GDPR, Privacy and Cookies Policy

Introduction
Welcome to the privacy policy of Hanover, a brand of Cleversteam Limited, a company incorporated in England with company number 07362371, whose registered office address is at Studio E, 44 Simpson Street, Liverpool, L1 0AX (hereinafter referred to as “Hanover”, “we”, “us” or “our”).
1. Important information and who we are Purpose of this privacy policy
We respect your privacy and are committed to protecting your personal data.
Whenever you interact with us, including but not limited to engaging through email, phone, other electronic transmissions, purchasing a product or service, or using the www.hanovercrm.com website or our Hanover cultural exchange CRM, we will collect and process your personal data. This privacy policy aims to provide a transparent summary of how we collect your personal data and the purposes for which we will process it.
This website is not intended for children (those under 18 years of age), and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Hanover is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us:
Full name of legal entity: Cleversteam Limited Email address: moc.mrcrevonah%40tcatnoc Postal address: Digital House, 44 Simpson Street, Liverpool, L1 0AX Telephone number: (+44) 151 528 5410
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 5 February 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website and our Hanover cultural exchange CRM 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may process, collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
● Identity Data includes your full name, title, date of birth, and gender. ● Contact Data includes billing address, email address and telephone number(s). ● Financial Data includes bank account and payment card details. ● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. ● Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. ● Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, and feedback. ● Usage Data includes information about how you use our website, products and services. ● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email, in person or otherwise. This includes, but is not limited to, personal data you provide when you:
● purchase our products or services; ● create an account on our website / Hanover cultural exchange CRM; ● give us feedback or contact us; ● book a ‘Hanover CRM Demo’ call; ● request marketing to be sent to you.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We may receive or manually collect personal data about you from various External Third Parties and public sources, as set out in the Glossary.
4. How we use your personal data
We will only process your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:
● Where we need to perform the contract we are about to enter into or have entered into with you. ● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ● Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to. Where we do require your prior written consent as a legal basis for processing your personal data, we shall ensure that such consent is expressly and freely given, clear, unambiguous, unbundled from other terms and conditions, concise and easy to understand. You have the right to withdraw consent at any time; should you wish to withdraw consent, please contact us at moc.mrcrevonah%40tcatnoc
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests for such processing, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    • Purpose/Activity

    • Type of data

    • Lawful basis for processing including basis of legitimate interest

    • Purpose/Activity

    • Purpose/Activity

    • Type of data

    • Type of data

    • Lawful basis for processing including basis of legitimate interest

    • Lawful basis for processing including basis of legitimate interest

    • To register you as a new customer

    • (a) Identity (b) Contact

    • Performance of a contract with you

    • Purpose/Activity

    • To register you as a new customer

    • Type of data

    • (a) Identity (b) Contact

    • Lawful basis for processing including basis of legitimate interest

    • Performance of a contract with you

    • To deliver the requested products and/or services to you, including:
      (a) Managing payments, fees and charges
      (b) Collecting and recovering money owed to us
      (c) Engaging third party service providers

    • (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

    • (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to recover debts due to us)

    • Purpose/Activity

    • To deliver the requested products and/or services to you, including:
      (a) Managing payments, fees and charges
      (b) Collecting and recovering money owed to us
      (c) Engaging third party service providers

    • Type of data

    • (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

    • Lawful basis for processing including basis of legitimate interest

    • (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to recover debts due to us)

    • To manage our relationship with you which will include:
      (a) Notifying you about changes to our terms or privacy policy from time to time
      (b) Asking you to leave a review or take a survey

    • (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

    • (a) Performance of a contract with you

      (b) Necessary to comply with a legal obligation

      (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    • Purpose/Activity

    • To manage our relationship with you which will include:
      (a) Notifying you about changes to our terms or privacy policy from time to time
      (b) Asking you to leave a review or take a survey

    • Type of data

    • (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

    • Lawful basis for processing including basis of legitimate interest

    • (a) Performance of a contract with you

      (b) Necessary to comply with a legal obligation

      (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • (a) Identity(b) Contact(c) Technical

    • (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      (b) Necessary to comply with a legal obligation

    • Purpose/Activity

    • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • Type of data

    • (a) Identity(b) Contact(c) Technical

    • Lawful basis for processing including basis of legitimate interest

    • (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      (b) Necessary to comply with a legal obligation

    • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    • (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

    • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    • Purpose/Activity

    • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    • Type of data

    • (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

    • Lawful basis for processing including basis of legitimate interest

    • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    • (a) Technical (b) Usage

    • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    • Purpose/Activity

    • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    • Type of data

    • (a) Technical (b) Usage

    • Lawful basis for processing including basis of legitimate interest

    • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    • To make suggestions and recommendations to you about products or services that may be of interest to you

    • (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

    • Necessary for our legitimate interests (to develop our products/services and grow our business)

    • Purpose/Activity

    • To make suggestions and recommendations to you about products or services that may be of interest to you

    • Type of data

    • (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

    • Lawful basis for processing including basis of legitimate interest

    • Necessary for our legitimate interests (to develop our products/services and grow our business)

    • To carry out our professional obligations in:
      Checking whether we can act for you as a new or existing customer
      Checking whether we can act across from you as a counter party or other third party on a matter involving a new or existing customer
      Carrying out all of our legal and regulatory compliance requirements (including, without limitation, conflicts of interest checks, anti-money laundering checks, anti-terrorism checks, sanctions checks, fraud checks and background screening)

    • (a) Identity(b) Contact(c) Financial(d) Professional

    • (a) Performance of a contract with you
      (b) To comply with a legal or regulatory obligation
      (c) Public interest
      (d) Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences)


    • Purpose/Activity

    • To carry out our professional obligations in:
      Checking whether we can act for you as a new or existing customer
      Checking whether we can act across from you as a counter party or other third party on a matter involving a new or existing customer
      Carrying out all of our legal and regulatory compliance requirements (including, without limitation, conflicts of interest checks, anti-money laundering checks, anti-terrorism checks, sanctions checks, fraud checks and background screening)

    • Type of data

    • (a) Identity(b) Contact(c) Financial(d) Professional

    • Lawful basis for processing including basis of legitimate interest

    • (a) Performance of a contract with you
      (b) To comply with a legal or regulatory obligation
      (c) Public interest
      (d) Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences)


Marketing 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser asking permission to be placed on your computer's hard drive. The file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our services to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our services.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
● External Third Parties as set out in the Glossary. ● Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We engage some external third parties based outside the UK in order to provide services to you and process your personal data in accordance with this privacy policy. Where we work with such third parties, we will transfer your personal data outside the UK.
That said, whenever we transfer your personal data out of the UK, we will not do so without ensuring a similar degree of protection is afforded to that personal data. We do this by requiring at least one of the following safeguards to be implemented prior to any such international transfer:
● We will only transfer your personal data to territories that have been deemed to provide an adequate level of protection for personal data; or ● Where we use providers outside of the EU, we may use specific contracts approved for use by the UK which gives your personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain 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. 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.
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.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as further set out in the Glossary.
If you wish to exercise any of the rights set out above, please contact us via email at moc.mrcrevonah%40tcatnoc
No fee usually required
You will not 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and/or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
Below is a list of external third parties with whom we engage, or may engage, in the provision of our products and services. Accordingly, we may either receive or share your personal data with these entities. The entities listed may change on occasion, so we advise you to review this policy regularly for any updates:
● Appsignal - Monitors the performance of Hanover including error tracking. ● Asana - Project management and partner support. ● AWS (Amazon Web Servers) - Application hosting and data storage for Hanover. All the data is hosted in the EU-West region in Dublin, Ireland. ● Bettermode - Customer hub for communications, updates, posts and articles. ● Google Analytics - Analyses the use of our website. Google Analytics gathers information about website use using cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy can be found at the following web address: https://www.google.com/policies/privacy/ ● Hubspot - Client relationship management and lead generation. ● LinkedIn - Connecting with customers and potential customers. ● Mailchimp - Sending emails in Hanover. To send them, we use Mailchimp (via the product Mandrill). ● Posthog - Analysing application usage within Hanover. ● SEVIS (Student Exchange Visitor Information System) - Processing of DS 2019 forms via an API connection. ● Shortcut - Software development project management and partner support. ● Stripe - Processing payments within Hanover. ● Twilio - All text messages sent from Hanover are sent via Twilio. ● XERO - Is our accounting software for processing invoices. ● Zendesk - Customer service support inbox and knowledge base storage platform.
These external third parties shall also include:
● Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. ● HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Publicly Available Sources
We may obtain personal data from you from publicly available sources, such as Companies House and/or other public registers.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
● If you want us to establish the data's accuracy. ● Where our use of the data is unlawful, but you do not want us to erase it. ● Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. ● You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to process it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

A cultural exchange CRM solution, specialising in global placements. Brought to you by Cleversteam.


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Created by Cleversteam.

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A cultural exchange CRM solution, specialising in global placements. Brought to you by Cleversteam.


Follow Us

Created by Cleversteam.

All rights Reserved