PRIVACY AND COOKIES POLICY

This is the Privacy and Cookies Policy (the “Policy”) of Hubber Ltd a limited company registered in England and Wales with a registered company number of 11591844 and a registered address at 8 Dean Street, London W1D 3RL (hereafter “Hubber”, “we” or “us”). This Policy describes the ways in which Hubber collects and uses information about you when you visit our website at hubber.biz (the “Website”), use (as a Salon) our website at salon.hubber.biz (the “Salon Website”) or use (as a Stylist) our mobile application (the “App”).

Hubber may change this Policy at any time in which case we shall notify you of any changes to this Policy. The changes will apply to your use of the Website, Salon Website and/or App (as applicable) after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Website, Salon Website and/or App (as applicable). If you continue to use the Website, Salon Website and/or App (as applicable) after the date on which the change comes into effect, your use of the Website, Salon Website and/or App (as applicable) indicates your agreement to be bound by the new Policy.

For the purposes of data protection legislation, Hubber is the controller for the processing of your personal data. Hubber has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. Hubber’s registration number is ZA490777.

Important information for Hubber Stylist customers: If you are a customer of a Hubber Stylist, your Stylist may provide you with a link referencing an appointment made within our system. We do not process any of your personal data and all contact is directly with your Stylist alone.

This Policy was last changed on 8 March 2019.



SECTION A – Your use of the Website

1. Information which is collected when you use the Website: Hubber may collect the following information from you when you use the Website:

a.   any information which you provide when you contact us via the Website, including your name, phone number, e-mail address and details of your particular query;
b.   the Unique Device Identifier or a record of the internet browser which you are using when you use the Website. This may provide an approximate location as to where you are using the Website and on what device; and
c.   the information collected by Hubber’s use of cookies and similar technologies (please see paragraph 16 below).


2. Processing ground: Hubber relies on the contractual necessity processing ground to collect the items of information listed in 1(a) above, as this information is required in order for Hubber to answer your particular query. For the information listed in 1(b) and 1(c), Hubber relies on the legitimate interests processing ground. It is necessary for Hubber to collect these items of personal data in order to provide the Website’s service to you and to maintain and improve the Website, which is Hubber’s fundamental business purpose. The items of personal data collected are, in being limited to “technical” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

 

3. How the information about you on the Website is used: The information about you described in paragraph 1 may be used by Hubber as follows:

a.   to answer your particular query;
b.   to enable Hubber to undertake administration tasks in relation to the management of the Website;
c.   to tweak, tune and facilitate the improvement of the Website;
d.   to provide technical support in relation to your use of the Website and troubleshooting;
e.   to prevent fraud or illegal activities;
f.    to use such information in anonymised form for its own research and marketing purposes; and
g.   to share with third parties as described in paragraph 10 below.



SECTION B - Your use of the Salon Website

4. Information which is collected when you use the Salon Website: Hubber may collect the following information from you when you use the Salon Website:

a.   any information which you enter into the Salon Website when creating an Account including your name, phone number, e-mail address, organisation details (including amenities), bank details, and any other details that you provide to us during the registration process;
b.   the Unique Device Identifier or a record of the internet browser which you are using when you use the Salon Website. This may provide an approximate location as to where you are using the Salon Website and on what device; and
c.   the information collected by Hubber’s use of cookies and similar technologies (please see paragraph 16 below).


5. Processing ground: Hubber relies on the contractual necessity processing ground to collect the items of information listed in 4(a) above, as this information is required in order for Hubber to provide the booking services via its Salon Website. For the information listed in 4(b) and 4(c), Hubber relies on the legitimate interests processing ground. It is necessary for Hubber to collect these items of personal data in order to provide the Salon Website’s service to you and to maintain and improve the Salon Website, which is Hubber’s fundamental business purpose. The items of personal data collected are, in being limited to “technical” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.



6. How the information about you on the Salon Website is used: The information about you described in paragraph 4 may be used by Hubber as follows:

a.   to assess your eligibility for an Account (as set out in the Salon Terms);
b.   to enable Hubber to undertake administration tasks in relation to the management of the Salon Website and to provide the services that Hubber provides via the Salon Website to you, namely permitting you to obtain bookings in your Salon from Stylists;
c.   to tweak, tune and facilitate the improvement of the Salon Website;
d.   to provide technical support in relation to your use of the Salon Website and troubleshooting;
e.   to prevent fraud or illegal activities;
f.    to use such information in anonymised form for its own research and marketing purposes; and
g.   to share with third parties as described in paragraph 10 below.



SECTION C – Your use of the App

7. Information which is collected by the App: Hubber may collect the following information when you use the App:

a.   any information which you enter into the App when creating an Account including your name, phone number, e-mail address, month and year of birth, bank account details and any other details that you provide to us during the registration process;
b.   the Unique Device Identifier or a record of the internet browser which you are using when you use the App. This may provide an approximate location as to where you are using the App and on what device; and
c.   the information collected by Hubber’s use of cookies and similar technologies (please see paragraph 16 below).

8. Processing ground: Hubber relies on the contractual necessity processing ground to collect the items of information listed in 7(a), as this information is required in order for Hubber to provide the booking services via its App and, in the case of your month and year of birth, verify you meet the age requirements to access the App. For the information listed in 7(b) and 7(c), Hubber relies on the legitimate interests processing ground. It is necessary for Hubber to collect these items of personal data in order to provide the App’s service to you and to maintain and improve the App, which is Hubber’s fundamental business purpose. The items of personal data collected are, in being limited to “technical” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

 

9. How the information about you on the App is used: The information about you described in paragraph 7 may be used by Hubber as follows:

a.   to assess your eligibility for an Account (as set out in the Stylist Terms);
b.   to enable Hubber to undertake administration tasks in relation to the management of the App and to provide the services that Hubber provides via the App to you, namely to permit you to book Appointments in Salons and to remind you of upcoming appointments via text;
c.   to tweak, tune and facilitate the improvement of the App;
d.   to provide technical support in relation to your use of the App and troubleshooting;
e.   to prevent fraud or illegal activities;
f.    to use such information in anonymised form for its own research and marketing purposes; and
g.   to share with third parties as described in paragraph 10 below.

 

SECTION D - GENERAL 

10. Sharing information with third parties: Hubber shall not pass your information to any third party (other than as described in this paragraph). Your information may, subject to Hubber’s obligations to comply with applicable data protection legislation, be shared with the following third parties:

a.   its website operator, Squarespace
b.   its SMS provider (used to send reminder messages);
c.   having taken precautions to maintain the security of such information, Hubber may share this information with its regulator;
d.   in anonymised form, Hubber may share the information with:

i.       any third party, in relation to the sale of some or all of Hubber’s business, or its assets, or as part of any business restructuring or reorganisation. Hubber will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this paragraph;
ii.       data aggregators and app providers as part of an analysis of user metrics or sales performance; or
iii.       law enforcement agencies in compliance with law enforcement.


11. Links to third party websites and third party adverts: Hubber is not responsible for the privacy policies and practices of other sites even if you access them using links from the Website, Salon Website and/or App. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Website, Salon Website and/or App from a third party site or via a social network (e.g. Twitter), Hubber is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

 

12. Security: Hubber has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.

 

13. Storage and Data Retention: We store your personal data in the EEA and we retain your personal data for as long as you wish to make use of the Website, Salon Website and/or App (as applicable) and for a maximum of 28 days after you close your Account or after a period of 18 months of Account inactivity (unless otherwise required to retain it for legal reasons).
 


SECTION E - Contact with Hubber

14. Information Hubber collects and uses if you contact us or make complaints: When Hubber receives complaints by email it files any relevant document and may retain details of the complainant and other individuals identified in the complaint. Hubber will only use this information to process the complaint. Hubber shall retain information in relation to a complaint for 6 years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis.

 

15. Contacting customers: If you are a customer of a Hubber Stylist, we may contact you to inform you of your Appointment details on behalf of your Stylist. You can inform us if you do not wish us to do this at any time by contacting support@hubber.biz.

SECTION F- Cookies and Similar Technologies

16. Cookies:

a.   What are Cookies? Cookies are small text files that are placed on your device when you use the App or visit the Website. Hubber’s use of cookies is detailed below. Session cookies enable you to move from page to page within the Website, Salon Website and/or App and any information you enter will be remembered but is deleted when you close your browser and/or App or after a short time. Persistent cookies allow us to remember your preferences and settings when you use the Website, Salon Website and/or App in the future, in different browser or App sessions.
b.   Disabling Cookies: The use of the cookies described above improves the functionality of the Website, Salon Website and/or App and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Website, Salon Website and/or App, and some of the features of the Website, Salon Website and/or App may not function properly. By continuing to use the Website, Salon Website and/or App, including using social networking media functionality, you consent to the relevant cookies being set on your device.
c.   Third Party Cookies: Third Party advertisers may place or read cookies on your browser or device in the Website, Salon Website and/or App. This Policy is applicable only to the use of cookies by Hubber and does not cover the use of cookies by any third parties (including advertisers).
d.   More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.

Hubber uses cookies and similar technologies in the following ways when you use the Website, Salon Website and the App:

Cookie Type

Google Analytics

Purpose

Hubber uses Google Analytics cookies to collect information about how visitors use the Salon Website, which, in turn, Hubber uses to help improve the Salon Website. These cookies collect information in an anonymous form, including the number of visitors to the Salon Website, where visitors have come to the Salon Website from, and the pages they visited.

Further Information

Opt-out Tool.

Squarespace cookies

Hubber uses these cookies on the Website in order to help improve it. Further information can be found here.

See here.

SECTION G – Contact and Your rights 

17.   Hubber Details: If at any time you would like to contact Hubber you can do so by sending an e-mail to us at support@hubber.biz or write to us at “Data Protection Query, Hubber Ltd, 8 Dean Street, London, United Kingdom, W1D 3RL. This is Hubber’s registered address and we are a company incorporated in England and Wales with company number 11591844.

 

18.    Your Rights: You can contact us using the details set out in the paragraph above if you wish to: (a) access a copy of the personal data that we hold about you; (b) correct any items of personal data that we hold about you; and/or (c) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. You may also contact the ICO at any time.