This Policy explains how your personal data may be processed when you visit and browse our website and social media channels. It does not address AWO’s other personal data processing operations, for example where we provide services to you on the basis of a contract between us. Additional policies and procedures addressing these processes are in place and we provide information to data subjects at the point of data collection or subsequently, as required by law.

Data controller

AWO is an agency comprised of HNK Legal, HNK Litigation, HNK Data Consulting and AWO Belgium. This website is operated by HNK Legal (ICO registration: ZA656719). Contact us via email privacy@awo.agency or post to AWO, 2 John Street, London, WC1N 2ES with any questions regarding this Policy or any other data protection issue related to AWO.

What we (do not) collect

In line with AWO’s mission and values we have built this site so that we do not collect any data from visitors for any purpose. Our only interests are informing you about our organisation, enabling you to contact us and maintaining the security of the website, therefore:
* we do not set any cookies at all on this site or your own device.
* we do not collect any data whatsoever about people who visit our site, unless you suscribe to our mailing list.
* we do not conduct any analysis of how people use our site
* we do not allow third-party tracking of any kind on this site
* we have licensed fonts from foundries that don’t entail usage tracking

Third party data processing and retention

AWO has selected Netlify to host its website because of its focus on static sites and their redundant network of servers. In order to provide this service, Netlify processes the Internet protocol (IP) address of the device accessing the site and additional traffic data including the browser software and operating system that the computer uses and the Internet address (URL) from which the visitor came. This information is processed for the purpose of diagnosing technical problems and defending against attacks.

AWO does not review, monitor or otherwise access the data collected by Netlify, but by using Netlify to host our website engages them to process site visitor data for the aforementioned purposes. We do this on the basis of our legitimate interests in providing a functional website. Netlify is based in the USA and primarily processes data in that location. The data processing agreement between AWO and Netlify includes data processing clauses and an international data transfer support mechanism (European Commission Standard Contractual Clauses) as required by the EU General Data Protection Regulation and national data protection law. Netlify’s terms state that they retain the aforementioned data for up to 30 days. After this time, Netlify advise that they will delete or anonymise data for research and development purposes.

AWO uses EmailOctopus to manage its mailing list and inform subscribers about its work. We selected EmailOctopus because it was the only provider we could find that allowed us to disable email tracking functionality. EmailOctopus is engaged on terms that ensure the confidentiality and security of personal data and compliance with applicable data protection laws. Email addresses are retained by EmailOctopus and AWO to manage your subscription and deleted thereafter. You can find EmailOctopus’s Privacy Policy here.

Like the rest of our website, the subscription process has been designed to limit extraneous personal data processing. Your email is briefly processed by Netlify, transmitted by EmailOctopus and automatically deleted at the end of your session on our site.

Information security

AWO has built a static website because it is inherently more secure than dynamically generated websites (as there is nothing dynamic for scripting or database security attacks to exploit) and deployed a Let’s Encrypt TLS certificate.

Social media

AWO also uses social media and social networking to inform people about our organisation. Personal data processed by social media platforms is subject to the terms and conditions of the platform owners, which may act as controllers of that data. If you engage with AWO’s social media accounts you should check Twitter’s Privacy Policy and Linked in’s Privacy Policy , which are subject to regular change, to understand how your data may be used. AWO’s social media accounts and pages are managed by AWO staff members. AWO is not responsible for any comments, links or content produced by third parties.

Your rights

Where AWO processes your personal data you may have the right:
* to be informed as to whether AWO holds data about you;
* to access that data;
* to have inaccurate data corrected;
* to have your data deleted;
* to opt-out of particular data processing operations;
* to receive your data in a form that makes it “portable”;
* to object to data processing;
* to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.

You can seek to exercise these rights via email to privacy@awo.agency or post to AWO, 2 John Street, London, WC1N 2ES. You also have the right to lodge concerns or complaints with the UK Information Commissioner’s Office . Data subjects covered by EU law may also be entitled to lodge complaints with the data protection supervisory authority in their country of residence.

Changes and revisions

We may update this Policy in future. We will maintain an accessible record of any such changes.

Policy published 1st July 2020.

Policy updated 18 November 2021 to reflect implementation of email subscription.