Privacy Notice

HK Consulting Ltd

Last updated: 11 December 2024

Welcome to HK Consulting Ltd’s Privacy Notice, trading as Sales in DACH. We offer a web-based learning and development platform found at https://salesindach.mykajabi.com. With our offering, we naturally collect information on people and have written this Privacy Notice to explain whose information we collect, how we collect it as well as why we collect it. We have used Kajabi as a third-party supplier in order for us to deliver the Sales in DACH Academy; you can find Kajabi’s Privacy Notice here: https://legal.kajabi.com/policies/privacy.

This Privacy Notice was last updated on 11 December 2024 by our Legal & Compliance Team and it’s regularly kept under review and updated as and when necessary. If you have any questions about it, please do reach out to our Legal & Compliance Team on [email protected].

Here is a little legal dictionary courtesy of our Legal & Compliance Team

Okay, so we all know that legal terminology can be quite complicated to sometimes understand. Don’t worry about it here though. Our Legal & Compliance Team have made a little dictionary below with the key data protection words and phrases and have explained them in this section.

It’s super important to us that all of the people that trust us with their information, understand exactly what we’re doing with it. For each word in the little dictionary below, it’s been capitalised and throughout the rest of the Privacy Notice, if you see a capitalised word or phrase, you know that it’s defined in this little dictionary, and you can refer to it to check the meaning if you’re unsure.

Consent → refers to when an individual gives agreement which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the Processing of any Personal Data relating to them.
Data Controller → refers to an organisation that determines when, why and how to Process Personal Data. It is responsible for establishing policies and procedures in line with Data Protection Laws.
Data Processor → refers to an organisation that Processes Personal Data on behalf of a Data Controller. It is responsible for establishing policies and procedures in line with Data Protection Laws and also its contractual obligations with Data Controllers.
Data Protection Laws → refers to the UK GDPR, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable European Union legislation (such as the General Data Protection Regulation 2016/679) relating to Personal Data. The “UK GDPR” is the retained version of the General Data Protection Regulation 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419). The UK GDPR sits alongside the Data Protection Act 2018.
European Economic Area (“EEA”) → refers to the 27 countries in the European Union ("EU"), Iceland, Liechtenstein and Norway.
Legitimate Interest → refers to when an organisation’s interests are legitimate (as they need to do something to operate) and these interests do not override an individual’s interests or fundamental rights and freedoms.
Personal Data → refers to any information identifying an individual or information relating to an individual that an organisation can identify (directly or indirectly) from that data alone or in combination with other identifiers that it Processes.
Process or Processing → refers to any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

If there is anything at all that you don’t understand in this little dictionary, you can reach out to our Legal & Compliance Team on [email protected].

Some important details about our business

We run our business as HK Consulting Ltd which is incorporated in England & Wales and has the registration number of 14198035 and registered address of 5 Brayford Square, London, England, E1 0SG.

Data Protection Laws have created the concepts of a Data Controller and a Data Processor. Sales in DACH’s status is that of a Data Controller to our direct customers. To keep us (and all other organisations) in check, we are supervised by the Information Commissioner’s Office (“ICO”) which is the data protection supervisory authority in England & Wales. Our registration identification with the ICO is ZB503037. You should note that in some circumstances, Sales in DACH operates as a “data processor” such as when it is providing the Sales in DACH Academy to SDRs of Germany Ltd.

Getting the down-low on our data protection compliance program

We’re super strong believers in protecting the confidentiality and integrity of Personal Data and our Legal & Compliance Team have built an entire data protection compliance program on this important topic. We also live by certain data protection principles at Sales in DACH and these include believing:

Personal Data must be Processed lawfully, fairly and in a transparent manner.
Personal Data must be collected only for specified, explicit and legitimate purposes.
Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
Personal Data is accurate and where necessary, kept up to date.
Personal Data should not be kept in a form which permits identification of individuals for longer than is necessary for the purposes for which the Personal Data is Processed.
Personal Data must be Processed in a manner that ensures its security using appropriate technical and organisational measures to protect it against unauthorised or unlawful Processing and against accidental loss, destruction or damage.

We hope that you can see that we are serious about looking after your Personal Data. You have trusted us, and we won’t let you down.

What type of Personal Data do we collect?

We collect, use, store and transfer different kinds of Personal Data depending on our relationship with you. In general, we collect the following types:

Identity Data (e.g., first name, maidan name, last name and title).
Contact Data (e.g., phone number, email address, business address and billing address).
Communications & Marketing Data (e.g., your preferences in respect of cookies and marketing).
Financial Data (e.g., bank account details, value added tax numbers).
Profile Data (e.g., agreements you have entered into with us such as our terms and conditions).
Transaction Data (e.g., invoices, payment details).
Technical Data (e.g., internet protocol addresses, browser type and version, time zone settings and location).
Usage Data (e.g., information about how you use our website).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your Personal Data but is not considered Personal Data under Data Protection Laws as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

Please note that Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

Who are the people that we collect Personal Data on?

We feel fortunate that so many people have connected with us at Sales in DACH. We are grateful to everyone that helps us to deliver our offering and uses our services. In particular, we collect Personal Data on website users, individual sellers using our services, businesses using our services, third party suppliers and our partners.

You are a curious website user that is intrigued by what we’re offering…

Hello, hello and a big welcome! Thank you for clicking on our website to find out more.

If you like what you see and want to find out more, please do reach out to us as we definitely want to hear from you! In the meantime, check us out on LinkedIn too and connect with our founder Helena.

What do we collect? We collect your Technical Data and Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data and Communications & Marketing Data (if you decide to get in touch with us).

How do we collect this? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this Personal Data through our direct interactions with you such as when you contact us through our website (we have our fingers crossed that you do!).

What’s our legal ground(s) for Processing? One or more of the following apply:

Consent (i.e., in that you are choosing to provide us with your details so that we can contact you).
Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

You are a fabulous individual seller using our services…

Whoopee! We love that you’re a part of our community and huge thank you for trusting us to help you in your sales career.

We’ve built our Sales in DACH Academy to help bring out your superpowers in sales. All of this is done through sharing tips, tricks and bringing together all of our knowledge in one place - all for you.

What do we collect? We collect your Technical Data and Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Communications & Marketing Data (for when you entered into our website terms and conditions).

What’s our legal ground(s) for Processing? One or more of the following apply:

Contract (i.e., in that you have agreed to our website terms and conditions).
Consent (i.e., in that you are choosing to provide us with certain details).
Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

You are an amazing business using our services…

Hurray! We are delighted that you’ve put your faith in us in helping you to recruit, train and guide sellers.

The crème de la crème of German-speaking B2B sales tactics is all happening here with us at Sales in DACH and we love that you’ve picked us to help your business in this area.

What’s our legal ground(s) for Processing? One or more of the following apply:

Contract (i.e., in that you have agreed to our website terms and conditions).
Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

You are an awesome third-party supplier or a partner that helps us to deliver our services…

Kudos for being a part of our journey! We appreciate you.

We are grateful for all of the external support that we receive ranging from accountants to software providers.

What do we collect? We collect your Technical Data and Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data, Financial Data, Transaction Data and Profile Data (for when we are engaging you for your services and expertise).

How do we collect this? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this Personal Data through our direct interactions with you (i.e., we will hold Personal Data on your staff that have engaged with us).

What’s our legal ground(s) for Processing? One or more of the following apply:

Contract (i.e., in that we need this information perform a contract with you).
Legitimate Interests (i.e., its necessary for our Legitimate Interests in keeping records to develop our business strategy).

Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

Who do we share Personal Data with?

We really will only share your Personal Data when necessary and have outlined examples of the types of organisations with whom we would share it with below. Please note that some of these organisations operate as Data Controllers whereas others operate as Data Processors.

Technology companies that provide us with hardware and software products including in respect of artificial intelligence and help us to conduct our business operations (such as Google and Kajabi). The technology companies that we engage with tend to operate as Data Processors.
Professional advisers such as banks, payment providers and accountancy firms which we need to engage with for the purposes of our business and may need to provide data. The professional advisors (such as Bewise Consultancy and Aria Grace Law CIC) that we are supported by tend to operate as Data Controllers.
Regulators and other governmental authorities (such as Companies House and HMRC) – which we need to engage with for the purposes of our business and may need to provide data. Regulators and governmental authorities operate as Data Controllers.
Third parties that we’ve collaborated with and support each other in our business activities . Organisations that we collaborate with tend to operate as Data Controllers.
Third parties to whom we may be in contact with to sell, transfer or merge parts of our business or assets, or to attempt to acquire or merge with other companies. These third parties tend to operate as Data Controllers.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with Data Protection Laws. We enter into contractual agreements with all of our third parties (with the exception of regulators and governmental authorities) which include the appropriate data protection clauses. The nature of the contractual agreements that we enter into with all of our third parties depend on whether the third party is operating as a Data Controller or a Data Processor in its interaction with Sales in DACH.

How do we protect your Personal Data?

We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those who have a business need to know. We have put in place policies and procedures to deal with any suspected or actual personal data breaches (although we hope not to ever be in that position!).

How do we safely transfer Personal Data across borders?

We ensure though that Personal Data is transferred safely and securely at all times. Whenever your Personal Data travels outside of the UK and/or the EEA, we ensure that it’s protected by putting in one of the following safeguards:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data as endorsed by the ICO and identified and determined by the European Commission.
We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

If you want to find out the specific mechanism used when transferring your Personal Data out of the UK and/or the EEA, please reach out to our Legal & Compliance Team on [email protected].

How long do we keep data for?

We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you (although, of course, we really don’t want to be in that situation).

What rights do you have in respect of your personal data?

Under certain circumstances, you have specific rights in respect of the Personal Data that we Process about you. Your rights include:

Right of access to information and copies of the Personal Data that we hold about you.
Right to rectify (i.e., correct) your Personal Data where it is inaccurate or incomplete.
Right to delete your Personal Data, but only in specific circumstances, for example where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected or Processed. It may not therefore always be possible for us to delete all of the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
Right to restrict Processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid.
Right to object to Processing in cases where Processing is based upon our Legitimate Interests or where Processing is for direct marketing purposes (including profiling).
Right to data portability which means the right to receive, move, copy or transfer your Personal Data to another Data Controller. You have the right to this when we are Processing your Personal Data based on Consent or on a contract and the Processing is carried out by automated means.

If you wish to exercise any of the rights set out above, please contact our Legal & Compliance Team on [email protected]. You won’t have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will definitely notify you and keep you updated.

We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint to the ICO which can be contacted on www.ico.org.uk.

What other links and features are on our website?

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We want to let you know that we do not control these third-party websites and are not responsible for their privacy statements and notices. When you leave our website, we really do encourage you to read the privacy documentation of the website you visit.

How do we use your Personal Data in our marketing practices?

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in Consent before we share your Personal Data with any third-party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us and withdrawing your Consent. Where you opt-out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g., as we may be required to contact you in order to perform the contract).

Our commitment to your success extends to virtual and face-to-face events we host where we strive to create a welcoming environment and empower your sales journey. As part of our ongoing efforts to enhance your experience, we may collect Personal Data at these events, which could include photographs and videos of attendees for marketing purposes. We respect your privacy choices and if you attend our events and prefer not to have your Personal Data used for marketing purposes, you have the right to object and can do so by getting in touch with our Legal & Compliance Team on [email protected] to exercise your right.

Want to get in touch about this Privacy Notice?

Feel free to get in touch with our Legal & Compliance Team on [email protected].

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