Privacy Policy
This policy explains what personal information HPS Holding LLC collects through this website and in the course of providing services, why we collect it, and the choices you have.
Last updated: May 12, 2026 · Effective: May 12, 2026
HPS Holding LLC (“HPS Holding”, “we”, “us”) is the controller of the personal information described in this policy. Our registered office is 375 Embarcadero, Hartford, Connecticut 06132, USA. This policy applies to su.hpsholding.com and to our business dealings with clients, prospective clients, suppliers and job applicants.
1. Information we collect
We collect only what we need to answer enquiries and deliver services.
Information you give us
- Contact details — name, company, job title, work email address, telephone number.
- Enquiry content — the message you send us, including any commercial context you choose to include.
- Engagement information — correspondence, meeting notes and contract details relating to services.
- Recruitment information — CVs and application details, if you apply for a role with us.
Information collected automatically
- Server log data — IP address, user agent, referring URL, pages requested, date and time. Our hosting provider records these for security and diagnostics.
- Cookie data — see our Cookie Policy. Analytics and advertising cookies are only set after you consent.
Information we do not collect
We do not knowingly collect Social Security numbers, payment card data, biometric data, precise geolocation, or information from children under 16 through this website. We do not ask for special categories of personal data.
2. How we use information
| Purpose | Categories used | Legal basis / justification |
|---|---|---|
| Responding to enquiries | Contact details, enquiry content | Steps taken at your request prior to a contract |
| Delivering and administering services | Engagement information, contact details | Performance of a contract |
| Invoicing, accounting and tax records | Contact and engagement information | Legal obligation |
| Website security and abuse prevention | Log data | Legitimate interest in keeping the site available and secure |
| Measuring website performance | Analytics cookie data | Your consent |
| Measuring advertising campaigns | Advertising cookie data | Your consent |
| Recruitment | Application information | Steps taken at your request prior to employment |
We do not sell personal information, and we do not share it for cross-context behavioural advertising as those terms are defined under the Connecticut Data Privacy Act or the California Consumer Privacy Act.
3. Cookies and similar technologies
This website sets a strictly necessary cookie (or equivalent local storage entry) to remember your consent choice. Analytics and advertising technologies are loaded only if you allow them in the consent banner. You can reopen the banner at any time using the Cookie settings link in the footer, and you can clear stored choices through your browser settings.
Full detail, including retention periods for each category, is set out in our Cookie Policy.
4. Sharing your information
We share personal information only in these circumstances:
- Service providers acting on our instructions — website hosting, email delivery, document storage, accounting and IT support. Each is bound by written confidentiality and data-protection terms.
- Professional advisers — our lawyers, auditors and insurers, where necessary.
- Legal requirements — where disclosure is required by law, court order, or a lawful request from a public authority.
- Business transfer — if the firm or part of it is sold or reorganised, subject to the acquirer honouring this policy.
We never disclose one client’s commercial data to another client, and supplier pricing obtained under an engagement is not reused outside it.
5. Data retention
| Record type | Retention period |
|---|---|
| Enquiries that do not become engagements | 24 months from last contact |
| Client engagement files | 7 years after the engagement ends |
| Client-supplied raw data sets | Returned or securely destroyed within 60 days of engagement close |
| Invoices and accounting records | 7 years (tax requirement) |
| Website server logs | 90 days |
| Consent records | 24 months |
| Unsuccessful job applications | 12 months, unless you ask us to keep them longer |
6. How we protect information
- Encryption in transit (TLS) across the website and all client file exchange.
- Encryption at rest for stored client data on US-based infrastructure.
- Role-based access — consultants can access only the engagements they are assigned to.
- Multi-factor authentication on all business email and file storage accounts.
- Mutual non-disclosure agreements signed before any client data is transferred.
- Annual security awareness training for all staff and a documented incident response procedure.
No system is perfectly secure. If a breach affects your personal information and creates a risk to you, we will notify you and the relevant authorities within the timeframes required by applicable state law.
7. Your rights
Depending on where you live, you may have the right to:
- confirm whether we process your personal information and obtain a copy of it;
- correct inaccurate information;
- delete information we hold about you;
- obtain your data in a portable format;
- opt out of targeted advertising, sale of personal data, or profiling (we do not sell data or profile individuals);
- withdraw consent at any time, without affecting processing already carried out.
Connecticut residents may exercise the rights above under the Connecticut Data Privacy Act. California residents have equivalent rights under the CCPA/CPRA, including the right not to be discriminated against for exercising them. Residents of other states with comprehensive privacy laws have similar rights.
How to make a request
Email contact@su.hpsholding.com with “Privacy request” in the subject line, or write to us at the postal address below. We will verify your identity using information already held (for example, by replying to a known email address) and respond within 45 days, extendable once by a further 45 days where necessary. There is no charge for a reasonable request.
Appeals
If we decline a request, you may appeal by replying to our decision within 60 days. We will respond in writing within 45 days explaining the outcome. If the appeal is denied, you may contact the Connecticut Attorney General or your own state Attorney General.
8. International transfers
We are a United States firm and store personal information on infrastructure located in the United States. If you contact us from outside the US, your information will be transferred to and processed in the US, where data protection law may differ from that of your own country. Where we engage international suppliers on a client’s behalf, only the minimum contact information necessary is shared.
9. Third-party links
This website may link to third-party sites, such as professional bodies or supplier directories. We are not responsible for their content or their privacy practices, and we encourage you to read their policies before providing information to them.
10. Do Not Track and opt-out signals
Our website honours the Global Privacy Control (GPC) signal where a browser transmits one: analytics and advertising categories default to off and the consent banner reflects that choice. We do not respond to legacy Do Not Track headers, which lack a common standard.
11. Changes to this policy
We review this policy at least annually. Material changes will be posted here with a revised “last updated” date and, where the change significantly affects how we use your information, communicated directly to active clients.
12. Contact and complaints
HPS Holding LLC — Privacy Contact
375 Embarcadero
Hartford, Connecticut 06132
USA
Email: contact@su.hpsholding.com
Telephone: +1 (718) 462-8415
Hours: Monday to Friday, 8:30–18:00 Eastern Time
If you are not satisfied with our response you may lodge a complaint with the Office of the Attorney General in your state.
Questions about this document
Write to contact@su.hpsholding.com, call +1 (718) 462-8415, or post to HPS Holding LLC, 375 Embarcadero, Hartford, Connecticut 06132, USA, marked for the attention of the Privacy Contact.