Privacy Policy

Effective: May 24th, 2018
Last updated: April 1st, 2019

TechHub respects your privacy and is committed to protecting your personal data. This privacy policy will explain how we collect, process and look after your personal data over the course of our business, including any data you may provide to us through using our website (regardless of where you visit it from) and services, and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

The purpose of this privacy policy

This privacy policy aims to give you information on how TechHub collects and processes your personal data through your use of this website and our services, including any data you may provide through this website when you sign up to our newsletter, purchase a membership, attend a TechHub event, and so on.

The “services” that we will refer to in this privacy policy include TechHub memberships (with their respective products, benefits and add-ons), events, competitions, mobile applications, web pages and subdomains. This privacy policy doesn’t apply to any third-party websites, services or applications, even if they are accessible through our services.

TechHub services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy 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 policy supplements the other notices and is not intended to override them.

Controller

TechHub is the global community for tech entrepreneurs and startups. To find out more about what we do, visit our About Us page. We are headquartered in the United Kingdom but made up of different legal entities that operate locations around the world. You can find the address and contact details for our worldwide locations on our Contact Us page.

This privacy policy is issued on behalf of TechHub Europe Ltd so when we mention "TechHub", "we", "us" or "our" in this privacy policy, we are referring to TechHub Europe Ltd and all its wholly owned subsidiaries responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. TechHub Europe Ltd is the controller and responsible for this website.

Our contact details

Our full details are: TechHub Europe Ltd (company number 07054279), registered at 1-15 Clere St, London EC2A 4UY, United Kingdom.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details below:

Melissa Hofert, Financial Controller & HR Manager

We prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames. To exercise your data protection rights, get in touch with us via privacy@techhub.com

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.

Your duty to inform us of changes to your data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This 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 policy of every website you visit.

2. What personal data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data may include first name, last name, username or similar identifier, title
Other Personal Data may include gender, nationality, country you’re based in, photo, public links to your social media profiles.
Verification Information may include a photo ID or government issued identification, proof of address, date of birth.
Contact Data may include email address, home, work or billing address, phone number, or other information that allows us to contact you.
Financial Data may include bank account and payment card details.
Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
Technical Data may include internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this website or TechHub services.
Profile Data may include your username and password for TechHub services, purchases or orders made by you, feedback and survey responses.
Professional Information may include your company name, title, role, team, interests, skills and other information about your profession or company.
Company Data may include information about your company size, structure, funding, products, sector, clients, age of company.
Usage Data may include information about how you use our website, products and services.
Marketing Preferences may include your preferences in receiving marketing from us and our third parties and your communication preferences.
Employment Data may include qualifications and tax, pension, performance and salary information.
Diversity Monitoring Data, may include your ethnic background, gender identity, sexual orientation, whether you have a disability, your citizenship status and whether you have ever served in the armed forces.

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 Identity Data to calculate the gender ratio within the TechHub member community. 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.

Some of the information we collect about you is classed as Special Category Data . Special category datais defined by the Data Protection legislation as data relating to 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.

If you fail to provide personal data

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.

3. How we collect personal data

When you use TechHub services, we collect personal data from and about you. We collect the data in different ways, including through:

Information you provide to us directly: when you visit our websites and use our services we might ask you to provide personal data to us. You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

apply for TechHub membership;
purchase and use TechHub memberships and any related services, benefits or add-ons;
send emails, messages, calendar invitations and any other information over the course of your membership including photos, videos, blog entries or requests that you choose to share on our communication channels such as email or Slack;
sign in the TechHub premises a visitor;
subscribe to our newsletter;
contact us with questions related to our products and services or request marketing to be sent to you;
participate in TechHub events as an attendee, speaker, professional advisor or mentor;
enter a competition, promotion or survey; or
give us some feedback.

Information we collect through automated technologies or interactions: when you interact with our websites, we may automatically collect Technical Data about your equipment, like your IP address and device type. We also collect information when you navigate through our websites, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites so that we can continue to provide the best experience possible (for example, by changing its user interface).

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our Cookie Statement.

Information we get from third parties or publicly available sources. The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from publicly available materials. We use this information to supplement the personal data we already hold about you, in order to validate the personal data you provide. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:
- analytics providers (such as Google based outside the EU);
- advertising networks (such as Facebook based outside the EU).
Contact, Financial and Transaction Data from providers of payment services such as Stripe, based outside the EU and GoCardLess, based inside the EU.
Identity and Contact Data from publicly available sources, such as Companies House based inside the EU.

4. How we use 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 it is necessary for our legitimate interests (or those of a third party) to give you the best service/product and the best and most secure experience. We make sure 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. For example, we limit the data to what is necessary, control access to the data, and where we can, aggregate or de-identify the data. 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).
Where we need to comply with a legal or regulatory obligation, for example to conduct due diligence to prevent money laundering or other illegal activities. Under exceptional circumstances, we may be required by law to provide personal data to law enforcement agencies, courts or others in connection with claims and other litigation.
Where we have your consent/explicit consent. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications (on our behalf or on behalf of third parties to you via email) or in collecting and using Diversity Monitoring Data. You have the right to withdraw consent at any time by contacting our data privacy manager, whose contact details are set out above.

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

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To assess applicants’ fit for TechHub membership	(a) Identity (b) Contact (c) Professional	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to curate a community of members building technology products and provide products and services relevant to our membership)
To register and onboard new members, including: (a) Verifying your identity (b) Setting up your member account (b) Granting you access to TechHub’s online services (c) where relevant, setting up additional services or add-ons	(a) Identity (b) Contact (c) Verification (d) Professional (e) Profile (f) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to create a member record and deliver our products and services via easy-to-use systems) (c) Necessary to comply with a legal obligation
To process and deliver membership orders and payments including: (a) Managing payments, invoicing, fees and charges (b) Collecting and recovering money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and perform accounting procedures)
To deliver our services and manage membership accounts, including: (a) Notifying you about changes to our services, terms, or privacy policy (b) resolving queries or issues communicated by you (c) Sharing community and facilities updates for your TechHub location (d) Sharing, suggesting or recommending opportunities or services offered under your membership that may be of value to you (e) Asking you to take a survey or give feedback	(a) Identity (b) Contact (c) Professional (d) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated, to deliver and study how customers use our products/services, to develop them to grow our business)
To distribute tickets to our events including: (a) Managing event registration & issuing tickets (b) Communicating event changes (e.g. time or venue)	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (event logistics and communication with attendees)
To assess the fit of an individual for our programme, in the capacity of a speaker, professional advisor or mentor	(a) Identity (b) Contact (c) Professional	Necessary for our legitimate interests (providing relevant, high-quality content through the events under our programme)
To promote our company and its service offering including: (a) enabling individuals to access and partake in relevant upcoming events, offers, competitions or other initiatives (b) communicating company news and industry updates	(a) Identity (b) Contact (c) Marketing	(a) Your consent (given by subscribing to our newsletter or giving us permission to contact you for this purpose) (b) Necessary for our legitimate interests (to study how customers and potential customers use our products/services, to develop them and grow our business)
To provide customer support or information you’ve requested related to your account or our services	(a) Identity (b) Contact (c) Professional	Necessary for our legitimate interests (to provide customer support, study how customers and potential customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To manage visitors and security on TechHub premises: (a) keeping a visitor log and informing members about incoming visitors (c) video monitoring of public spaces (e.g. reception areas) and no-access spaces (e.g. server rooms)	(a) Identity	Necessary for our legitimate interests (to maintain safety and security on TechHub premises, to protect TechHub property and that of its member individuals and companies, and to manage visitors entering TechHub premises)
To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Usage (b) Marketing (c) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To source job applicants and assess their fit for open job vacancies	(a) Identity (b) Contact (b) Professional	(a) Performance of a contract (b) Necessary for our legitimate interests (to hire qualified individuals who are the right fit for our business)
To keep employee records and manage HR processes	(a) Identity (b) Contact (b) Professional (b) Financial (b) Employment	(a) Performance of a contract (b) Necessary to comply with a legal obligation

Marketing and promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have subscribed to our newsletter, used our services (e.g. attended a TechHub event) or 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.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the TechHub Europe Ltd. group of companies (e.g. the professional advisors who mentor at TechHub events) for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a membership purchase.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Statement.

Video Footage

TechHub premises have video monitoring to protect the safety of TechHub employees, members, and guests and their property. Recordings may be accessed by TechHub within the EU and elsewhere and may be shared with competent authorities in accordance with applicable laws. Recordings are retained for ten days, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them longer.

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.

5. How we may share 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.

Internal third parties: wholly-owned subsidiaries of TechHub Europe Ltd acting as joint controllers or processors and who are based in the US and India and provide access to their local membership services.

External third parties:

Our community. Our services include online and offline member communities and networks that allow you to share information and connect with others. This is achieved by creating profiles for members or permitting members to create their own profiles. Such a profile contains your name and the name of your company and other information you choose to provide. Depending on the services you use, this profile might be created automatically and is accessible to other members on the network. You can supplement your profile by adding additional information about yourself and your company or organization, send messages and send, accept or reject connection requests to other members. Please note that we cannot control the actions of other users of the services with whom you share information.
Service providers based in the United Kingdom and United States who provide building management, security and software (such as email delivery, payment processing, accounting, customer support management, project management, online messaging, video monitoring, visitor logging, event ticketing, analytics) on our behalf.
Professional advisers including lawyers, bankers and auditors based in the United Kingdom who provide legal, banking and accounting services to us.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
With your consent, programme contributors based in the United Kingdom with whom we collaborate to deliver industry-focused events and who provide mentorship and professional advice as part of our programme.
Corporate partners, based in the United Kingdom and United States who require sharing aggregate data for reporting purposes or sharing personal data (with your consent) for joint industry-focused initiatives delivered under the partnership.
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 policy.

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.

6. International transfers

If you wish to use the local services of TechHub’s wholly-owned subsidiaries offered under TechHub membership, we may share your personal data with them. This may involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Some of our external third parties are located in the United States or other countries that do not provide the same standard of data protection as the EU.

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. Read here for further details.
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. Read here for further details.

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

7. 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.

8. How long we keep personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Because these needs can vary for different data types used for different purposes, retention times will also vary. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax]purposes. In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

9. Your rights and choices

TechHub cares about your personal information and we will be prepared to address any requests related to your individual rights under the GDPR. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. You can:

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.

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. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to privacy@techhub.com.

How to exercise your data protection rights

If you wish to exercise any of the rights set out above, please send your request via email to privacy@techhub.com.

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 may 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.

Time limit to respond

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 this case, we will notify you and keep you updated.

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