1. Introduction
HT Markets & Metrics ("we," "us," or "our") is committed to protecting the privacy and security of your personal and business information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website (https://www.htmarketsmetrics.com/) or engage our consultancy services.
We operate from Leeds, United Kingdom, and serve clients across the UK, European Union (EU), and Canada. As such, this policy is designed to comply with the UK General Data Protection Regulation (UK GDPR), the EU GDPR, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
2. Information We Collect
We collect information necessary to provide our international growth, logistics, and financial consultancy services. This includes:
A. Personal & Business Contact Information
Name, job title, and company name.
Email address, phone number, and mailing address.
Business registration numbers (e.g., VAT, BN, EORI numbers).
B. Financial Data for Grant Applications & Strategy
To provide our Export Grant and Financial Modelling services, we may collect sensitive financial documentation, including but not limited to:
Company financial statements (Balance Sheets, P&L).
Bank account details (for setting up direct deposits with grant authorities).
Tax records and CRA/HMRC correspondence.
Payroll data (if required for grant eligibility regarding employees).
Project-specific budgets and cost forecasts.
C. Technical Data
IP address, browser type, and operating system (via cookies and analytics).
Information about how you interact with our website.
3. How We Use Your Information
We use your data for the following specific purposes:
Service Delivery: To deliver consultancy services, including supply chain architecture and partner negotiation.
Grant & Funding Applications: To prepare and submit applications to government bodies (e.g., CanExport, Innovate UK) on your behalf. (Legal Basis: Performance of Contract).
Financial Modelling: To build forecasts and landed cost models.
Communication: To schedule consultations and update you on project progress.
Compliance: To fulfill obligations under tax laws and trade regulations in the UK, Canada, and EU.
4. Legal Basis for Processing (UK & EU GDPR)
Under the GDPR, we process your personal data under the following legal bases:
Contractual Necessity: Processing is necessary to fulfill our service agreement with you (e.g., applying for a grant).
Legal Obligation: Processing necessary to comply with the law (e.g., keeping records for HMRC/CRA).
Legitimate Interests: Processing for business improvement and B2B marketing, provided it does not override your rights.
Consent: Where you have explicitly agreed to data processing (e.g., subscribing to a newsletter).
5. Consent and collection (Canada - PIPEDA)
In compliance with PIPEDA:
Meaningful Consent: We obtain your consent to collect, use, and disclose personal information. For sensitive financial data used in grant applications, we require express consent (written or verbal confirmation).
Implied Consent: We may rely on implied consent for less sensitive information where a business relationship already exists, such as using your email to send project updates.
Withdrawal: You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting us.
6. International Data Transfers
As an international consultancy, we transfer data between the UK, the EU, and Canada.
Adequacy Decisions: The UK, EU, and Canada (for commercial organizations) all recognize each other's data protection laws as "adequate." This means data can flow freely between these jurisdictions without additional complex legal safeguards.
We ensure that any transfer of data to government bodies (for grants) or third-party logistics (3PL) providers is done securely and strictly for the purpose of your expansion strategy.
7. Data Sharing and Disclosure
We do not sell your data. We may share your information with:
Government Bodies: (e.g., Global Affairs Canada, UK Dept for Business and Trade) strictly for the purpose of securing grants or funding you have requested.
Service Providers: Trusted third parties who assist us in operating our website and conducting our business (e.g., cloud storage, accounting software), subject to confidentiality agreements.
Legal Authorities: If required by law or to protect our legal rights.
8. Data Retention
We retain your personal and financial data only as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.
Grant Data: Retained for the duration required by the specific funding authority (often 6-7 years for audit purposes).
General Client Data: Retained for the duration of our business relationship plus a standard limitation period.
9. Security of Financial Data
We take the security of your financial data seriously. We implement appropriate technical and organizational measures (such as encryption, access controls, and secure file transfer protocols) to protect your data against unauthorized access, alteration, disclosure, or destruction.
10. Your Rights
Depending on your location, you have the right to:
Access the personal data we hold about you.
Correct inaccurate or incomplete data.
Delete your data ("Right to be Forgotten"), subject to legal retention requirements.
Object to processing (GDPR) or withdraw consent (PIPEDA).
Portability: Request a copy of your data in a structured format.
To exercise these rights, please contact us using the details below.
11. Contact Us
HT Markets & Metrics is responsible for your personal data.
Contact Name: Hubert Theriault
Email: contact@htmarketsmetrics.com
Location: Leeds, United Kingdom
For Canadian Clients: If you are not satisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada. For UK Clients: You have the right to lodge a complaint with the Information Commissioner's Office (ICO).