HTK Privacy Policy

HTK is a leading cloud-based software-as-a-solution (SaaS) provider located in Ipswich, England. HTK empowers brands with innovative data insights, machine learning and loyalty marketing solutions. Our customer loyalty and engagement cloud technology, “Horizon”, is a highly configurable multi-tenant SaaS platform designed to help marketing, loyalty and customer experience professionals grow customer value through the real-time application of data.

The personal data we collect from you, either directly or indirectly, will depend on how you interact with us, our Website, our Products, your location, and applicable law. 

(a) Personal Data You Provide to Us

(i) When you visit our Website

HTK collects certain personal data from you when you choose to provide us with this information on our Website. Such personal data may include:

• Contact information: such as your name, email address, phone number, postal address, job title, and company name (for example, when you fill out our website form to request a demo; to request assistance from our customer support team; or to subscribe to our online newsletter or biennial magazine).
• Account login credentials: such as your email or username and password when you create an account with us and log in to that account via our Website.
• Correspondence content and support data: such as personal data you provide in any free text “comments” boxes on our website forms, or in communications you have with us via email or phone (for example, when you have a question or request technical or operational support from our HTK support team).

(ii) When you use our Products

If you are a user of one of our Products (e.g. our Horizon app), you or your employer may provide certain personal data to us through the use of our Products. For example, personal data we collect may include: 

• Contact information: such as your name, email address, phone number, and postal address (for example, when you register for a Horizon account and/or sign up to our loyalty program through our Horizon platform).
• Account log-in credentials: such as your email or username and password when you sign up for a Horizon account with us.
• Transactional data: and other payment information if you purchase our Products such as software subscriptions.
• Marketing information: such as your contact preferences. 
• Troubleshooting and support data: such as personal information you provide or we otherwise access in connection with support queries we receive from customers. This may include, for example, contact or authentication data, the content of your communications or correspondence with HTK, and the product or service you are using in relation to your query.

(b) Personal Data We Collect Automatically

When you visit our Website or use our Products, our servers will log certain technical information from your browser or device automatically. In some (but not all) countries, including countries in the European Economic Area (“EEA”) and the UK, this information is considered personal data under applicable data protection laws. To the extent that this automatically collected data includes, or is linked to, personal information, we will treat the data in accordance with this Privacy Policy.

The information we collect includes:

• Identifiers and device information: such as your Internet Protocol (IP) address, domain name, browser type, and log data detailing your interactions with our Website (e.g. aggregate information on what pages users accessed or visited) are logged automatically.
• Geolocation data: such as your general location data which we may derive from your IP address when you visit our Website or use our Products.
• Information collected through social media platforms: We receive information about you when you engage with us through various third-party social media platforms. The data we exchange with these third-party platforms may depend upon your privacy settings with these platforms. Please note that we are not responsible for the data protection and use practices of these third-party platforms. Please see their privacy policies to learn how they use your information.  

Some of the above information will be collected through cookies and similar technologies. You can find out more about this in our “Use of Cookies” section below.

Our Website does not collect any sensitive personal data about you, such as health-related information or information about your race, ethnicity, or sexual orientation.

(c) Personal Data We Collect from Third-party Sources

There are limited circumstances in which we may receive information about you from others. For example, our clients may provide personal information about others (such as their employees, agents, suppliers or customers) in the course of using our products and services for the purposes of managing aspects of their business. In such cases, we are collecting the information purely on behalf of our client, on their instructions, and we rely on our clients to only provide your information where lawfully entitled to. We do not have control over their privacy policies and practices and suggest you read them if you have any concerns. 

HTK uses the personal data we collect from and about you for the following business purposes and, if you are a resident of the EEA or UK, on the following legal bases identified below:

• Developing and improving our Website and Products: We process your personal data for our legitimate interest in developing, improving, and/or troubleshooting our Website, Products, services, and marketing activities, and to provide you with more relevant content and service offerings, or where necessary, in reliance on your consent.
• Customer relationship management and delivering our Products: to establish you as a customer on our systems, provide you with any information or Products that you have requested or purchased, managing and administering your account and managing our customer relationship with you, to perform our contract with you and to the extent necessary in reliance on our legitimate interests
• Transactional considerations: We process your personal data to complete transactions, and send you related information, including purchase confirmations and invoices, to perform our contract with you and to the extent necessary in reliance on our legitimate interests.
• Service-related communications: We may send you service, technical and other administrative communications or notifications (product updates and product patches and fixes) in reliance on our legitimate interests in administering our products and providing certain features. These communications are considered part of HTK’s products and in most cases you cannot opt-out of them.  If an opt-out is available, you will find that option within the communication itself.
• Handling contact and support requests: If you fill out a “Contact Us” webform or request support as a user, or if you contact us by other means including via a phone call, we process your personal information to perform our contract with you, and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.
• For our business purposes: such as to conduct internal analytics and reporting, aggregate statistical data regarding usage of our services, and expand our business development activities in reliance on our legitimate interests.
• Promoting the security of our Websites and Products: To the extent necessary for our legitimate interests in promoting the safety and security of our Website and Products, we use your personal information to investigate and prevent fraudulent transactions, unauthorized access to the Website, Products, and other illegal activities.
• Sending marketing communications: In reliance on our legitimate interest in conducting direct marketing or where necessary with your consent, we will process your personal information for marketing purposes in accordance with your preferences, such as to communicate with you via email, post, or telephone about our Products, services, surveys, newsletters, biennial magazine, promotions, rewards, and/or upcoming events which we think may be of interest to you. These marketing communications may also serve to provide other updates, news or information about HTK and/or our select partners. Please see the “Your Privacy Rights” section below, to learn how you can opt out from HTK’s marketing communications.
• Online advertising: We process your personal data to deliver targeted advertising and marketing campaigns to you (which may include in-Product messaging/push notifications) based upon your activities and interests to the extent it is necessary for our legitimate interest in supporting our marketing activities or advertising our products and services.
• Profiling and automated decision making: We may use personal data (including data collected using cookies and similar technologies) to evaluate and predict your personal preferences and interests (i.e. profiling activities) to create targeted offers and promotions for you based on your use of our Products. Please note that this is subject to your consent where required by applicable law.
• Complying with legal obligations: We process your personal information when cooperating with law enforcement agencies, regulators, courts, and/or government authorities in accordance with our legal obligations under applicable laws, including our obligations to respond to your requests under applicable data protection law.

We may share or disclose your personal information to the following categories of recipients:

• Our group companies and affiliates: We may share your personal data with our group companies and affiliates, including our parent company, ITA Group, Inc.
• Third-party service providers: We may share your personal data with our third-party service providers who provide us with the platform for you to interact with us through the Website or Products, or who otherwise provide data processing services to us and support the operation of our business and services. These services may include: cloud hosting, customer service/help desk support, registration and subscription services, marketing automation tools, analytics and reporting, financial reporting and program metrics, payment processing, reseller and referral services, project management tools, issuance of rewards or cash cards, collaboration and communication tools (including surveys), data backup services, and professional services.
• Law enforcement bodies, regulatory or governmental agencies, and/or courts: We may share your personal information with law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by law.
• Business transfers. We may share your personal information with a third party who acquires our business in a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business or assets, or in the event of a bankruptcy, dissolution, or related or similar proceedings.

HTK uses reasonable and appropriate technical and organisational security measures to safeguard your personal data against loss, misuse, unauthorized access/disclosure, and alteration, for example, by storing your personal data on secure servers; encrypting your personal data in transit; and limiting access to your personal data to authenticated and approved staff.

Please be advised, however, that while we deploy these security measures and strive to protect your personal data, the use of the internet is not 100% secure, and for this reason we cannot guarantee the security or integrity of any personal data that you transmit or disclose to us online. You should only access our Website and services within a secure environment.

If you are a resident of the European Economic Area (“EEA”) or the UK, in some cases, your personal data will be transferred and processed to countries outside of the EEA or UK, such as the United States, where we have servers or in which we engage service providers.

Where we transfer your personal data to a country outside of the EEA or UK that is not covered by an adequacy decision from the European Commission or an adequacy regulation from the UK Secretary of State, we have taken appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Policy and applicable EU and UK data protection laws. Specifically, we use the European Commission’s Standard Contractual Clauses (“SCCs”) for transfers of personal data outside the EEA, and the UK International Data Transfer Addendum (“UK Addendum”) for transfers of personal data outside the UK. HTK and its parent company, ITA Group, have entered into an intragroup transfer agreement based on the SCCs and UK Addendum which allows for the processing and transfer of EEA/UK personal data to the United States.

Individuals located in the UK and EEA have the following data protection rights.  To exercise any of them see specific instructions below or contact us using the contact details provided under the “Contact Us” heading below.

• You may access, correct, or request deletion of your personal data. 
• You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format).
• You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contact us” heading below. If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as transactional emails or emails about your account.
• If the collection and processing of your personal data is based on your consent, then you have a right to withdraw your consent at any time for future processing by using the contact details provided under the “How to contact us” heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal data.  For more information, please contact your local supervisory authority. Contact details for supervisory authorities in Europe are available here and for the UK here. 

We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We will only keep your personal information for as long as we require it for the purposes for which it was obtained. However, we may also keep some of your personal information for specified period of time under our data backup and retention policy, and as required by certain laws (for example those relating to corporate governance, money laundering and financial reporting legislation), or, where your personal information is controlled by our clients, in accordance with our clients’ instructions.

Our Website uses cookies and similar technologies to enable certain functionality and help collect information about your visit to our Website.

For example, our Website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics serves cookies to collect limited data directly from your browser or device to enable us to evaluate your use of our Website and compile reports for us regarding activity on our Website. For further information on how Google collects and uses this data, please refer to www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the services by visiting https://tools.google.com/dlpage/gaoptout.

We also work with other third parties to provide advertising services and analytics (e.g. to show levels of engagement and regularity of use) in connection with our Website and Products. These third parties use cookies or similar technologies to automatically collect some of the information described above from visitors to our Website and Products over time and pulls information from third parties for purposes of analytics and advertising.  We use the analytics information to analyze and improve our services.  Our advertising partners use the information to try to understand your interests and show you relevant advertising about our Products and services.

For further information about our use of cookies, online targeted advertising, and how to opt-out of having your information used for these purposes, please refer to our . If you wish to restrict or block cookies which are set as a result of visiting this Website, or indeed any other website, you can do this with your browser settings. The Help menu within your browser should tell you how to do this. Please note, however, that restricting certain cookies may impact on the functionality of this Website.

Machine Learning (“ML”) is a type of Artificial Intelligence (“AI”) which uses data and algorithms to recognise patterns in customer behaviour datasets, allowing us to improve our Products and giving our clients access to new functionalities and automated features.

HTK uses ML in its Products and may process some of the personal data listed above to deliver these ML powered services.  Leveraging ML models helps our clients understand what their customers want and need, helping them deliver a more personalised customer relationship experience.

We may modify or update this privacy policy from time to time to reflect the changes in our business and practices. If we make any changes to this Privacy Policy, we will notify you by changing the “Last Updated” date above. Please try to check on this page from time to time so that you can keep up to date with any changes.

If we make any material changes, we will take an appropriate measure to inform you consistent with the significance of the change, for example, posting a prominent notice on the Website, and/or notifying you via email.

If you have any questions, complaints, or concerns about this privacy policy or our privacy practices generally, please contact us at hello@htk.co.uk, 0870 600 2311, or by writing to us at: Chapmans Warehouse, Wherry Quay, Ipswich, Suffolk IP4 1AS.