Privacy Policy
Introduction
Harper Stein Limited is committed to safeguarding the privacy of our visitors, our Members and all our users. We collect, use and store personal and sensitive information that you provide to us, in accordance with this Privacy Policy and in the with GDPR.
This policy will clearly explain what information we store and why we store it, how we will treat your personal, private and sensitive information and that we comply with your privacy rights.
We know what we store, why we store it and how we use it
The service Harper Stein provides is bespoke. To deliver this service we collect, store and process personal and sensitive information which is provided to us by our ambassadors, members, complimentary members, historical members and potential future members. This information may include some, or all, of the following;
- Your name, postal address, email address and telephone numbers
- Personal information such as your gender, age and date of birth, appearance specifics, your hobbies, interests, lifestyle and values
- Your preferences in a partner, which may include sexual preferences
- Your psychological profile
- Sensitive information such as your sexuality, religion and political stance
- A portfolio of your photographs
- Your signed non-disclosure agreement and terms
- For paid members financial information
- Electronic information about your computer such as your IP address, location, browser version, length of visit and the pages you visit.
- Other important information
This information may also be used for the purpose of subscribing to our email newsletters providing you opt in for this service.
You have the right to request to remove your information at any time. You can do this by emailing us at: Goodbye@harperstein.com with a copy of your ID for identification proof and your request where we will ensure a response is made within 28days.
Your personal information does not include internal notes recorded or feedback following dates with other members. We also continue to store the non-disclosure agreement in the event a related legal issue should arise.
Management have final approval to remove a Members record, however, where the deletion of your information including electronic documents, will cause data holes in another members record, your information will be anonymized. This is to ensure that in the event that a complaint or legal issue may require the information, it will be available.
We respect your privacy rights
- Our members will always be informed of their rights in our Privacy Policy and will have access to the version of Privacy Policy applicable when they started working with Harper Stein.
- You have the right to request access your personal information via a “subject access request”. You can request this, at any time, by emailing us at GDPR@harperstein.com with proof of your ID and your request where we will ensure a response is made within 28days.
- You have the right to correct inaccurate personal information stored with us.
- You have the right to withdraw your consent and thus have your information erased.
- You have the right to restrict your personal data or object to the use of your information at any time.
- You have the right for information portability
- You have the right to be notified if a data breach occurs
We are always working for the better
We are always updating our knowledge and the information we store about each member, from face to face meetings, oral and written feedback and online communications. Our fully GDPR trained Consultants and Psychologists are information processers and controllers and, alongside the named Data Protection Officer, are responsible for the collection and accuracy of the information we hold. They are supported through IT companies and applications who abide by GDPR.
Our staff, ambassadors and partners all abide by our Non-disclosure agreement and as such Harper Stein do not share or permit the use of our members information outside the purpose of matching, except where required by law or to protect our members, or a third parties, safety.
We use information in structured ways
Personal information is fundamentally used to match two members together. The information we store is used to keep detailed records on all of our members, track matches between members and to ensure that we uphold the law and our service requirements.
Additionally we use information to verify identity claims by searching publicly available records, both through electronic means and written means. We may also use information for business analysis and will always anonymize identity.
We may also use information;
- to enable you to personally use the services available including private invite only pages;
- to send you requested brochures or further information;
- to send you non-marketing communications via email and through the post;
- to send you email notifications or email newsletter which has been requested. You can unsubscribe to these at any time through the link provided in the email;
- to provide third parties with statistical information. Third parties will not be able to identify any individual user from provided information;
- to deal with enquiries and complaints made by or about you relating to our website;
- to keep our company secure and prevent fraud; and
- when specifically requested, to provide by sale personal informational to matchmaking agencies so that the individual can be considered as a match for their members. This is an extended service.
You will not be supplying personal information for publication on the Harper Stein website. Should you wish to provide a testimonial we will authorize this and publish only limited information with your written consent which can be withdrawn at any time.
We understand when we can disclose information
Harper Stein will disclose personal information to its employees, and officers as reasonably necessary to provide the service. Additionally it may disclose personal information to insurers, advisers, ambassadors or subcontractors. This is in line with our non-disclosure agreement.
We may disclose your personal information:
- to provide the service
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to individuals reasonably believed to be applying to a court for disclosure of personal information where, in the reasonable opinion of Harper Stein, such court or authority would be reasonably likely to order disclosure of that personal information to avoid public disclosure.
Unless requested, Harper & Stein will not sell or provide your personal information to third parties.
We are secure and have security procedures
- Our membership databases are cloud based systems which are password protected
- All of our computers, mobile telephones and iPads are password or pin protected
- Our passwords are encrypted
- Where possible codes are used to label members
- Only Management have access to download member records
- Management needs to approve the deletion of member records following a request and production of valid ID
- Our belief is that you have the right be to forgotten and as such member records will be archived when there is no interest shown from the member or by Harper Stein
We are thoughtful in how we contact Members
- Contact with new members will always be labeled with strictly private and confidential when using email or letter
- Contact with existing members will be through telephone, text, WhatsApp email and written communication unless the member makes a preference
Our Lawful Basis
Under GDPR, we use Contract and Consent as the basis for lawful processing of our members data.
We use Consent as a Lawful Basis. We do not use pre-selected ticked boxes to ask for your consent to hold, use, process and store your information and give you the option to withdrawing your consent at any time.
Regarding the lawful basis of Contract; for members in contract, we process the Members information to fulfil the contractual obligation which can include processing of member information of a potential member who has not yet signed the Harper Stein Contract.
We additionally uphold a contract with members who sign our Non-disclosure agreement which applies to all members, staff and ambassadors.
Website Users and Visitors
Harper Stein uses third-party services such as HotJar and Google Analytics to collect and log information about our visitors behaviours and IP address. This is to allow us to analyze aspects such as number of visitors and how visitors interact with the site.
Amendments
Harper Stein may update this policy from time to time by publishing a new version on our website without notice, however we will always retain previous copies of this Policy should you request to view it.
Third party websites
Our website includes hyperlinks to, and details of, third party websites. Harper Stein have no control over, and are not responsible for, the privacy policies and practices of third parties.
How to contact us
To request a copy of the information we hold on you, please email, with a copy of your valid ID: GDPR@harperstein.com
To request the removal of the information we hold on you, please email, with a copy of your valid ID: Goodbye@harperstein.com
You can write to us at:
24/25 The Shard
London Bridge Street
London
SE1 9SG