This Policy issued by Hub365 is addressed to individuals outside our organisation with whom we interact, including visitors to our website (our “Site”) and other users of our services (“you”).
We’ve tried to keep it as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, pixel tags and browsers, then read about these key terms first. Your privacy matters to us, so whether you are new to Hub365 or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us.
Who is the Data Controller?
The Controller for the purposes of the GDPR is:
National Dealer Academy Limited trading as Hub365 Group Solutions
Managing Director: Sabina Hegarty
The Willows, Tylers Causeway, Newgate Street, Hertford SG13 8QN, Phone: 020 8368 7344
As controller we have introduced physical, electronic, administrative and managerial procedures to safeguard and secure the information we collect from you to protect your Personal Data against accidental, unlawful or unauthorised disclosure.
If you have any concerns about providing any data, you can also provide it by telephone. We have implemented appropriate technical and organizational security measures designed to ensure that your personal data remains private and secure.
Who is the Data Protection Officer?
It is not mandatory for us to appoint a Data Protection, but we feel strongly that there should be one point of contact to ensure any issue or concern is handled quickly and efficiently.
The Data Protection Officer of the controller is:
National Dealer Academy Limited trading as Hub365
1 Queens Parade, London N11 2DN
You may, at any time, contact our Data Protection Officer directly with any questions or suggestions regarding data protection.
Should you wish to make a request to access your data, please contact our Data Protection Officer, and we will provide the details securely, free of charge within a maximum of one month, unless there is any legal reason why we must not.
If at any time you should wish to opt out of receiving any communication from us, please contact our Data Protection Officer directly.
At any time you may prevent the setting of cookies through our site by adjusting the settings on your web browser, denying the setting of cookies. Also, cookies already set may be deleted at any time via your web browser. If you deactivate the setting of cookies in your web browser, it may be that not all functions of our site are fully usable.
Your Personal Information
Information you provide via our website is held on secure servers and will not be sold, shared or divulged under any circumstances except if required by law. We will only use your personal information for the purposes of delivering the service you requested when providing it.
Lawful basis for Processing Personal Data:
We have to have a lawful basis for processing your Personal Data as set out in Article 6 of the GDPR. At least one of these must apply whenever we process personal data. We have identified the following legal bases for processing your Personal Data:
In Processing your Personal Data, we may rely on one or more of the following legal bases, depending on the circumstances:
We have obtained your prior express consent to the Processing. This legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way.
Collection of Personal Data:
We may collect Personal Data about you, such as your name, address and contact details. Examples of sources from which we may collect Personal Data include the following:
We will only process and store your data for the period necessary to achieve the purpose of the storage, or as required by UK and EU law. If the storage is no longer required or the law dictates that we should no longer keep it, we will securely erase it.
Categories of Personal Data:
The categories of Personal Data about you that we may Process include:
Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; preferences; and account settings.
Contact details: telephone number; email address; and social media profile details.
Professional details: professional profile details; association memberships; qualifications and company insight data.
Device details: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Site and other technical communications information.
Payment details: billing address; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date.
Usage details: records of your use of our Site and other services, including: registrations; details of content with which you interact; votes; questions; downloads; ratings; feedback; profile views; search queries; anonymous viewings; page views; player clickstream; chapters; and favourite moments.
Analysis data: keywords, communities, trends, content quality and content importance.
Views, opinions and interests: any comments, ratings, views or opinions that you choose to send to us, post via our Site, via a survey, or publicly post via social media platforms; your community interests and solution interests.
Processing your Special Category Data (Sensitive Personal Data) (For definition see Key Terms): We do not seek to collect or otherwise Process your Special Category Data, except where:
Purposes for which we may Process your Personal Data: The purposes for which we may Process Personal Data, subject to applicable law, include:
Our Site: operating and managing our Site; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Site.
Provision of services to you: providing our Site and other services to you (including suggesting content that may be of interest to you, based on your past activity); communicating with you in relation to those services; recommending content that may be of interest to you; and recommending your content to others.
Marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law.
Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
Financial management: sales; finance; corporate audit; and vendor management.
Surveys: engaging with you for the purposes of obtaining your views on our Site or our services.
Improving our Site and our services: identifying issues with existing Site and our services; planning improvements to existing Site and our services; creating new Site and our services.
Disclosure of Personal Data to third parties
We will not share your details with anyone outside of Hub365 Group Companies, with the exception of your CV details, only after you have “opted-in” for us to do so.
Minors under the age of eighteen years old are not eligible to use our Site and we therefore ask that minors do not submit any Personal Data to us, or use any of the services provided on, through or via our Site.
International transfer of Personal Data
We will not transfer your Personal Data to other countries outside the UK.
We take every reasonable step to ensure that:
Your Personal Data that we Process is accurate and, where necessary, kept up to date;
any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
We take every reasonable step to ensure that your Personal Data that we Process is limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.
The criteria for determining the duration for which we will keep your Personal data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.
Your legal rights
Subject to applicable law, under GDPR you have rights regarding the Processing of your Personal Data, including:
This does not affect your statutory rights.
You have right to escalate a complaint to the Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf. The Authority for this is the Information Commissioner’s office, who can be contacted at, email@example.com
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact the Data Protection Officer using the contact details above. If you do request that we supply you with the personal data we hold, we will provide this within a maximum of one month and will not charge a fee for the access.
‘Controller’ means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws. In the UK this is the Information Commissioner’s Office (ICO).
‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided in Section (3)
‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
‘Special Category Data’ means Sensitive Personal Data about race or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life or sexual orientation, genetics or biometrics, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
We keep your personal information private and safe — and put you in control.
31st July 2020