1 Scope of this notice
1.1 Huboo Technologies Limited (Huboo, we, us or our) is committed to respecting and protecting your privacy. This Privacy Notice sets out what we do with the personal data we process about you.
1.2 This Privacy Notice applies to our processing of personal data of (i) users of (i) huboo.com (Website), (ii) our contacts at our customers and users of our customer portal that we call our “Dashboard” which we make available to our customers who use our e-commerce fulfilment services (Dashboard) and (iii) end customers of our direct customers (end customers) where that information is provided by our direct customers in connection with our services (ie so that we can fulfil; end customer orders). We refer to the subjects of personal data we process using you or your in this Privacy Notice.
1.3 This Privacy Notice does not extend to any other websites we might link to. For information about how our customers or partners process personal data of their customers, please visit their websites directly. For example, if you order a product from one of our customers, they will have provided you with this information in their own privacy notice or policy.
2 Our Role
2.1 We are Huboo Technologies Limited (trading as Huboo), a company registered in England and Wales under company registration number 09727464. Our registered office is at 41 Corn Street, Bristol, BS1 1HT. We are registered with the Information Commissioner’s Office with registration number ZA143402.
2.2 For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (the GDPR, as and to the extent it forms part of domestic law in the United Kingdom), for the most part, Huboo is the controller of the personal data it processes about you. However, where we process personal data of end customers, to whom we make deliveries of our customers’ products, this will be personal data provided to us by our customers and we do this as data processors. In relation to such personal data, our customers are data controllers and they are required to provide data privacy information when they collect it.
2.3 We have appointed a data protection officer who has responsibility for advising us on our data protection obligations. You can contact the data protection officer at: [email protected]
3 The personal data we collect
3.1 personal data is any information relating to an identified or identifiable living person.
3.2 The persons to which this privacy notice applies may be registered companies, sole traders, partnerships or individuals. Where they are a registered company, we will process personal data in relation to our contact at that company.
3.3 The personal data we process of users of the Website will be the following details provided by individuals who would like to receive information about our services:
· email address
· phone number
We also process the following personal data of individuals who apply for a vacancy posted on our careers website pages:
· email address
· phone number
· address (at the option of the applicant)
· personal profile information, such as career and education history
We also process the following personal data of individuals who are customers of our customers and who contact us via the Website:
· email address
· phone number
· order details
· IP address
3.4 We process the following personal data of individuals who are points of contact at our customers (who may also be also users of the Dashboard):
· contact information such as email addresses and telephone numbers
· IP address (automatically collected by cookies)
In relation to end customers, we receive order details from our customers and will process the following personal data of those individuals in connection with processing and delivering orders:
· email address
· phone number
· other information required for you to place an order
3.5 We process the following personal data of individuals whose data we obtain at sales conferences, exhibitions and similar events at which we promote our services:
· email address
· phone number
4 What we do with the personal data we collect
4.1.1 if you are enquiring about our services or have otherwise provided your details so that we can follow up an initial conversation or introduction, to contact you with information you may need;
4.1.2 if you are a point of contact at one of our customers, to run and manage the customer account including providing support to you in using our services and to answer any questions you may have, including dealing with complaints or other feedback;
4.1.3 if you are an end customer, to fulfil orders that you place for goods purchased from one of our customers;
4.1.4 if you are our customer or an end customer, to provide support to you in using our services and to answer any questions you may have, including dealing with complaints or other feedback;
4.1.5 if you are an applicant for a vacancy, to process your application.
4.2 Where we contract directly with a customer, we need certain personal data to perform our contract. Where you are an end customer and we are engaged by a trader from whom you have ordered a product to fulfil and arrange delivery of your order, we do not have a contract with you, but we will need your personal data to complete your delivery. We obtain this data from our customers, with whom you placed an order. If you do not provide the necessary personal data, we will not be able to make the delivery. When end customer data is collected for the purposes of deliveries, our customer (the company you have ordered from) must tell you which personal data is mandatory for you to provide and how your personal data will be processed.
5 Our legal basis for processing your personal data
5.1 In accordance with applicable data protection laws including the GDPR, we are only permitted to process your personal data if we have a legal basis for doing so. The table below details the legal basis is in relation to each of the purposes set out above.
|Purpose||Personal data processed||Legal basis|
|To respond to requests for information about our services and becoming a customer, or follow up an initial conversation or introduction||The contact details provided by you||We process this personal data on the basis that we have your consent to do so as you have provided your contact details to use for responding with information you may need|
|To pass on your information to selected third parties if you have expressed an interest in hearing more from them via our website||The contact details provided by you||We process this personal data on the basis that we have your consent to do so because you have provided your contact details for us to pass on to the relevant third party so that they can respond to you|
|To use your personal data to set up a service from a selected third party||The personal data provided by you||We process this personal data on the basis that we have your consent to do so because you have provided your contact details for us to set this up on your behalf|
|To run and manage our customer accounts||Your name and contact details including address, telephone number and email address||We process this personal data on the basis that it is necessary to enable us to fulfil the contract that we have with our customers to deliver our services (where we liaise directly with the customer) and where we liaise with a representative from the customer, on the basis that we have a legitimate interest in such processing (which is to fulfil the contract with our customer which will usually be your employer)|
|To fulfil orders that you (as an end customer) place with traders who are our customers, either direct (using their websites) or via a third party platform (for example, eBay, Shopify or Amazon)||Your name, address, telephone number, email address, order information and any other order related information provided to us by our customer||We process this personal data on the basis that it is necessary for the purpose of our legitimate interests and the legitimate interests of our customer with whom you place an order, which is us delivering your order to you and satisfying the requirements of our contract with our customer|
|To arrange third party services necessary to fulfil your order||Your name, address, telephone number, email address, order information and any other order related information provided to us by our customer||We process this personal data on the basis that it is necessary for the purpose of our legitimate interests and the legitimate interests of our customer with whom you place an order, which is us delivering your order to you and satisfying the requirements of our contract with our customer|
|To provide support to you in using our services and to answer any questions you may have||Your name, address, telephone number and email address||We process this personal data on the basis that we have your consent to do so as you have provided your contact details to use for answering your question|
|To deal with complaints or other feedback||Your name, address, telephone number and email address||We process this personal data on the basis that we have a legitimate interest in ensuring that we can assist with your complaint or use your feedback to make improvements to our business and provide the best possible service for our customers and end customers|
|To manage online applications for vacancies||Name, email address,phone number,address (at the option of the applicant) andpersonal profile information, such as career and education history||We process this personal data for these purposes on the basis that we have a legitimate interest in dealing with applications efficiently and expeditiously|
5.2 In accordance with the GDPR, we will only retain personal data for as long as is necessary in light of the reason we are processing it. For example, if we are delivering a parcel to you, we will need to retain your name and address from when the order is received until a reasonable period after the order has been delivered to ensure that we can deal with any queries in relation to a delivery and/or in relation to any order returns processing. We will also need to process personal data relating to our customers for the duration of their account with us being active, and for a reasonable period afterwards for our record keeping purposes.
5.3 All personal data we process is stored securely in accordance with the technical and organisational security measures we have implemented to meet the requirements of the GDPR.
5.4 We do not use personal data of our customers or end customers for activities unrelated to the fulfilment services we operate.
6 Sharing your personal data
6.1 We share your personal data with third parties who help us deliver our services and in turn meet our obligations under our contracts with our customers. These are selected third parties who provide services to us in connection with fulfilling end customer orders (couriers and other delivery service providers, courier integration, label printing, order return processing and order insert production).
6.2 We will also share your personal data with selected third parties who provide other specific services, if you have expressed an interest in hearing more from them about their services, or to set up a service from a selected third party.
6.3 For the purposes of managing applications for job vacancies, we share personal data in applications with a third party (Workable Technology Limited).
6.4 Finally, we share personal data where we are required to do so in order to comply with a regulatory or legal provision.
6.5 We will never sell your personal data for direct marketing.
6.6 We only allow third parties to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. Any third party with whom we share your personal data is authorised to use it only to the extent necessary to perform the task we have engaged them as our processor to do. Any use for other purposes is strictly prohibited.
6.7 We will disclose your personal data where we are legally required to do so, for example to tax authorities, or where we need to share your personal data for the purposes of preventing or detecting crime, in connection with legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights or claims.
7 Where personal data is stored and transferred
7.1 The personal data that we collect will not ordinarily be transferred to, or stored at, a destination outside the UK or the European Economic Area (EEA).
7.2 However, if we do need to transfer your personal data outside the UK or the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data.
7.3 We will also comply with applicable UK and EEA laws designed to ensure the privacy of personal data.
7.4 Please contact us if you wish to find out more; if we ever transfer your personal data outside the UK or the EEA you can ask us for a copy of the relevant safeguards implemented in relation to the transfer.
8 Changes of Business Ownership and Control
8.1 From time to time our business will change and this may involve us selling some or part of that business. If this happens, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers.
8.2 The personal data we process may, if it is appropriate, be transferred to any new owner but always under the terms of this Privacy Notice and they will only be allowed to use that data for the same purposes for which you supplied it to us.
9 Your rights
9.1 You have a number of rights under data protection law. These rights and information about how you can exercise them are set out in this section. We may need to ask you for proof of your identity before we can respond to a request to exercise your rights detailed in this section and we may need to ask you for more information, for example to help us to identify the personal data that your request relates to. If you seek to exercise your rights we will explain to you whether or not the right applies to you as these rights do not apply in all circumstances.
9.2 We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly complex, or if you have made numerous requests, we may extend the time we take to respond by up to an additional two months. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
9.3 If you would like to exercise any of these rights, please contact us using the details provided at 2.3 above.
9.4 A right to access your personal data – You have a right to ask us for copies of the personal data that we hold about you (subject to some exceptions).
9.5 A right to have inaccurate personal data corrected – You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
9.6 A right to object to us processing your personal data – You have a right to object to us processing any personal data where we are relying on legitimate interests as the legal basis of our processing (as set out in Section 5 above). If you make a request to exercise your right to object but we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
9.7 A right to have your personal data erased – You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Notice.
9.8 A right to ask us not to market to you – You can ask us not to send you direct marketing. You can do this by following the “unsubscribe” instructions in any marketing emails we send; by changing your account settings; or by contacting us using the details above.
9.9 A right to have processing of your personal data restricted – You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights. Restricting your personal data means that we only store your personal data and don’t carry out any further processing of it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.
10.1 You are important to us, and so is protecting your personal data. We have high standards when it comes to collecting and using personal data. For this reason, we take any complaints we receive from you about our use of your personal data very seriously and request that you bring any issues to our attention by contacting us at [email protected].
10.2 You also have the right to lodge a complaint with:
· the Information Commissioner’s Officer (which regulates data protection compliance in the UK and provides information for this purpose on its website at www.ico.org.uk); or, if applicable
· a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
11 Changes to this Privacy Notice
We may change this Privacy Notice as we decide from time to time or as may be required by law. If we make any changes they will be posted on our website.
APPENDIX 1 – COOKIES NOTICE
You can block cookies at any time by rejecting their use (if they are not strictly necessary) when you use our Website or by activating the setting on your browser that allows you to refuse some or all cookies. However, if you do block cookies there may be parts of the Website that you will be unable to access or that will not function properly.
We use the following types of cookies:
Strictly necessary Cookies – These are cookies that are essential for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website. We will not ask your permission to place these Cookies on your computer. You can still block these Cookies by changing your internet browser settings as mentioned above.
Functionality Cookies – These are used to recognise you when you come back to the Website so that we can personalise our content for you, greet you by name and remember your preferences (for example, your region).
First Party Cookies – The Website may place and access certain first party Cookies on your computer. These are Cookies placed directly by us via the Website and are used only by us to improve your experience of using the Website and to improve our range of products and/or services.
Third Party Cookies – When using the Website certain third party Cookies may be placed on your computer. Third party Cookies are used on the Website for advertising purposes.
Analytic Services – Whenever you visit our website, we use a third party service, Google Analytics, for our legitimate interests, to collect standard information about your website use, such as internet logs and details of your visitor behaviour patterns. The reason we use this service is so that we can find out how many people visit the Website and the various parts of the Website. This information helps us to find out how the Website is working and how to improve it. We do not identify anyone, and we do not make or allow Google Analytics to (or attempt to) identify anyone visiting our website.
Changes to this Cookies Notice
We may change this Cookies Notice from time to time or as may be required by law. If we make any changes they will be posted on the Website.