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SpaceHubb Privacy and Cookies Policy


    1. Welcome to Space HubbLtd’s Privacy and Cookies policy. This policy complies with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the Data Protection Act 2018 (DPA 2018).
    2. We use this policy to notify website visitors about how we collect, use and store personal data (excluding special categories of personal data and data relating to criminal convictions and offences) through use of our website and to provide services.
    3. Under the terms of GDPR for the purposes of general sales and marketing, Space Hubb acts as the “Data Controller”, the company which manages and decides why and how your personal information is processed. This Privacy Policy sets out how we manage and protect that data.
    4. We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
    5. The purpose of this privacy policy is to give you information on how Space Hubb collects and processes your personal data through your use of theWebsite, including any data you may provide through theWebsite when you use the Website.
    6. TheWebsite is not intended for children and we do not knowingly collect data relating to children.
    7. 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.
    8. Space Hubb is the controller and responsible for your personal data (collectively referred to as "Space Hubb", "we", "us" or "our" in this privacy policy).
    9. ou have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
    10. As regards changes to the privacy policy and your duty to inform us of changes, we keep our privacy policy under regular review. This policy was last updated on 27 May 2020. We may change the policy from time to time so please revisit this page in future.
    11. 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.
    12. The Website 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.
    1. 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).
    2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      1. (a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
      2. (b) Contact Data includes billing address, delivery address, email address and telephone numbers.
      3. (c) Financial Data includes bank account and payment card details.
      4. (d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
      5. (e) 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 the Website.
      6. (f) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
      7. (g) Usage Data includes information about how you use our website, products and services.
      8. (h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    3. 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.
    4. 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.
    5. 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 goods 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.
    We use different methods to collect data from and about you including through:
    1. Direct interactions. You may voluntarily give us your Identity, Contact and Financial Data by filling in our online forms or by communicating or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      1. (a) apply for our products or services;
      2. (b) create an account on our website;
      3. (c) subscribe to our service or publications or blog;
      4. (d) request marketing to be sent to you;
      5. (e) enter a competition, promotion or survey;
      6. (f) give us feedback or contact us;
      7. (g) request us to contact you for product demonstrations, registration for events orseminars, or requests for any content and information.
    2. Automated technologies or interactions. As you interact with and browse theWebsite or interact with an email that we send to you, we may collect information about your browsing activities, we will automatically collect Technical Data about your equipment, browsing actions and patterns. This may include details of your geographic location via your IP address, your browser details and site interaction information. We collect this information through the use of cookies, server logs, and other similar tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
    3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources. For example, if you have registered with a conference or exhibition which we have sponsored or attended, we may be supplied with your details by the event organiser and the delegate list. We will only ever use this information if you have expressly agreed, and always in accordance with the usage guidelines provided by the conference organiser.
    4. Analytics providers such as Google, advertising networks and search information providers for Identity and Contact Data.
    5. Providers of technical, payment and delivery services for Contact, Financial and Transaction Data.
    6. Data brokers or aggregators for Identity and Contact Data.
    7. Publicly available sources such as Companies House and the Electoral Register based inside the EU for Identity and Contact Data.
    1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      1. (a) Where we need to perform the contract we are about to enter into or have entered into with you.
      2. (b) 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.
      3. (c) Where we need to comply with a legal obligation.
    2. 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 you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
    3. 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 what our legitimate interests are where appropriate.
    4. 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(s) we are relying on to process your personal data where more than one ground has been set out in the table below.
    5. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
      To register you as a new candidate or employer
      1. (a) Identity
      2. (b) Contact
      Performance of a contract with you
      To process and deliver our service to you including:
      1. (a) Manage payments, fees and charges
      2. (b) Collect and recover money owed to us
      1. (a) Identity
      2. (b) Contact
      3. (c) Financial
      4. (d) Transaction
      5. (e) Marketing and Communications
      1. (a) Performance of a contract with you
      2. (b) Necessary for our legitimate interests (to recover debts due to us)
      To manage our relationship with you which will include:
      1. (a) Notifying you about changes to our terms or privacy policy
      2. (b) Asking you to leave a review or take a survey
      1. (a) Identity
      2. (b) Contact
      3. (c) Profile
      4. (e) Marketing and Communications
      1. (a) Performance of a contract with you
      2. (b) Necessary to comply with a legal obligation
      3. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
      To enable you to partake in a prize draw, competition or complete a survey
      1. (a) Identity
      2. (b) Contact
      3. (c) Profile
      4. (d) Usage
      5. (e) Marketing and Communications
      1. (a) Performance of a contract with you
      2. (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
      To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
      1. (a) Identity
      2. (b) Contact
      3. (c) Technical
      1. (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)
      2. (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
      1. (a) Identity
      2. (b) Contact
      3. (c) Profile
      4. (d) Usage
      5. (e) Marketing and Communications
      6. (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)
      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
      1. (a) Technical
      2. (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)
      To make suggestions and recommendations to you about goods or services that may be of interest to you
      1. (a) Identity
      2. (b) Contact
      3. (c) Technical
      4. (d) Usage
      5. (e) Profile
      6. (f) Marketing and Communications
      Necessary for our legitimate interests (to develop our products/services and grow our business)
    6. In the above table:
      1. (a) Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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.
      2. (b) 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.
      3. (c) Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
    7. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
    8. 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).
    9. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
    10. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
    11. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
    12. 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.
    13. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.
    14. 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.
    15. 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.
    16. 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.
    1. 5.1 We may share your personal data with the parties set out below for the purposes set out in the table above.
      1. (a) To our shareholders, directors, employees, officers, insurers, professional advisors, agents, suppliers or sub­contractors to the extent that it is reasonably necessary to do so for the above permitted purposes;
      2. (b) If we are required to do so by law or in any legal proceedings;
      3. (c) If we need to for fraud prevention or to protect the rights, property or safety of us, our customers or others.
      4. (d) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or shareholdings or any or all of the shares in Space Hubb. 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.
      5. (e) Service providers acting as processors based in any country who provide IT and system administration services.
      6. (f) Professional advisers acting as processors or joint controllers including lawyers, solicitors, barristers, law firms, bankers, auditors and insurers based in any country who provide consultancy, banking, legal, insurance and accounting services.
      7. (g) HM Revenue & Customs (HMRC), regulators and other authorities acting as processors or joint controllers based in any country who require reporting of processing activities in certain circumstances.
    2. 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.
    1. We are an international business with a global customer base. We may need to transfer personal information between any of the countries in which we operate and to our suppliers and sub­contractors in other jurisdictions. This will involve transferring your data outside the European Economic Area (EEA).Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
    2. We do not transfer any data to third countries or international organisations unless they are deemed by applicable law to have adequate privacy protection or recognised legal mechanisms are in place to ensure adequate protection of your information (e.g. EU Model Contract Clauses or EU-US Privacy Shield or Swiss-US Privacy Shield frameworks).
    3. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    4. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    5. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
    1. 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.
    2. 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.
    3. We restrict access to personal information to our employees, contractors and agents on a needtoknow basis and ensure that they are subject to contractual confidentiality restrictions and may be subject to disciplinary procedures or dismissed if they fail to meet those obligations.
    1. How long will you use my personal data for?
    2. 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.
    3. 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.
    4. We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal purposes.
    5. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
    6. 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.
    1. You have the right to:
      1. (a) 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.
      2. (b) 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.
      3. (c) 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.
      4. (d) 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.
      5. (e) 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:
        1. (i) If you want us to establish the data's accuracy.
        2. (ii) Where our use of the data is unlawful but you do not want us to erase it.
        3. (iii) 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.
        4. (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      6. (f) 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.
      7. (g) 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.
    2. If you wish to exercise any of the rights set out above, please contact us.
    3. 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.
    4. 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.
    5. 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.