Please read this privacy policy carefully before using the website. If you do not agree with the terms of this privacy policy, please do not continue access of the website. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
Effective 1 Jan 2020
As noted in our terms and conditions, www.huckletree.com (“site”) is operated by Huckletree Limited of 115 Alexandra Park Road, London, N10 2DP (“we” “our” “Huckletree” “us”) who are committed to protecting and respecting the privacy of our users (“you” “your” “customer” “member”).
This privacy policy (“policy”) together with any other documents referred to and made available at www.huckletree.com/docs/privacy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This policy will inform you as to how we look after your personal data when you visit our site (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this policy.
This policy aims to give you information on how Huckletree collects and processes your personal data through your use of this site, including any data you may provide through this site when you sign up to be a member, purchase one of our products or services or apply to our Alpha Programme, contact us via email, chat to us through our online chat systems or any other form of communication medium we provide through our site.
This site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy policy or fair processing policy 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 policy supplements the other policies and is not intended to override them.
For the purpose of the General Data Protection Regulation (GDPR), the data controller is Huckletree Limited and further contact details are provided below. If you have any questions about this policy, including any subject access requests (SAR) to exercise your legal rights (which are detailed in section 9 and in the Glossary of this policy) please email us directly at gdpr@huckletree.com.
In addition we have appointed a Data Privacy Officer who is responsible for overseeing questions in relation to this policy, please refer to the contact information below for any further assistance you might need from us.
Our full details are: Huckletree Limited of 115 Alexandra Park Road, London, N10 2DP
Full name of legal entity:
Huckletree Limited
Postal address:
115 Alexandra Park Road, London, N10 2DP
Telephone number:
020 394 89270
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.
This version was last updated on the date noted in the header of this policy and historic versions can be obtained by contacting us on the above contact details.
The data protection law in the UK will change on 25 May 2018. Although this policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes. 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, and if there are any changes please let us known through the above contact details.
This site include links to third-party sites such as, Twitter, Facebook, Instagram, Youtube, Medium, Linkedin; plug-ins and applications that we do not own or operate. 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 sites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every site you visit asthey are subject to their separate and independent privacy statements, notices, and terms. The collection, use, and disclosure of your personal information will be subject to the privacy policies of the third party and not this Policy.
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 follows:
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 usage data to calculate the percentage of users accessing a specific site feature. 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 policy.
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.
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.
We use different methods to collect data from and about you including through:
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:
You have the right to withdraw consent to marketing at any time by contacting us by email directly at gdpr@huckltree.com.
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 register you as a new customer/member | (a) Identity
(b) Contact |
Performance of a contract with you |
| To register you as an applicant on our accelerator programs such as for example, Alpha programme. | (a) Identity
(b) contact |
Performance of a contract with you |
| To carry out our obligations arising from any contracts entered into between you and us | (a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| To process and deliver your order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in our newsletters and allow you to participate in interactive features of our service, when you chose to | (a) Identity
(b) Contact (c) Profile (d) Usage (e)Marketing/Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this site (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 deliver relevant site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e)Marketing/Communications (f) 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 site, 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 site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We may also use your data, or permit selected third parties to use your data as set out in the table above to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post or telephone. These third parties collect or receive information about your use of our services, including through the use of cookies, web beacons and other similar technologies and this information may be collected over time and combined with information collected across different websites and online services.
Some of these companies participate in industry developed programs to provide customers with choices about whether to receive targeted advertising. Please visit the websites operated by:
(a) Network Advertising Initiative www.networkadvertising.org;
(b) Digital Advertising Alliance www.digitaladvertisingalliance.org
(c) European Interactive Advertising Digital Alliance www.edaa.eu
If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, please inform us by email on gdpr@huckletree.com.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
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 provided consent for Huckletree to do so.
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly. For more information about the cookies, web beacons and other standard technology we use, please see https://www.huckletree.com/docs/cookie-policy.
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.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may disclose your personal information to third parties:
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:
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.
The data that we collect from you may be transferred to, and stored at, a destination outside the EEA as 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.
It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
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 are aware that these safeguards depends partly on the European Commission’s judgment as to the adequacy of safeguards for personal data applicable in the receiving country and this may change over time. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 although we take such steps to protect your information, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information; any transmission is at your own risk.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted, often, using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access
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.
How long will you use my personal data for?
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.
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 your ‘legal rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary for further details on your rights.
If you wish to exercise any of the rights set out above, please contact us on the above contact details provided in relation to SAR requests.
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.
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.
We will respond to all requests within 30 days. Occasionally it may take us longer than 30 days 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.
Privacy laws and guidelines are part of a constantly changing environment. We will notify you of material changes by e-mail or by posting a message under the relevant services on the site.
If you have any questions or comments regarding our Policy, please contact us at: Data Privacy Manager, Huckletree Limited of 115 Alexandra Park Road, London, N10 2DP. Email: gdpr@huckletree.com
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We 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. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties [in reference to section 5 ‘Disclosures of your personal data’]
You have the right to:
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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.