This policy applies to all the personal data (personally identifiable information) we process regardless of how it was captured by electronic means, paper records, in person or via social media and how that data is stored or whether it relates to past or present customers, supplier contacts, shareholders, website users or any other Data Subject (Individuals).
We are 100% committed to protecting your personal information and we shall always be transparent with you about how we are using your details. This document outlines how we do this, and regardless of the personal data we hold we shall process your personal data in full accordance the EU General Data Protection Regulation GDPR and the UK Data Protection Act 2018. We will be open about what information we collect, why we need it, and how we intend to use it. This document explains how we obtain, collect, process and store information about you, if we share with any third parties and details of your rights.
Full business contact information is at the end of this policy.
HubGem have core beliefs regarding your data:
- We will never sell, rent, distribute or make public your personal data
- Data should only be collected and processed when absolutely necessary
- We have duty of care to hold this data safe
- The rights of the data subject remain lawful, fair and transparent
Who is responsible for managing my information?
This website is owned and maintained by HubGem Marketing. All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
We do utilise cloud computing applications such as HubSpot, and Office 365, which potentially means that data may be stored outside of the UK.
How do we receive your personal data?
We may collect or otherwise receive your Personal Data when:
- you visit and interact with our Website;
- you provide it to us directly as a client or prospective client, including by way of contacting us via telephone, email, mail, or a contact form, or live chat service on our Website;
- you click on one of our advertisements, social media posts, or open one of our emails;
- you register and attend one of our live events;
- we receive it from other affiliates within HubGem or
- we obtain it from publicly available sources.
On what basis do we process your information?
We collect your personal data directly from our website and via email and telephone. We maintain records of customer contact, which falls under the lawful basis of legitimate interest (GDPR Article 6(f)) and under the lawful basis of being necessary for the performance of a contract (GDPR Article 6(b)).
Personal data is processed entirely for the legitimate interest of maintaining contact between us and you (our customer, or potential customer) in order to deliver our service and fulfil any contracts, which exist between us. We do not process any special category data within the meaning of GDPR.
We may process your Personal Data for purposes of:
- providing you with access to our Website;
- managing our relationship with you;
- selling and supporting our Services to you;
- responding to your requests and questions;
- sending you marketing communications about our business that you have expressed interest in, or which we think may interest you;
- collecting payment for our Services;
- measuring and improving our Website, Services, and marketing initiatives; and
- enforcing our legal obligations and complying with applicable laws and regulations.
What information do we collect?
Personal and sensitive data is required to allow us to provide our services to our clients.
We may process the following types of Personal Data about Website visitors:
- basic identifying information, such as your name and surname;
- contact information, such as your email address;
- professional information, such as your place of work; and
- identifiers and device information, such as your IP address and associated location, device ID, operating system, and website navigational information, such as information about your interaction with the Website.
We may process the following types of Personal Data in connection with our Services:
- basic identifying information, such as your name and surname;
- contact information, such as your email address, postal address, and phone number;
- professional information, such as your job title, position, and information about your organization; and
- billing information, such as your bank account number.
Cookies are small text files that are placed on your computer when you access a website.
Our website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.
For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy below.
How do we use and store your information?
We may process your Personal Data on the basis of:
- your consent;
- the need to perform a contract that we entered into with you;
- our legitimate interests, such as our interest in marketing and selling our Services;
- our obligation to comply with applicable law; or
- any other ground, as required or permitted by applicable law.
Where we process your Personal Data based on your consent, you may withdraw your consent at any time. However, this will not affect the lawfulness of our processing before your withdrawal of consent. It will also not affect our processing performed on any other lawful ground.
If we receive your Personal Data as part of providing our Services to you based on a contract, we require certain Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the Services to you.
The information you provide may be used in a number of ways, for example:
To personalise visits to our website, through Google Analytics and HubSpot we are able to understand how our clients found our website and are able to track their journey through the website which enables us to provide a better service.
When you complete a form on our website, you will enter your name, email address and other personal information. This information will be saved securely in HubSpot CRM and used for the purposes outlined on the form, you may also choose to 'opt in' to other communications.
If you have chosen to 'opt-in' we may use your personal data to tell you about other products and services we think may be of interest to you via an Email Newsletter or Marketing Emails, which are sent directly from our CRM system HubSpot. You may unsubscribe at any time by clicking the link at the bottom of the newsletter or by emailing us and asking us to remove you from this service.
By using the Contact Forms and Email links, the data you input will be entered directly into our Hubspot CRM system. Visitors to our website who have submitted data via a form or email will only be contacted for marketing purposes following their submission of explicit consent to receive such communications. You can unsubscribe from communications at any time, either directly via clicking ‘Subscription Preferences’ in our email footers, or by contacting us and asking to unsubscribe.
The website is not intended for, or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at email@example.com, so that we may delete the information.
Do we ever share personal data?
We do not share your personal data with other third-parties other than data processors as listed below.
We may also disclose your personal information to third parties in the event we sell or buy business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
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.
Do you have any third-party processors?
As previously mentioned, we interact with carefully chosen third parties who also comply with the relevant regulations and legislation. These third parties are Google and HubSpot, which are both, based in the USA and are EU-U.S Privacy Shield compliant.
Our company is located in the UK.
We transfer your personal data outside the UK unless you instruct us not to transfer your personal data to third parties located outside the UK; such transfer is necessary to provide the services you have requested from us; or it is otherwise required or permitted by law.
We may sometimes have to give our technical service providers access to our information systems and the information stored on them, which may include your personal information. Depending on the circumstances, the people who get access to that information might be outside the UK and the European Economic Area. However, any access they have will be controlled by a contract which keeps to UK data-protection laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
When can we contact you in the future?
We would like to send you information about our own products and services, as well as those of selected third parties. We may do this by post, telephone, email or SMS, unless you have told us that you do not wish to be contacted in this way. We will always ask you to confirm in advance that you are happy for us to allow third parties to contact you by email.
If you would like to change any of your preferences relating to the way in which we may use your information for direct marketing, then please update your user preferences or send an email to firstname.lastname@example.org
How long will we hold your information for?
We have a system of retention periods in place to ensure that your information is only stored whilst it is required for the relevant purposes or to meet legal requirements. Where your information is no longer required, we will ensure it is disposed of in a secure manner from our systems.
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 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, requirements.
In some circumstances you can ask us to delete your data: see your legal rights 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.
What are your rights as a data subject?
If you are a Data Subject about whom we store Personal Data, you have certain data protection rights under applicable privacy laws.
Please note that you can only exercise these rights with respect to Personal Data that we process about you when we act as a data controller. To exercise your rights with respect to Personal Data processed by us on behalf of one of our clients, please read the privacy notice(s) of our clients.
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 use 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. If you wish to exercise any of the rights set out above, please contact us.
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.
Does this policy apply to linked websites?
What happens if there is a data breach?
As per the GDP regulations all data breaches will be reported to the ICO within 72 hours.
This includes those of any 3rd parties where it's apparent that personal data stored has been compromised.
Who can we contact if we have any queries about this policy or how our data is held?
By email: email@example.com
Or write to us at HubGem Marketing, 27 Main Street, Scothern, Lincoln, Lincolnshire. LN2 2UJ. Or call us on +44 740 117 1651
Last updated: 24th February 2023
"Service"). Under the GDP and Data Protection Act 2018, we will ask for your specific consent to using cookies when you visit the service.
What are cookies?
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
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
Cookies used by our service providers
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date Information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
Blocking all cookies will have a negative impact upon the usability of many websites if you block cookies, you will not be able to use all the features on our website.