Hub Publishing Ltd., trading as Hub Marketing Services
Registered office: 5 Minton Place, Victoria Road, Bicester, Oxon, OX26 6QB
Data Protection Officer: Richard Wormell
Company Registration Number 308 7640
ICO Registration Reference: ZA339156
We're committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure. We may change this Policy from time to time so please check this page occasionally to ensure that you're happy with any changes.
By using our website, you're agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to:
privacy@hubmarketing.co.uk
General Data Protection Regulation (GDPR)
Our website and internal processes are in line with the General Data Protection Regulation (GDPR) which aims primarily to give control back to citizens and residents over their personal data as well as address the export of personal data outside of the European Union (EU).
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. GDPR does not apply to information already in the public domain for example Companies House data.
How do we collect information from you?
We obtain information about you when you use our website, for example, when you contact us about products and services, to make an online purchase or if you register to receive one of our newsletters.
Hub Publishing Ltd. also acts on behalf of its clients in the capacity of data processor. A data controller and data processor agreement is in place to safeguard your interests and establish a clear line of responsibilities. We only collect the information needed to provide our clients with the marketing services necessary to perform the contractual obligations we have to our clients, for example direct marketing.
When working exclusively as a data processor, Hub Publishing Ltd. will be acting on the instruction of its client who are the data controller and who have their own privacy policy which we encourage you to read on their website. Our client may provide us with your personal information to process on their behalf. Although the information about you may be from their own database coincidentally there may be times when your information could be contained in data that we have purchased on behalf of our client from Market Location who are a third-party list provider. The lawful basis to do so is set out in Article 6 of the GDPR, and in particular: Article 6(1)(f) Legitimate interests. Market Location's privacy & fair processing notice is here.
We also obtain information about you when you use our website, for example, when you contact us about products and services, to make an online purchase or if you register to receive one of our newsletters.
What type of information is collected from you?
The personal information we collect might include your name, address, your email address e.g. privacy@hubmarketing.co.uk, your company name and role, IP address, and information regarding what pages are accessed and when. If you purchase a product from us, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions, as explained below.
The purposes of the processing: how is your information used?
We may process your personal information for our legitimate business interests. We may use your information to carry out our obligations arising from any contracts entered into by you and us; to act on behalf of our clients in the capacity of data processor and to fulfil our contractual obligations as a data processor. If we are working exclusively as a data processor acting on the instruction of our client we will strive to ensure that our client complies with GDPR and PECR regulations. We use the information collected from you for direct marketing, for example to email or post you marketing information which we believe may be of interest to you and your business. Also to make telephone contact, provide estimates and quotations, to modify or improve our services, determine the effectiveness of promotional campaigns and advertising, data analytics & enhancement.
We may also use your information to:
to carry out our obligations arising from any contracts entered into by you and us;
dealing with entries into a competition;
seek your views or comments on the services we provide;
notify you of changes to our services;
send you communications which you have requested and that may be of interest to you. These may include information about our goods and services;
process a job application.
In you making initial contact you consent to us maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. We will only collect the information needed so that it can provide you with our marketing services.
Our legitimate interests and the basis for processing
Our legitimate interest is to meet Hub Publishing Ltd.'s contractual obligations to its clients and to respond to marketing enquiries.
You have the right to object to this processing if you wish and if you wish to do so please email privacy@hubmarketing.co.uk
Legitimate Interest Assessment Summary:
to meet Hub Publishing Ltd.'s contractual obligations to its clients and to respond to marketing enquiries.
to meet our interest in providing marketing services to our clients that is relevant to their clients who are individuals, for this reason we may process personal information to send marketing that is tailored to your interests and industry.
data processing enables us to enhance, modify, personalise or otherwise improve our services & communications for the benefit of our customers and wider target audience.
data processing helps us to determine the effectiveness of our campaigns and advertising.
it is reasonable to consider legitimate interest as grounds for the processing of personal data for business to business (b2b) direct marketing purposes, given the very limited amount of personal information being processed; the fact that it is being used solely for the purposes of marketing to the business for which the individual works and not the individual him/herself. The individuals concerned are likely to be people within the organisation who would expect to be contacted for business communications. In the context of b2b direct marketing our communications relate to business services rather than the personal life of the individuals receiving the communications. This interest could not be achieved without requiring disproportionate effort and without having to use the personal data.
Legitimate interests pursued by Hub Publishing Ltd.'s and/or its clients
To promote the marketing services offered by Hub Publishing Ltd. and/or to market the services and/or products offered by Hub Publishing Ltd.'s existing clients.
The retention periods for the personal data
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
Who has access to your information?
Third Party Service Providers working on our behalf:
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our own behalf or to fulfil our contractual to our clients, for example to send you direct mailings by email or post. One such third party for example is the email marketing platform that is operated by Extravision.
However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and contracts are in place that require them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. We do not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Hub Publishing Ltd. has purchased from a third-party list broker, on behalf of a client.
The relevant third party product provider will use your details to provide you with information and carry out their obligations arising from any contracts entered into with them. In some cases, they may be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. These third party product providers will share your information with us which we will use in accordance with this Privacy Policy. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we're under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Legal basis for processing any personal data
To meet Hub Publishing Ltd.'s contractual obligations to its clients, act as a data processor on behalf of our clients, and to respond to marketing enquiries.
Legitimate interests pursued by Hub Publishing Ltd. and/or its clients
To promote the full service marketing agency services offered by Hub Publishing Ltd. To meet Hub Publishing Ltd.'s contractual obligations to market the services and/or products offered by Hub Publishing Ltd.'s existing clients.
The legal basis for processing the data is the legitimate interest pursued by us as the data processor, or in some cases, as the data controller. Our lawful basis to do so is set out in Article 6 of the GDPR, which includes: Article 6(1)(f) "(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual's personal data which overrides those legitimate interests"; and Recital 47 of the Official Journal of the European Union: " The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest". The purpose for processing the data including our legitimate interests are set out above in 'How is your information used?'. At anytime you are entitled to object and ask us not to send you any commercial communications.
Privacy and Electronic Communications Regulations (PECR) allows electronic direct marketing communications to be sent to corporate subscribers (business email addresses of individuals working for incorporated entities) without prior consent, unless the recipient specifically requests not to receive emails from the sender (“opt-out”). Each direct marketing email includes an “unsubscribe” option to allow the individual to notify the sender that he/she no longer wishes to receive emails from the sender.
You can find out more about Legitimate interests on the Information Commissioner's Office (ICO) website and at Official Journal of the European Union.
Your choices
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information. If you receive an email marketing communication you can click to unsubscribe on the email.
You are entitled to ask us at any time, not to send you any commercial communications. You can change your marketing preferences at any time by contacting us by email:
privacy@hubmarketing.co.uk,
How you can access and update your information
The accuracy of your information is important to us. We're working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your email address, or any of the other information we hold is inaccurate or out of date, please email us at:
You have the right to ask for a copy of the information we hold about you.
Please email us at: privacy@hubmarketing.co.uk,
Complaints
In the event that you wish to make a complaint about how your personal data is being processed you have the right to complain to the Managing Director of Hub Publishing Ltd.. If you do not get a response or if you prefer you can complain to the ICO.
Hub Publishing Ltd, attention of Managing Director, Hub Publishing Ltd., 5 Minton Place, Victoria Road, Bicester, Oxon, OX26 6QB. Tel: 01865 770770
ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Tel: 0303 123 1113
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it's treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear in the address bar of most web browsers or on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your privacy@hubmarketing.co.uk etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Profiling
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.
Use of 'cookies'
Like many other websites, our website uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps us to improve our website and deliver a better more personalised service.
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies of may result in a loss of functionality when using our website.
Analytics and Customization Cookies
These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are, or to help us customize our websites and application for you in order to enhance your experience.
Google
Google Analytics gathers information allowing us to understand interactions with our websites and ultimately refine that experience to better serve you.
Cookie file names:
_ga
Used to distinguish users.
_gid
Used to distinguish users.
_gat
Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
AMP_TOKEN
Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<property-id>
Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out.
__utma
Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.
__utmt
Used to throttle request rate.
__utmb
Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.
__utmc
Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
__utmz
Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
__utmv
Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.
__utmx
Used to determine a user's inclusion in an experiment.
__utmxx
Used to determine the expiry of experiments a user has been included in.
Wordpress
Wordpress provides the content management of the website and will store cookies based on whether you are logged in or not.
Cookie file names:
wordpress_[hash]
wordpress_logged_in_[hash]
wp-settings-{time}-[UID]
Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you're agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
Review of this Policy
We keep this Policy under regular review. This Policy was last updated in 24 May 2018.