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Privacy Policy


Privacy Policy

BACKGROUND:

The Hub Directory understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://thehubdirectory.com/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy works in conjunction with our Terms and Conditions https://thehubdirectory.com/terms-conditions/.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

GDPR Roles:

Data subject is any natural person, and in the concept of GDPR in the EU is based in an EU member state. They must give explicit permission for the use of their personal data.
Data controller collects, controls and determines the purposes and means by which personal data is processed. 
Data processor processes the personal data on behalf of the data controller. This is a service provider, such as a hosting company, or anyone used it the collection, treatment and use of data.
Supervisory authority is an independent public authority, which is established by an EU Member State and it is responsible for enforcement of the GDPR legislation. Despite the fact that GDPR applies to the whole of the EU, the specifics may vary between the different countries.

2. Information About Us
Our Site is owned and operated by Barry Newlove, a sole trader.
Registered address: Residencia Turys 1, Avenida de La Mancha 29b, 03183 Torrevieja, Spain.
NIE number: X4948034K.
Email address: info@thehubdirectory.com.
Telephone number: +34 966 266 043.
Postal address: The Hub Directory, Residencia Turys 1, Avenida de La Mancha 29b, 03183 Torrevieja, Spain.

3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site contains links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out below, using the methods also set out. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.

Identity Information including name, title, date of birth, etc.
Contact information including email address, telephone number.
Business information including business name, address, telephone number, website, location, social media links, email address, images, etc.
Payment information. We use third-party secure processors for credit card payments.
Profile information including preferences, login details, purchase history.
Technical information including IP address, browser type and version, operating system.

7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we may use your personal data, and our lawful bases for doing so:

Registering you on Our Site.
User name, email address and contact information.
For providing and managing your Account.
For providing and managing your access to Our Site.
For personalising and tailoring your experience on Our Site.
For administering Our Site.
For administering your business listing.
For personalising and tailoring our products AND/OR services for you.
For communicating with you.
For supplying you with information by email that you have opted-in-to, or for contractual upgrades in line with the law.

With your permission AND/OR where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated system[s] for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Identity Information including  name, title, date of birth, etc.
Indefinitely, unless removed.
Contact information including address, email address, telephone number, etc. Indefinitely, unless removed.
Business information including business name, address, location etc. Indefinitely, unless removed.
Profile information including preferences and interests, username and password, purchase history. Indefinitely, unless removed.
Technical information including IP address, browser type and version, operating system. Indefinitely, unless removed.

9. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data securely online, and not in any offline databases.
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
* limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
* procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group. This includes subsidiaries AND/OR a holding company and its subsidiaries.

11. How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11.3 You can control your Privacy Settings to Our Site by visiting the Privacy Settings page, https://thehubdirectory.com/privacy-settings-page/
11.4 You can choose to be “forgotten” by Our Site by submitting your email address to the Forget Me page, https://thehubdirectory.com/privacy-policy/forget-me/

12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. 
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products AND/OR services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytics, advertising, publicity, performance, and security. For more details, please refer below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Active Purposes:
Name: Function. Purpose: Functionality cookies allow websites to remember certain pieces of information such as the site preferences and choices they make on the site. This may include such things as username, region, and language. The purpose of these cookies is to allow the website to provide personalised features like listings,  news, and weather if you share your location.
Name: Marketing. Purpose: Marketing cookies help website owners determine the users interests, based on browsing activity, purchases and preferences. These cookies allow a more user-friendly experience because they carry out functions such as remembering passwords, and keeping items in shopping carts when the customer exits the web browser.
Name: Preferences. Purpose: Preference cookies help websites remember information that changes the way the website behaves or looks. This can include things like your preferred language or your location.
Name: Other. Purpose: Other cookies can allow the website to perform certain functions not covered by any of the specific categories. They help the website remember information about your visit, which can both make it easier to visit the site again, and help make the site more useful.
Name: Social media. Purpose: Social media cookies are cookies used to allow the connection between a website to a third-party social media platform. They remember information after the user signs in to a social media account from a website. Many social media cookies are set through plugins, widgets, and sharing buttons.
Name: Analytics. Purpose: Analytics cookies are performance cookies used to track website visitors and their user behaviour. This data is used to improve the way the website works and in turn, used to improve user experience. Google Analytics (GA) cookies are one of the most common analytics cookies set by websites.

Vendors:
Cloudflare.
Elementor.com.
Google Analytics.
Google Fonts.
Google General.
Google Maps.
Google Recaptcha.
Google Tag Manager.
Hubspot.
YouTube.

Domains:
nr-data.net
youtube.com
www.youtube.com
www.googletagmanager.com
js-agent.newrelic.com
ipapi.co
*.hubspot.com
static.hsappstatic.net
*.gstatic.com
maps.googleapis.com
bam-cell.nr-data.net
listingprowp.com
js-eu1.hs-scripts.com
js-eu1.hs-banner.com
js-eu1.hs-analytics.net
www.google.com
js-eu1.hscollectedforms.net
js-eu1.usemessages.com
f.hubspotusercontent-eu1.net
forms-eu1.hsforms.com
region1.google-analytics.com
www.thehubdirectory.com

The following first-party Cookies may be placed on your computer or device:

Cookie: __cf_bm. Domain: .hubspot.com. Vendor: Hubspot. Purpose: Function. Type: Functional. Description: This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. Duration: 30 Minutes.

Cookie: elementor. Domain: thehubdirectory.com. Vendor: Elementor. Purpose: Function. Type: Necessary. Description: This cookie is used by the website’s WordPress theme. It allows the website owner to implement or change the website’s content in real-time. Duration: Never.

Cookie: Google Fonts. Domain: .thehubdirectory.com. Vendor: Google Purpose: Function. Type: Functional. Description: Google Fonts does not set cookies. However, if a font is requested by the visitor’s browser, the visitor’s IP address is recorded by Google and used for analytical purposes. This is also reflected in a transparent manner in the Google Terms and Conditions for the Google Fonts API. Duration: 12 Months.

Cookie: __hmpl. Domain: .hubspot.com. Vendor: Hubspot. Purpose: Marketing. Type: Necessary. Description: Collects information on user preferences and/or interaction with web-campaign content. Duration: Persistent.

Cookie: hs-messages-is-open. Domain: .thehubdirectory.com. Vendor: Hubspot. Purpose: Marketing. Type: Necessary. Description: This cookie is used to determine and save whether the chat widget is open for future visits. It resets to re-close the widget after 30 minutes of inactivity. Duration: 30 Minutes.

Cookie: __hssc. Domain: .thehubdirectory.com. Vendor: Hubspot. Purpose: Function. Type: Functional. Description: This cookie keeps track of sessions. Duration: 30 Minutes.

Cookie: __hssrc. Domain: .thehubdirectory.com. Vendor: Hubspot. Purpose: Function. Type: Functional. Description: Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. Duration: Session.

Cookie: __hstc. Domain: .thehubdirectory.com. Vendor: Hubspot. Purpose: Function. Type: CRM. Description: Used for marketing and tracking purposes. Duration: 13 Months.

Cookie: HUBLYTICS_EVENTS_53. Domain: .hubspot.com. Vendor: Hubspot. Purpose: Marketing. Type: Necessary. Description: This cookie collects visitor activity information from multiple websites in order to display more appropriate advertisements. It also enables the website to limit the number of times the same advertisement is shown to a visitor. Duration: Persistent.

Cookie: JSESSIONID. Domain: thehubdirectory.com. Purpose: Function. Type: Necessary. Description: JSESSIONID is a cookie generated by Servlet containers and used for session management in J2EE web applications for HTTP protocol. If a Web server is using a cookie for session management, it creates and sends JSESSIONID cookie to the client and then the client sends it back to the server in subsequent HTTP requests. Duration: Session.

Cookie: messagesUtk. Domain: .thehubdirectory.com. Vendor: Hubspot. Purpose: Function. Type: Functional. Description: to store browser details, store performed actions on the website. Duration: 13 Months.

Cookie: rc::a. Domain: thehubdirectory.com. Vendor: Google. Purpose: Marketing. Type: Necessary. Description: to read and filter requests from bots. Duration: Persistent.

Cookie: VISITOR_INFO1_LIVE. Domain: .youtube.com. Vendor: YouTube. Purpose: Marketing. Type: Advertisement. Description: A cookie set by YouTube to measure bandwidth that determines whether the user gets the new or old player interface. Duration: 6 Months.

Cookie: YSC. Domain: .youtube.com. Vendor: YouTube. Purpose: Marketing. Type: Advertisement. Description: YSC cookie is set by Youtube and is used to track the views of embedded videos on Youtube pages. Duration: Session.

Our Site uses analytics services provided by Google Analytics, Monster Insights, Hubspot, and YouTube. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products AND/OR services offered through it.
The analytics services used by Our Site use Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics services used by Our Site use the following Cookies:

Cookie: CONSENT. Domain: .youtube.com. Vendor: YouTube. Purpose: Analytics. Type: Analytics. Description: YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data. Duration: 2 Years.

Cookie: _ga. Domain: .thehubdirectory.com. Vendor: Google. Purpose: Analytics. Type: Analytics. Description: The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. Duration: 2 Years.

Cookie: _ga_D5EVLEXSN0. Domain: .thehubdirectory.com. Vendor: Google. Purpose: Analytics. Type: Analytics. Description: This cookie is installed by Google Analytics. Duration: 2 Years.

Cookie: _gd[Timestamp]. Domain: .thehubdirectory.com. Vendor: Google. Purpose: Analytics. Type: Analytics. Description: Analytics cookie used to distinguish users. Duration: Session.

Cookie: hubspotutk. Domain: .thehubdirectory.com. Vendor: Hubspot Purpose: Analytics. Type: Analytics. Description: This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. Duration: 6 Months.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
You can control your Privacy Settings to Our Site by visiting the Privacy Settings page, https://thehubdirectory.com/privacy-settings-page/

15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@thehubdirectory.com.
Telephone number: +34 966 266 043.
Postal Address: The Hub Directory, Residencia Turys 1, Avenida de La Mancha 29b, 03183 Torrevieja, Spain.

16. Data Controller
Our Site Data Controller is Barry Newlove.
Registered address: Residencia Turys 1, Avenida de La Mancha 29b, 03183 Torrevieja, Spain.
NIE number: X4948034K.
Email address: info@thehubdirectory.com.
Telephone number: +34 966 266 043.
Postal address: The Hub Directory, Residencia Turys 1, Avenida de La Mancha 29b, 03183 Torrevieja, Spain.

17. Supervisory Authority
The Spanish supervisory authority is the Agencia Española de Protección de Datos (“AEPD”), which also represents Spain on the European Data Protection Board. There are also Regional Data Protection Commissioners who supervise personal data processing by regional public authorities and other entities controlled by regional public authorities. You should check in your local area for your Regional Data Protection Commissioner.

The contact details of the AEPD are as follows:

Address: C/Jorge Juan, 6, 28001 Madrid, Spain
Telephone: +34 901 100 099/ +34 91 266 35 17
Website: www.aepd.es

18. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 27/07/2022.

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