TUBR, Ltd - Privacy Policy

Key information: 
We’ve provided a summary of the key information set out in this privacy policy. We encourage you to still read the full privacy policy as it contains important information. 

Summary:

      When you use our App
         •
We do not collect personal data from you. 

      When you visit our website
          •
We will collect technical information about how you use our website by using cookies. 

      If you subscribe to our newsletter or otherwise contact us
 

•  We will collect your name and contact details or any other information that you may provide relating to your enquiry or reason for contacting us. 
• We don’t keep your personal data for longer than we need to for the reasons we collected it.
•  If you opt out of receiving marketing communications from us, we will keep your personal data in order to maintain a suppression list of people who have opted out to ensure you are not sent marketing communications when you have asked us not to.
• We share your personal data with third parties who help us to run our business, only if we are satisfied they have appropriate measures to protect your personal data. 
• Sometimes we may share your personal data with our professional advisors or other third parties as part of a corporate transaction. These are limited circumstances and the recipients will be bound by legal, regulatory or confidentiality obligations, as applicable.
• We may transfer your personal data outside of the UK and EEA where our service providers process your personal information in other countries. We will ensure that we have appropriate safeguards in place.

How your personal data is collected
We collect personal data from you: 

1. Directly when you submit an enquiry through our contact form or when you otherwise contact us via phone, email or social media sites, send us feedback or complete customer surveys or participate in competitions;
2. indirectly, such as your browsing activity while on our website; we may collect information indirectly using the technologies explain in the section on ‘Cookies’ below.

How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘Contact details’ above).


What we use your personal data for

Our lawful basis

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:
To comply with our legal and regulatory obligations
In other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:
Your consent as gathered through our cookie banner when you first visit our website—see ‘Cookies’ below
Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you through our website and App

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:
Your consent as gathered through our cookie banner when you first visit our website —see ‘Cookies’ below
Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service and website to you

Communications with you not related to marketing, including about changes to our services, terms or policies or changes to other important notices

Depending on the circumstances:
To comply with our legal and regulatory obligations
In other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

Protecting the security of systems and data

To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Marketing our services to existing and former customers

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers. See ‘Marketing’ below for further details.

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.

Aggregated Data 
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users viewing certain content. 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 policy. 

Marketing
We may use your personal data to send you updates (by email,) about our services, including exclusive offers, promotions or new and updated services available through our App.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us using the contact details provided above; or
• using the ‘unsubscribe’ link in emails. 

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
For more information on your rights to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with
We routinely share personal data with other third parties we use to help us run our business, e.g. marketing agencies, website hosts and website analytics providers. 

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above may occasionally also need to share personal data with:

• professional advisors (such as lawyers, accountants and other advisors), in which case the recipient of the information will be bound by confidentiality obligations; or
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘Contact details’ above).

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. 

International transfers
Other countries outside of the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to share your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

We will transfer your personal data to our service providers located outside the UK.​

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued in accordance with the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.

How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is collected and used.

Different retention periods apply for different types of personal data. We will keep personal data for the retention periods set out in our Retention Policy, which is available on request using the contact details above. Following the end of the relevant retention period, we will delete or anonymise your personal data.

Your legal rights
You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:
—at any time to your personal data being used for direct marketing (including profiling)
—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.

For further information on each of those rights, including the circumstances in which they apply and circumstances in which they do not apply, please contact us (see ‘Contact details’ above). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

No fee usually required
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 could refuse to comply with your request in these circumstances.

What we may need from you
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.