1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3 This privacy policy was last updated on 3 May 2018

2. How we use your personal data

2.1 In this Section 2 we have set out:

  1. the general categories of personal data that we may process;

  2. the purposes for which we may process personal data; and

  3. the legal bases of the processing.

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account and profile data ("account and profile data”). The account and profile data may include your name and email address, address, telephone number, profile picture, date of birth and social media ids. The source of the account and profile data is you on registration via www.hubbub.org.uk. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4 We may process your personal data that are provided in the course of the use of our services ("service data”). The service data may include your name and email address, address, telephone number, profile picture, date of birth and social media ids. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and for the purposes of performance of a contract.

2.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.6 We may process information contained in any enquiry you submit to us regarding products, campaigns and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business,

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.13 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to Hubbub Foundation Enterprise Limited which is our wholly owned subsidiary insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your personal data to partners of a specific campaign or service insofar as reasonably necessary for the delivery of the specific campaign or service. You will be asked for consent for this in advance of your participation.

3.4 Financial transactions relating to Hubbub Foundation UK and Hubbub Foundation Enterprise Limited may be handled by our payment services providers PayPal, Stripe, Xero and Moneysoft. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Any subcontractor will be covered by confidentiality obligations.

3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 These transfers are subject to special rules under UK and European law.

4.3 We use subcontractors which are situated in the United States of America. Transfers will be protected by appropriate safeguards. We share data with Mailchimp whose privacy policy may be accessed via the following link: https://mailchimp.com/legal/privacy/ and Xero whose privacy policy may be accessed through the following link: https://www.xero.com/uk/about/terms/privacy/

4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

  1. Personal data collected for a specific campaign or service will be retained for the length of the campaign or service delivery.

  2. Personal data that is account and profile data, enquiry data, notification data or correspondence data and will be retained until the point at which you decide to no longer receive communications from us, via unsubscribing to newsletters or contacting us directly.

  3. Transaction data from purchases of services and goods will be retained in order to prove the original transaction and to communicate any essential information related to the service or good purchased.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store all data on secure servers.

6.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.5 You acknowledge that the transmission of inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password except when you log in to our website.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

  1. the right to access;

  2. the right to rectification;

  3. the right to erasure;

  4. the right to restrict processing;

  5. the right to object to processing;

  6. the right to data portability;

  7. the right to complain to a supervisory authority; and

  8. the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data]by visiting https://www.hubbub.org.uk/my-details when logged into our website.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.(including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

  1. consent; or

  2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. Our lead supervisory authority is the Information Commissioners Office (ICO) in the United Kingdom which may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us (please see paragraph 16.4 below), in addition to the other methods specified in this Section 8.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

10.1 Our website and services are targeted at persons over the age of 18.

10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. You may also update your profile data directly via your account on our website when logged in to: https://www.hubbub.org.uk/my-details.

12. Acting as a data processor

12.1 In respect of personal data collected through our partners, we do not act as a data controller; instead, we act as a data processor.

12.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13. About cookies

13.1 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.

13.2 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.

13.3 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.

14. Cookies that we and our service providers use

14.1 We use cookies for the following purposes:

Cookie name - Used by - DescriptionExpiration

__utma

Stores the amount of visits of a user, the time of their first visit, the previous visit, and the current visit. It does not contain any personal information and is used only for analytical purposes. 2 years from set/update.

__utmz Google Analytics

This performance cookie stores where a user came from (eg. search engine, search keyword, link),6 months from set/update.

_ga and _gid Google Analytics

Used to distinguish between website users in Google Analytics. 2 years and 2 hours.

_gat_UA-56140343-1 Google Analytics

Used to moderate calls to the Google Analytics service. 1 minute

__unam ShareThis

Set as part of the ShareThis service and monitors "click-stream" activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc. The ShareThis service only identifies a user if they have separately signed up with ShareThis for a ShareThis account and given them consent. Checks how long you stay on a site: when a visit starts, and ends. It does not contain any personal information and is used only for analytical purposes.14 months

cc_cookie_accept Website

Stores whether the user has accepted the cookie message or not.365 days

ASP.NET_SessionIdWebsiteUsed for authenticating a user's session after logging in. Closes when you exit the browser.End of session

ARRAffinityWebsiteTells our infrastructure which server to handle the request.End of session

MemberLoggedInWebsiteA binary flag which stores whether a user is logged in or not.End of session

ai_session and ai_user Website

Tracks users as they navigate the website predominately for infrastructure performance insights.1 day

DisplayName Website

Keeps track of a donors preference to show their name during a Direct Debit.End of session

__cfduid CloudFlare

Identify individual clients behind a shared IP address and apply security settings on a per-client basis.365 days

14.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

14.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

15. Managing cookies

15.1 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:

  1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);

  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

  3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);

  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

  5. https://support.apple.com/kb/PH21411 (Safari); and

  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16. Our details

16.1 This website is owned and operated by Raising IT Ltd.

16.2 Hubbub Foundation is registered in England and Wales under the registered charity number 1158700. Hubbub Foundation Enterprise Limited is owned by Hubbub Foundation and is registered in England and Wales under the company number 08910364. Our registered office is at Somerset House, New Wing, The Strand, London, WC2R 1LA.

16.3 Our principal place of business is at Somerset House, New Wing, The Strand, London, WC2R 1LA.

16.4 You can contact us:

  1. by post, to the postal address given above;

  2. using our website contact form;

  3. by telephone, on the contact number published on our website from time to time

  4. by email, using hello@hubbub.org.uk

17. Data protection registration

17.1 We are registered as a data controller with the UK Information Commissioner's Office.

17.2 Hubbub Foundation UK's data protection registration number is ZA337004. Hubbub Enterprise's data protection registration number is ZA392036.