Your privacy is extremely important to us. This privacy notice aims to give you information on how we collect and process your personal data and how you can check and update any of your personal data.

This website is not intended for children and we do not knowingly collect data relating to children.

It’s important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

 

Controller

Hub4Leaders Ltd. is the controller and responsible for your personal data (collectively referred to as “Hub4Leaders Ltd.”, "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: dpo@hub4leaders.co.uk

Postal address: Elmwood Court, Springwood Close, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XF

Telephone number: 01625 464420

You 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.

 

Changes to the privacy notice and your duty to inform us of changes

We want to ensure that we provide you with the best possible service. Please therefore always keep us updated of any changes to your personal information, for example, if your email address changes.

 

Third-party links

Our 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 notice of every website you visit.

 

The data we collect about you

We collect your personal data to help manage your account and to tell you about our products and services. The law also requires us to keep some personal data. The personal data we do keep relates only to your business role and would includeour name, job title and contact details. 

 

  • Identity Data includes first name, last name and job title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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 this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

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.

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.

 

How your personal data is collected

We use different methods to collect data from and about you including:

  • Filling in paper-based forms, such as interest forms and order forms, or by corresponding with us by post or telephone.
  • Filling in online forms, or corresponding with us via platforms, such as Interact, Sleeknote, SurveyMonkey, Join.me and by email, when you:
    • Purchasing our products or services online;
    • Create an account on our website;
    • Subscribe to our newsletters service or selected information sources;
    • Register for a free trial of our services;
    • Request marketing information to be sent to you;
    • Enter a competition, promotion or survey; or
    • Provide us with feedback.

 

Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see ‘We use the following types of cookie’ for further details.

 

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

  • Analytics providers such as Google Analytics and Twitter
  • Advertising networks such as Google Display Network and Facebook/LinkedIn
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SAGE and Stripe.
  • Identity and Contact Data from publicly availably sources such as individual school websites

 

Where your personal data is stored

We store your personal data in a variety of places, including in:

  • Customer relationship management software such as Insightly, cloud-based servers such as Microsoft, finance management services such as Sage and Stripe.
  • Internal company servers and personal computers
  • Office filing cabinets
  • Mobile phones

 

How we use your personal data

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:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.

 

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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

We use and analyse your information to keep in touch with you and to deliver and improve our products and services. We will also use your information to tell you about products and services we believe will be of interest to you.

In particular, this means using your data to;  

  • Register you as a new customer and help you manage your account
  • Process and deliver your order, manage your payments and renewals
  • Contact you, for example to help with any problems you are having with the service
  • Collect or recover money you may owe us
  • Notify you about changes to our services and policies
  • Look into any complaints or questions you may raise
  • Update you with any changes to our products and services
  • Improve our products and services and to develop new ones
  • Use data analytics to improve our overall service experience
  • Send you our regular customer newsletter
  • Let you know about our services and products

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

You can ask us to stop sending you direct marketing messages at any time by writing to or emailing us at dpo@theschoolbus.net.

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.

 

We use the following types of cookie:

Analytics cookies that anonymously remember your computer or mobile device when you visit our website. They keep track of browsing patterns and build up a profile of how our readers use the website.

Service cookies that help us to: make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; and meter the number of pages you view. Service cookies are also used to administer the website (load balancing) and to secure, validate and identify authenticated user sessions.

The sole third-party cookie comes from Twitter which is used to allow our Twitter feed to work – Twitter’s cookie policy

We have no access to third party cookies and third-party organisations have no access to ours. Other than allowing the third-party cookies to be served, we have no part to play in the use of these cookies although we may obtain statistical information from them about advertising on our site. The third-party organisations that place cookies have their own strict privacy policies.

Most browsers allow you to turn off cookies. However, switching off cookies will restrict your use of the website and/or delay or affect the way in which the website operates.

 

Change of purpose

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.

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.

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.

 

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 notice.
  • 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.

 

Transfer of data outside the European Economic Area (EEA)

Some 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.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries

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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

Data security

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.

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.

 

How long will you use my personal data for?

By law we must keep basic information about our customers and suppliers (including Contact, Identity, Financial and Transaction Data) for tax purposes seven years after they cease being customers or suppliers.

Master user personal data (including Contact and Identity Data) will be retained for six years after their school ceases being customers, in case it is required to assist in resolving any legal disputes. The master user is defined as an authorised user who is also the main point of contact between the customer and Hub4Leaders.

Authorised user data (including Contact and Identity Data) will be retained for one year after their school ceases to be customers, to provide sufficient time for the school account to be closed without unintended loss of data. An authorised user is a user of the service who is not a master user.

Prospect user data (including Contact and Identity Data) will be retained for two years to keep a record against publicly available data, and to ensure informed conversations in future. A prospect user is a potential customer who has provided data through our, or named sub-processor’s, service.

In some circumstances, you can ask us to delete your data − see Request erasure below for further information about when this right applies.

At the end of our retention periods, we may 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.

Your legal rights

Under certain circumstances, data protection laws in relation to your personal data allow 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

 

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In such cases, we will notify you and keep you updated.

 

Third Parties

We make use of External Third Parties

Service providers acting as processors based in the EU and the US who provide IT and system administration services.

Professional advisers acting as processors, including lawyers, bankers, auditors and insurers, based in the EU, who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities, acting as processors, based in the United Kingdom who require reporting of processing activities in certain circumstances.

 

Lawful Basis

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.

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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

 

 

APPENDIX 1

Name of sub-processor

Type of data processed

EU/Non-EU based

Interact

Identity, Contact

Non-EU

Sleeknote

Identity, Contact

Non-EU

SurveyMonkey

Identity, Contact

Non-EU

Join.me

Contact

Non-EU

Mailchimp

Contact

Non-EU

SAGE

Contact, Financial, Transactional

EU

Microsoft

Identity, Contact

EU

Insightly

Identity, Contact

Non-EU

Google

Technical

EU

Twitter

Technical

Non-EU

Facebook

Technical

Non-EU

LinkedIn

Technical

Non-EU

Get information about schools

Identity, Contact

EU

Individual school websites

Identity, Contact

EU

Atlassian

Identity, Contact

Non-EU

SendGrid

Identity, Contact, Financial, Transactional

Non-EU

Postmark

Identity, Contact, Financial, Transactional

Non-EU

Stripe

Identity, Contact, Financial, Transactional

Non-EU

NetSuite

Contact, Financial, Transactional

Non-EU

 



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