What kinds of personal data we process
We collect and process the following information about you; first name, last name, email address, telephone number, the topics of sessions attended, and topic-based on-boarding questions.
We will also collect survey data, such as for the Performance Pulse or other assessments. This data includes company-level data, such as sector, funding stage and sales strategy, and employee-level data such as self-assessed scores, role and demographic information.
How we use your personal data and on what grounds
Based on the agreement you have concluded with us, we use your personal data to fulfil the agreement that you have made with us and to enforce the rights and obligations relating to that agreement. We also process your data to manage and develop the customer relationship, such as to contact you, send you updates relating to our service (such as newsletters), for invoicing and debt collection and invite you to customer surveys. Please note that one of the properties of the service is to establish communications with other users of our service (in specific between experts and students), so your details may be made available to other users as well to facilitate taking part in the selected class and other related communication between you. This is also part of the agreement.
We may also provide you with direct marketing and target and customise our marketing and other content in order to serve you with more relevant content and create profiles and customer segments based on your interactions with our content and other information we have collected from you. We process your data for these purposes based on the agreement you have with us or our legitimate interest if you are not our customer. If have requested your consent for the foregoing activities, we process your personal data based on that consent. You can always opt out of receiving direct marketing and other updates, and object to profiling as well as withdraw your consent.
Based on our legitimate interest we may use your personal data and other information we collect automatically to analyse and develop our products, services and business, and to better understand how our services are used. We will not use your information in an identifiable form if it is not necessary for the above mentioned purposes.
For assessments such as the Performance Pulse or other assessments, your data will be used to compile your team's reports. These reports will be shared only with the managers and employees of the companies to which they belong. Your data may be anonymised, aggregated and published as part of case studies and reports.
Disclosures and access to your personal data
We may disclose your information to authorities when we have a legal obligation or other legitimate interest to do so under applicable law.
Based on your consent we may disclose your information within the limits of the specific consent you have given. Information on revoking your consent is provided below. We may disclose your personal data to a third-party partner if you have registered for a session or course via a partner page. We may disclose your personal data in connection with a business transaction, if and to the extent necessary.
We may disclose your personal data if it is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors or shareholders, and/or to ensure the safety and security of our services.
Access to users’ personal data is limited to Uhubs personnel. Data derived of such data, such as averages, can be shared by us to relevant people such as company advisors or consultants.
As the data subject, under data protection laws you can influence on how we process your personal data in the following ways:
Right of access, rectification and erasure: You have the right to request access to your personal data we process. At your request we will also rectify any inaccurate, incomplete or outdated personal data relating to you. You also have the right to request your personal data to be erased (right to be forgotten) in accordance with applicable law.
Data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when we process your data automatically based on a contract or your consent.
Right to object to direct marketing (including related profiling): In case you do not want to receive further marketing or other updates from us or wish to opt out of profiling we do in order to offer you tailored direct marketing, you have the right to object to processing of your personal data for those purposes. Should you use your right to object, you will no longer receive direct marketing from us. You can use your right to object either by contacting us or through the unsubscribe link on electronic messages we send you.
Right to object data processing and right of restriction: You have the right to object to processing we carry out based on legitimate interest on grounds relating to your particular situation, unless we have compelling legitimate interests for the processing which override those interests. You also have the right to request the restriction of the processing of your personal data, for example, in case you object to processing as described above or contest the accuracy of your personal data.
Revocation of consent: You may revoke a consent you have given at any time by contacting us or unsubscribing from further updates from us through the unsubscribe link on electronic messages we send you. Please note that revoking your consent does not affect the legality of the processing we have carried out prior to the revocation.
To exercise your rights, please contact Matt Milligan via email at: email@example.com
Retention of data
Information we process will only be retained as long as is necessary to fulfil the above mentioned purposes or as long as we have a statutory obligation to keep your information, after which it will be deleted from our files. When you have an agreement with us, we retain your data for at least the time that agreement is in effect. After the customer relationship ends, the retention period depends on the data and its purpose of use. For example, we retain your personal data for direct marketing purposes until you have objected to it and retain invoicing and payment information for 6 years after the customer relationship has ended. We comply with statutory obligations in retaining data. If you have exercised your right to object to direct marketing, we may still keep certain information about you to comply with that request.
Clause for insertion as follows;
Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.
Our appointed data processors include:
Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: firstname.lastname@example.org.