1. INTRODUCTION

We are BuddyHub Ltd (referred to as “we”, “us”, “our”, and “BuddyHub”) and are a Social Enterprise whose mission is to alleviate the problem of loneliness and isolation amongst some older people. BuddyHub also seeks to strengthen communities by creating the connectivity that is often lacking. This policy, together with the Terms and Conditions (which can be found at the bottom of our Website at www.buddyhub.co.uk) explains what types of personal and non-personal information we collect when you use the Website and provide us with any information in the context of taking part in any BuddyHub activity. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

1.1 Please read the following carefully to understand our views and practices regarding your personal data and how we will process it. By using the Website you consent to the collection, storage and processing of your personal information as stated in this policy.

1.2 BuddyHub uses the personal information we collect from you to provide and improve our service to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.

1.3 For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is BuddyHub Limited of 252A, Liverpool Road, London, N1 1LG, company number 09332306 which is registered with the ICO with registered number ZA119405.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

2.1 We may collect, store and use the following kinds of personal information:

(a) when you register as a User of the Website and/or become a member of BuddyHub, you will be asked to complete a profile form which will ask for your name, address, date of birth, email address, fixed line and/or mobile telephone numbers, bank information (for Seniors only), and certain other personal information about your appearance, photographs, personal values, interests, skills and aspirations.  Some of this information will be used to build a profile for you;

(b) when you contact us by email or telephone or through any contact form provided on the Website, or if you provide us with information when you take part in a BuddyHub activity we may ask you to provide some or all of the information set out in paragraph (a) above as well as any additional information required so that we can best assist you with your enquiry;

(c) we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website and your visits to and use of the Website (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, Website navigation and search terms that you use) (please see clause 6 for further information); and

(d) if you access the Website through a social networking profile, we may collect, store and use the details of that social networking profile and any information contained therein in order to populate any forms you might wish to complete on the Website.

2.2 We may also ask you to complete surveys and give feedback that we use for research purposes, although you do not have to respond to them.

2.3 If you choose to provide us with information on other people, or post information relating to other people, you must ensure that they have consented to you providing us with such information, that the information is correct and the use of such information is in accordance with this policy. By providing us with information on any other person, we are entitled to assume that the other person has consented to you providing us with their information and to us contacting them.

3. HOW DO WE USE PERSONAL INFORMATION?

3.1 We may use your personal information for the following purposes:

(a) to manage and administer the Website and any BuddyHub activities that you decide to participate in:

(b) To match Buddies to a suitable Friendship Wheel based on the information provided in your profile;

(c) To create a profile summary for Seniors which can be reviewed by Buddies we have identified as having similar geographic location and interests;

(d) to improve your browsing experience by personalising the Website;

(e) to enable you to use the Website;

(f) to deal with enquiries, complaints and feedback from you and people with whom you have interacted as part of your involvement with BuddyHub;

(g) to provide third parties with statistical anonymised information about our Users;

(h) to send you emails; and

(i) to analyse and improve the services offered on the Website.

4. WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION?

4.1 We reserve the right to disclose your personal information to the extent required by any applicable law or governmental body or judicial body. In addition, we may from time to time provide limited anonymised information relating to your usage and browsing habits on the Website to third parties. Without limitation, we may disclose any information relating to your behaviour and any other information we consider in our sole and absolute discretion to be relevant where we believe that you have, or may in the future, commit any criminal offence in the context of your relationship with BuddyHub.

4.2 We will use all reasonable endeavours to ensure that any person to whom we disclose confidential information is compliant with the Data Protection Act 1998 (or an equivalent standard) as regards its use and storage of your personal information. In particular, our contracts with product advertisers and third party providers’ state that they may use personal information relating to our customers disclosed to them by us solely for the purposes of providing services to our customers and that they may not disclose or otherwise use any such personal information for any other purpose.

5. NEWSLETTERS AND OTHER PROMOTIONAL COMMUNICATIONS

5.1 If you wish to subscribe to any newsletter published by us or wish to receive other targeted and relevant promotional communications from us or other carefully chosen affiliates, we offer you the option to “opt-in” to this service. If you change your mind and wish to stop receiving any such communications, please either email us at hello@buddyhub.co.uk or click the “unsubscribe” link in any email from us.

6. OUR USE OF COOKIES AND WEB BEACONS

6.1 Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and Users of the Website (including user site preferences or the contents of electronic shopping carts). Cookie files may also be placed on your computer by our trusted third-party advertising companies for the purposes as set out in this paragraph.

6.2 The data collected by cookies is anonymous. You can delete all cookies that are already on your computer’s hard drive by searching for files with “cookie” in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website. For more information about cookies, please visit: www.allaboutcookies.org

6.3 Web beacons consist of a small string of software code that represents a graphic image request on a Web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a Web page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalisation. Web beacons used by www.buddyhub.co.uk collect only anonymous data.

6.4 In order to improve our Website and the services we offer you, we use (temporary and persistent) cookies, authorised third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website.

6.5 In order to understand how people use our Website and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details such as the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website.

6.6 If you register with us or if you continue to use the Website, you agree to our use of cookies.

6.7 The Member always has the option of preventing the use of cookies by modifying the options of his/her web browser.

6.8 Additional information may be found in our dedicated Cookie Policy (insert link).

7. WHERE WE STORE YOUR PERSONAL DATA

7.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. 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 all in accordance with this privacy policy.

7.2 All information you provide to us is stored on our secure servers.

7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7.4 No system can be considered 100% secure regarding Internet security. Should a security breach occur we will endeavour to act as swiftly as possible to remedy the problem in as reasonably practicable time frame as possible.

7.5 We transmit personal information using Secure Sockets Layer (SSL) software which encrypts information you input. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

7.6 It is important that you protect against unauthorised use of your password and username to the Website. Please be sure to sign off from the Website when you finish using a shared computer.

8. YOUR RIGHTS

8.1 The Act gives you the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at hello@buddyhub.co.uk.

8.2 The Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9. ACCESS TO INFORMATION

9.1 The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

10. CHANGES TO OUR PRIVACY POLICY

10.1 We reserve the right to amend this privacy policy at any time. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.