1. Data Controller
Harpa Axis Ltd (“we”, “us”, “our”) is the data controller for personal data collected through this website and during our business activities. This notice explains what personal data we collect, why we collect it, how we use it, how long we keep it, and your rights.

2. Personal data we collect

We may collect: name, email, phone number, job title, company name, IP address and device/browser information, cookies identifiers, CVs and application information for recruitment. We may also collect special category data only where you provide it voluntarily e.g., disability information for recruitment.

3. Purposes of processing & legal bases

* To respond to enquiries and manage contracts lawful basis: contract/performance or legitimate interest.
* To send marketing where you have consent lawful basis: consent. You may unsubscribe at any time.
* To process job applications lawful basis: contract/legitimate interest (or legal obligation where applicable).
* To comply with legal obligations (e.g., accounting, anti-fraud) 
For legitimate interest processing we shall document and balance those interests in a legitimate interests assessment.

4. Sharing and processors
We use third-party service providers hosting, email, analytics, payment processors. We only share data necessary for their services and have Data Processing Agreements in place. Where data is transferred outside the UK we apply appropriate safeguards standard contractual clauses, adequacy mechanisms or other lawful safeguards.

5. Cookies and tracking
We use cookies for essential site functionality and with your consent analytics and marketing. See our cookie policy for details and to change your preferences.

6. Data retention
We keep personal data only as long as necessary for the purpose collected or as required by law Typical retention: enquiries 2 years; customer records 6 years after end of contract; applications 6 months.

7. Your rights
You have the right to: access your personal data, correct inaccurate data, request erasure (subject to legal exceptions), request restriction of processing, object to processing (including for direct marketing), request portability, and challenge automated decision-making. To exercise these rights contact dataprotection@harpa-axis.co.uk or write to the registered office.

8. Making a complaint
If you are unhappy with how we handle your data, please contact us first. 

dataprotection@harpa-axis.co.uk

Postal enquiries to the registered office.

You also have the right to complain to the Information Commissioner’s Office (ICO). 

9. Security
We implement reasonable technical and organisational measures to protect personal data. No internet transmission is 100% secure; we will notify individuals and the ICO of any personal data breach where required by law.

10. Changes to this notice
We may update this notice; changes will be posted here with an updated date.

11. Data Protection Officer (DPO)
If we appoint a DPO or data protection contact, details will be provided here.