carry out their job responsibilities and issue guidance and rules to our Data Processors and other Controllers with whom we share your data in order to govern their processing of your data in compliance with our security requirements.

We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you and we may refuse to share your data with third parties who approach us on your behalf until we have satisfied ourselves that there is a lawful purpose for doing so (including having your consent to do so).

Please note that whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us using your own equipment and software.

CCTV
As a secure site, we operate CCTV cameras across Armoury House and the Grounds. We do this in order to monitor the safety and security of our site, detect crime and anti-social behaviour. This means that when you visit Armoury House and Grounds we may capture live or still images of you. Our employees and service providers monitor live images as they are captured on screens within secure locations in Armoury House and the gatehouse, and they may review them after recording. We may share these images with the police or other law enforcement agencies where we are required to do so or to protect you and other visitors to our site. We will retain these images in accordance with our retention policy (see above).

Photographic Identification
We may require you to provide us with photographic identification and may need to issue you with a security pass when you visit Armoury House and Grounds. To do this we may need to take your photograph, which will be stored along with your other personal data for the duration of your visit and then in accordance with our retention policy (see above). We may ask your consent to take your photograph in this way and you may refuse your consent, but this may affect our ability to grant you access to Armoury House and Grounds.

Security searches
As a secure site we may carry out searches of persons, property and belongings in order to monitor and maintain security across the site. We may ask you permission before we carry out a search, but refusing to allow us to do so will affect our ability to grant you access to the site or may result in your being asked to leave the site with immediate effect. We do not routinely record information regarding searches carried out, but we may record information if the search results in evidence that may be required for law enforcement or for the maintenance of security on site.

When you visit our Website (www.hac.org.uk) , either to browse or to access the secure Membership areas, you do so in accordance with our Website Terms and Conditions and we will process any personal data that we collect from your use of our Website according to this Policy. This is limited to the processing that we carry out once we have received your personal data, and not during or as a result of your transmission of that data from your own devices or software.

Our website contains links to other websites. This Policy only applies to our own Website, so when you link to other websites you should read their own privacy policies. We cannot guarantee the security of your personal data when you navigate away from our website to those of third parties.

When you interact with us via our Social Media applications and sites, you may be subject to the rules of usage operated by the service or application provider. If you transmit or provide personal data via Social Media applications or sites, we cannot guarantee the security of that data nor the compliance with Data Protection legislation by the service or application providers. You should check the privacy policy of each provider according to the software or social media that you choose to utilise. Please remember that anything that you ‘post’ on social media is essentially publicly available and we cannot control the access to those platforms that you may choose to use. How we process the data we receive via social media will be governed to an extent by this Policy, but only insofar as we process it for our own purposes. If third parties access your personal data via any of our social media then we are not responsible in law nor otherwise for their processing of your personal data.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.

We have appointed a Data Protection Officer to oversee our compliance with current UK Data Protection legislation and to be our main point of contact in relation to queries from individuals and with the Information Commissioner’s Office (ICO).

Our Data Protection Officer can be contacted by writing to ‘The Data Protection Officer’, Armoury House, City Road, London EC1Y 2BQ or by emailing: privacy@hac.org.uk

We keep our Privacy Policy under regular review and we will place any updates on the Company website and notify members through the Newsletter and Regimental Fire. This Privacy Policy was last updated on 16th September 2019.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.

Cookies are useful because they allow a website to recognise a user’s device.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on this website by category is set out below, with a note as to whether we use them; and then some details of the actual cookies on the site, their purpose, and what to do if you do not consent to any specific cookies being used. Please note however that since we only use cookies where they will be of benefit, any failure to consent may limit your use of this site.

These cookies enable services you have specifically asked for.

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

WE DO USE THIS CATEGORY OF COOKIE ON OUR SITE

These cookies collect anonymous information on the pages visited.

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

By using our website, you agree that we can place these types of cookies on your device.

WE DO USE THIS CATEGORY OF COOKIE ON OUR SITE

You may be able block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our site.

If you do not consent to cookies being placed, you must notify us of the cookies to which you do not consent.

Except for essential cookies, all cookies will expire after twelve months.

Please also see our privacy policy and terms & conditions for further information.

These terms and conditions apply between you, the User of this Website (including any sub-domains, unless expressly excluded by their own terms and conditions), and the Honourable Artillery Company, the owner and operator of this Website. Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website. If you do not agree to be bound by these terms and conditions, you should stop using this Website immediately.

1. The Honourable Artillery Company is a charity registered in England and Wales (no. 208443). It also trades under the business name HAC Enterprises Ltd

1. All content included on the Website is the property of the Honourable Artillery Company, our affiliates or other relevant third parties. Content means any text, graphics, images, audio, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website. By continuing to use this Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner's prior written permission.
2. You may, for your own personal, non-commercial use only, retrieve, display and view the Content on a computer screen
3. You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of the Honourable Artillery Company.

You may not use the Website for any of the following purposes:

1. in any way which causes, or may cause, damage to the Website or interferes with any other person's use or enjoyment of the Website;
2. in any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation or governmental order;
3. making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner.

1. You must ensure that the details provided by you on registration or at any time are correct and complete.
2. You must inform us immediately of any changes to the information that you provide when registering by updating your personal details to ensure we can communicate with you effectively.
3. We may suspend or cancel your registration with immediate effect for any reasonable purposes or if you breach these terms and conditions.
4. You may cancel your registration at any time by informing us in writing to the address on our Contact Us page. If you do so, you must immediately stop using the Website. Cancellation or suspension of your registration does not affect your statutory rights.

1. When you register on this Website, you will be asked to create a password which you should keep confidential and not disclose or share with anyone.
2. If we have reason to believe that there is or is likely to be any misuse of the Website or breach of security, we may require you to change your password or suspend your account.

1. This Website contains links to other sites. Unless expressly stated, these sites are not under the control of the Honourable Artillery Company.
2. We assume no responsibility for the content of such Websites and disclaim liability for any and all forms of loss or damage arising out of the use of them.
3. The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them.

1. Use of the Website is also governed by our Privacy Policy and Cookies Policy.

1. Any online facilities, tools, services or information made available through the WEbsite is provided "as is" and on an "as available" basis. We give no warrant that this will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of the information, compatibility and satisfactory quality. The Honourable Artillery Company is under no obligation to update information on the Website.
2. Whilst we use reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, we give no warranty or guarantee in that regard and all Users take responsibility for their own security, that of their personal details and their computers.
3. The Honourable Artillery Company accepts no liability for any disruption or non-availability of the Website.
4. The Honourable Artillery COmpany reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions apply to any modified version of the Website unless it is expressly stated otherwise.

1. Nothing in these terms and conditions will:
   1. limit or exclude our or your liability for death or personal injury relating from our or your negligence, as applicable;
   2. limit or exclude our or your liability for fraud or fraudulent misrepresentation; or
   3. limit or exclude any of our or your liabilities in any way that is not permitted under applicable law.
2. To the extent that the WEbsite and Content are provided free of charge, we will not be liable to you for any loss or damage of any kind
3. We will not be liable to you in respect of any losses arising out of events beyond our reasonable control.
4. To the maximum extent permitted by law, the Honourable Artillery Company accepts no liability for any of the following:
   1. any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities;
   2. loss or corruption od any data, database or software;
   3. any special, indirect or consequential loss or damage.

1. You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected.
2. These terms and conditions may be varied from time to time. Such revised terms will apply to the Website from the date of the publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version.
3. These terms and conditions together with the Privacy Policy and Cookies Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions.
4. The Contracts (Rights of Third Parties) Act 1999 shall not apply to these terms and conditions and no third party will have any right to enforce or rely on any provision of these terms and conditions.
5. If any court of competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected.
6. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
7. This Agreement shall be governed by and interpreted according to the law of England and Wales and all disputes arising under the Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the English and Welsh courts.