Privacy Policy

Defined terms

Howamigoing or we or us means How Am I Going Ltd, a limited company registered in England and Wales under company number 09616647, and the owner and operator of Our Site.

Our Service means the provision of an online feedback platform that enables you to give professional feedback to and receive professional feedback from other people, as set out in our Terms of Use.

Our Site means the website howamigoing.com and any related subdomains, services, tools or applications provided by us.

you the reader of this document.

 

Privacy Policy

This document sets out how we will process personal data we collect from or about you, or which you provide to us (the Privacy Policy).

Please read this Privacy Policy carefully to understand why data is being collected and what we do with that data.

We may change the Privacy Policy from time to time by amending this page.

For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Howamigoing.

Where we hold your data as a result of your employer making use of Our Service, the data controller is your employer.

 

What type of information will we collect from you?

The personal information we collect from you will typically include the following:

• Contact details (including your name and work email address) and any other information you choose to provide us when using our service (your Contributions as set out in our Terms of Use)
• Feedback data, including scores, ratings and textual comments relating to professional performance, provided by yourself as part of a self-assessment and provided by people you request feedback from as part of a peer-assessment (your Feedback as set out in our Terms of Use)
• Conversations with us, including a record of the email or telephone correspondence created when you contact Howamigoing as part of a product or service query
• Details of visits to Our Site (which enable Our Site to remember information about you and your preferences) and use of Our Site.  Please read our Cookie Policy for further details. This may include information about your visit, including the full Uniform Resource Locators, clickstream to through and from Our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

 

Information we collect about you from others

Information about you will be passed to us from your selected work colleagues via an online feedback form, such as their opinions on your professional performance.

Information about you may also be passed to us from your employer as part of our client onboarding process (where your employer has requested use of Our Service) in which case the data controller is your employer and we are appointed to carry out Our Service on behalf of your employer as their data processor. This information will typically be your name, work email address, job title and location.

 

On what basis can we process your information?

The legal grounds for processing your personal data are as follows:

• It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, namely in order for us to provide you and / or your employer with Our Service, as set out in our Terms of Use.
• You have given us consent to the processing of your personal data for one or more specific purposes, including direct marketing.
• It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests include the promotion of Our Service and those of other organisations.

 

Information collected from you about other people

We may ask you to provide us with contact details of the persons you nominate to provide you with professional feedback, as a necessary part of using Our Service. Those details will only be used to request feedback from those persons and will not be shared with any other organisations.

 

What are we going to do with your information?

We will hold and use personal information about you in the following ways:

• In order to provide you and (where your employer has requested use of our services) your employer with our feedback services, your information will be processed to:
• create an online feedback form for other individuals to provide professional feedback as requested by you or your employer,
• collect, display and analyse the professional feedback provided by you or by those from whom you have requested.
• Communicate with you during the course of providing Our Service, for example with your enquiries and requests.
• Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future.
• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, unless we have your prior consent to contact you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
• Track your use of Our Service including your use of Our Site, completion of surveys via Our Site in order to personalise your repeat visits to Our Site and to administer and improve these.
• To notify you about changes to Our Service.
• To ensure that content from Our Site is presented in the most effective manner for you and for your computer.
• Respond to any complaint against us.

 

How long will we keep your data for?

We will retain your personal data for three years or until such time as you or your employer asks us to delete your data or where you withdraw any consent you have given us to process your data.

 

Who will your information be shared with?

In order to provide you with Our Service we will pass your information contained in online feedback forms to other individuals . We may also share your feedback with other personnel within your company where your employer has requested use of Our Service.

We will pass your details to the following organisations (our “data processors”) who require it to carry out certain activities on our behalf as part of our providing Our Service: Jensen Technologies SL, who provide IT services, and where we appoint other data processors, for example, sub-contractors in advertising networks, analytics providers and search information providers we will notify you in this Privacy Policy of the names of those organisations.

We will also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If our company or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We will not share your information with third parties for marketing purposes other than in accordance with this Privacy Policy (as described above in What are we going to do with your information?)

 

Security of your data

Your data will be held on secure servers within the European Economic Area ("EEA") with all reasonable technological and operation measures put in place to safeguard it from unauthorised access.  Where possible any identifiable information will be encrypted or minimised.

If we have given you a personal username and password which enables you to access certain parts of your account on our systems, you are responsible for keeping it confidential. Please do not share it with anyone.

 

Measures when transferring your data to others

There may be occasions where we need to send your data outside the EEA. This would cover situations where we need to deal with international aspects of your account and instruct overseas organisations to assist.

Some organisations may be located in countries outside of Europe where data protection laws are not as strict as they are in the UK. Where your personal data is being transferred outside the EU, we will undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information.

 

How can you access and update your information?

You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to [email protected]

 

How you can object to us using your data

You can ask us to limit the way in which we are using your information or object to certain types of processing. We will do our best to comply with your request unless we have to use the information for legitimate business or legal purposes.

Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.

Any queries or concerns about the way in which your data is being used can be sent to [email protected]

 

Moving your information to another organisation

You have the right to request that we send a copy of the personal data we hold about you to another organisation for your own purposes, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information to another organisation please let us know at [email protected]  We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

 

How can you withdraw your consent?

You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can contact us at any time via email to [email protected]. Where we hold your data as a result of your employer making use of Our Service for which they are the data controller, we will notify and require approval from your employer before deleting your data.

 

Complaints about the use of your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by writing to [email protected]

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office.  Further details can be found at www.ico.org.uk or by calling 0303 123 1113.