Hanei Ltd Privacy Notice

Last updated: 24 September 2026

Hanei Ltd (company number 16900540) is registered at South Park Studios, 88 Peterborough Road, London SW6 3HH. References to "we" or "us" throughout this policy shall refer to Hanei Ltd. For the purposes of this privacy notice we are the data controller of your personal information.

We may need to make changes to this Data Privacy Notice from time to time. This could be to reflect a new processing activity, government regulations, the deployment of new technologies or other developments in data protection laws generally. You should check the Hanei Ltd website periodically to see our most up to date privacy notice.

1. What information do we collect?

The information we collect depends on our relationship with you. For example, the types of information we collect will vary depending on the specific product or service you are interested in.

In general, where Hanei Ltd is the data controller, we may collect the following categories of personal information about you:

• Your full name;
• Your email address; and
• Your mobile number.

In addition, where you are a retailer taking part in the Hanei Ltd Retailer Pilot Scheme, we may collect the following information:

• Your store name;
• Your store's postcode;
• Which ePOS (till) system your store uses — e.g. PayPoint One, ShopMate, Epos Now; and
• How many convenience stores you own.

The ePOS and store-count fields are about your business — what till system you use and how many shops you operate. This does not contain personal data about your customers. This information allows us to tell you up front whether Hanei integrates with your current till and make the correct preparations to visit your store.

2. How we collect your personal information

While there are several methods we may use to collect personal information, the two main methods we rely on to collect personal information about you are from things you tell us yourself; and things we ask other people or organisations to share with us.

Things you tell us could include conversations we have on the phone, what you've written on an application form or if you post something on our website. We might also collect information about you from other people and organisations where appropriate.

3. Why we collect your personal information

We use your personal information for the purpose of providing our products and services to you. For example, we will need to process your contact details to arrange for the deployment of our technology into your shops where you are taking part in the Hanei Ltd Retailer Pilot Scheme.

4. How we use your personal information

If you are taking part in the Hanei Ltd Retailer Pilot Scheme, Hanei will not process the personal data of your customers. We use till data that consists of aggregated transaction information (e.g. what has been sold, when, and at what price), rather than information that could be used to identify an individual shopper. The screen-interaction data we collect from the tills is anonymised and limited to analysis of patterns.

This notice sets out how we use the personal information collected through our website and the information collected in connection with the Hanei Ltd Retailer Pilot Scheme. If our processing of personal data expands further in the future, this privacy notice will be updated to reflect the new processing.

5. Lawful Basis

We will only process your personal information where we have a legally valid reason to do so. Under the UK GDPR, this is called a lawful basis, and more than one lawful basis may apply depending on the processing activity taking place. The table below summarises the legal bases we rely on:

6. WhatsApp notifications

If you opt in through your Hanei account, we send you WhatsApp notifications about your listing requests. To do this, we store your mobile number and the date you opted in, and share your number with Meta's WhatsApp Business Platform. You can opt out at any time in your account settings.

7. Who we share personal information with

From time to time, we may need to share your information with third parties. For example, we use HubSpot (customer relationship management software) to store certain personal information securely in connection with the Hanei Ltd Retailer Pilot Scheme. We will not share any of your personal information other than for the purposes described in this privacy notice.

8. Data transfer and access across borders

The collection of information and its processing prior to transfer are subject to the national laws where it is collected and/or where the data subject is located, and conditions for or restrictions on its transfer according to those laws are respected by Hanei Ltd.

Where we transfer personal data, we ensure that the organisations and individuals with access to that data comply with robust security standards and are subject to strict contractual obligations regarding non-disclosure and data protection. Where a transfer is taking place to a jurisdiction without an adequacy decision recognised by the UK, this may include placing the party gaining access to the information under contractual obligations to protect it to appropriate standards (such as by putting Standard Contractual Clauses in place or implementing appropriate safeguards) or by relying on an applicable derogation.

9. Data Retention

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy notice and to comply with our legal and regulatory obligations. The period varies depending on the nature of the personal information and what we do with it.

For those taking part in the Hanei Ltd Retailer Pilot Scheme, if you book a pilot and we visit you: we may keep your details for 6 years from the end of our pilot relationship. If you submit the form and we don't end up visiting (e.g. if you cancel, we can't reach you, or you change your mind): we will delete your details within 12 months after submission. However, in some cases, such as if there is a dispute or a legal action, we may be required to keep personal information for longer.

10. Your rights

You have various rights regarding your personal information. For example, at any time you can ask us for a copy of your personal information, ask us to correct mistakes, change the way we use your information, or even ask us to delete it. We'll either do what you've asked or explain why we can't – usually because of a legal or regulatory issue.

To contact us about any of your data subject rights, please use the details of the Data Protection Officer provided below. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request we will tell you why.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in a secure electronic format, unless otherwise requested.

The right to rectification

We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you believe that any of the personal information we hold is incorrect, please let us know so that we can update or amend it.

The right to erasure

In certain circumstances you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or if you withdraw your consent (where applicable). However, this will need to be balanced against other factors, for example there may be legal and regulatory obligations which mean we cannot comply with your request. Please note that if we erase your personal data, this may restrict our ability to provide our services to you.

Right to restriction of processing

You are entitled to ask us to stop using your personal information. If you request that we restrict processing of your personal data, this may also restrict our ability to provide our services to you.

Right to data portability

You have the right to ask that we transfer any personal information that you have provided to us in connection with our services to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing

You can ask us to stop sending you marketing messages at any time by contacting us at the details provided below.

Right not to be subject to automated decision-making

You have the right not to be subject to decisions that are made automatically by inputting your personal information into a system or computer.

The right to withdraw consent

For certain uses of your personal information, we may ask for your consent. Where we rely on this lawful basis, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting us via the details provided in the section below. Please note in some cases we may not be able to provide our services to you if you withdraw your consent.

The right to lodge a complaint

You have a right to complain to the Information Commissioners Office in the UK, or the relevant Data Protection government body in the country you reside at any time if you object to the way in which we use your personal information. Regarding the ICO, further information can be found on the UK Information Commissioner's Office website: https://ico.org.uk.

Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request we will tell you why.

11. Cookies and Tracking

We don't use third-party advertising cookies on this website. The Hanei Ltd Retail Pilot Scheme landing page uses HubSpot's analytics cookie to count visits and measure how well the page is working. Your personal information will not be processed unless you submit the form to sign up to the scheme. You can also decline this cookie when you arrive on the page using the cookie banner. Declining won't affect your ability to submit the form.

12. Contact details of the Data Protection Officer

The Data Protection Officer:
Hanei Ltd
South Park Studios, 88 Peterborough Road,
London SW6 3HH
England
Email address: info@hanei.uk