ViewsHub Privacy Policy

We are ViewsHub Ltd.  This is our data protection and privacy policy.  Our contact and other details are set out at the end of this policy.  We are the controller in relation to the personal data processed by us in accordance with this policy, except where this policy explains otherwise.  It explains who we are, and why and how we process personal data. If you are the subject of any of the personal data that we process, this policy explains what rights you have, and how to get in touch with us if you wish to.

We provide a platform which enables individuals, teams and organisations to track and measure their performance by obtaining reviews and ratings from other people, including clients and other individuals and teams within their organisation.  Our platform can be used to review or rate people, teams and organisations, in two main ways:

Reviews relate solely to individuals (as opposed to teams or organisations), and the individual being reviewed has to be registered on the platform to receive them.  

The reviews are on the basis of sliding scales against defined characteristics (for example, creativity, resilience and ambition), and are intended to enable the individual to see how others view them in relation to each of these characteristics.  

Each individual has control over whether anyone else can see the reviews relating to them; access can be restricted just to the individual concerned; to other people from the same organisation who are also registered on the platform; or can be allowed to the public at large.  

The reviews are personal to the individual and are controlled by the individual, and are not visible to the individual's organisation (or to a wider audience) unless the individual chooses to make them so. The individual retains control over their reviews even if they move from one organisation to another.   An individual may choose to allow other registered users within their organisation to see their reviews, but they can change this at any time and, if they leave the organisation, the individual retains control over their reviews and can therefore stop registered users within the organisation from seeing their reviews after they leave.   

Ratings relate to individuals, teams within organisations and to organisations as a whole.  The ratings are on the basis of one to five stars against defined criteria, but include a free-text facility to allow those providing ratings to make their own comments on the individual, team or organisation concerned.  

When an individual registers on the platform on behalf of their organisation or (where their organisation is already registered) under their organisation's overall registration, they will be automatically be set up as a "team of one" on the platform (so that ratings can be provided in relation to them as an individual), but may also become members of wider teams as those teams are set up.  

Ratings relating to teams (other than teams of one) or organisations will not normally include personal data relating to members of the relevant team or organisation, but will do so if the ratings relate to an individual (as a team of one), if the team is sufficiently small (for example, two or three people, so that the ratings can more easily be related to the individuals within the team), or if the free-text section of the rating facility is used to refer to an individual (although those providing ratings are discouraged from doing this, so it should not normally happen).   

Although ratings are normally provided in relation to teams and organisations with individual members who are registered on the platform, this does not have to be the case; it is possible to rate a team or organisation which has no members registered on the platform, but in that case the rating will be deleted if not subsequently accepted by the person at the relevant organisation to who it is sent.  

Ratings are controlled by the organisation to which they relate, and the organisation can exercise overall control of the extent to which they are visible within, or outside, the organisation; this will be subject to the organisation's own data processing policy and it will be up to the organisation to ensure that the processing of any relevant personal data by it is in compliance with the applicable data protection regulations.  

Subject to that, the default setting in relation to ratings relating to an individual is that those ratings are only accessible to anyone else if the individual changes the relevant settings on the platform to allow this; however, although the individual has control via the platform to change the settings so as to provide who is normally able to see their ratings, administrators within their organisation may also be able to see the ratings relating to them in appropriate circumstances and the individual's organisation will be a controller of all personal data included in ratings (of individuals, teams and the organisation as a whole) and will therefore have ultimate control over who the ratings are visible to and how the ratings are used.  

Ratings relating to an individual are retained by their organisation when they leave, and cannot be moved with the individual to their new organisation.

Ratings relating to teams are visible to all members of the relevant team who are registered to use the platform; ratings relating to organisations are visible to all members of the organisation who are registered to use the platform.   

The principal difference between reviews and ratings is that:

• Reviews relate only to you as an individual and are controlled by you.  Other people (including other people within your organisation) can only see reviews relating to you if you give permission to them to do so.  You can at any time delete reviews relating to you (on an individual or global basis), and reviews from outside your organisation are subject to acceptance or rejection by you before they are added to your profile.   You retain control over your reviews (and over who can see them) when you move from one organisation to another.
• Ratings do not always relate to you; they only relate to you if you are being rated as an individual or as part of a sufficiently small team that the rating can be related to you as an individual.   Otherwise, ratings relate to teams or to the organisation as a whole and should not normally contain any personal data.  Although you have some control over ratings (for example, ratings sent to you from outside your organisation are subject to acceptance or rejection by you), your organisation exercises overall control over all ratings (including those relating to you as an individual), and will be able to view and manage them in accordance with its appropriate policy for doing so.  Ratings (including those relating to you as an individual) remain with the organisation if you leave.

The terms review and rating are used in this policy to refer specifically to the different types of performance measure described above, so reviews relate to individuals, and ratings to individuals, teams or organisations, as set out above.  

More details about how personal data is processed in relation to each scenario outlined above are set out in the relevant sections of this policy, below.   

When registering to use our platform, you can register in one or both of two possible capacities, as follows:

• As an individual; in which case you can use the platform to give and receive reviews;
• On behalf of your organisation (if no-one has previously done so) or under your organisation's registration (if someone has previously registered on behalf of your organisation); in which case you can use the platform to give and receive ratings.

How we process personal data depends on the purpose for which we obtain it and the individual to whom it relates.  We will normally only process personal data relating to you:

• If you are registered to use our platform as an individual and you receive reviews relating to you.
• If you are registered to use our platform under a registration on behalf or as part of the organisation that you work for and your organisation receives ratings relating to you as an individual.
• If you are an individual who has not yet registered to use our platform, but a user of our platform has sent you a rating that relates to you (it is not possible to send an individual a review unless that individual is registered on the platform – see below for more details about this).
• If you use our platform (whether you are a registered user or not) to review or rate another person, their team or their organisation; this may be at the request of the person, team or organisation concerned or, in the case of ratings (but not reviews) of your own volition.
• If you are a respondent to any survey, research, interview or other enquiry carried out by us.
• If you are the subject of a public survey carried out via our platform.
• If you attend (or are invited to attend) an event organised by us.
• If we wish to send you advertising, marketing or promotional material
• If you browse any of our websites
• If you provide goods or services (or if we are assessing your suitability to provide such goods or services) or you work for, or are an agent for or otherwise represent, someone who supplies, or is being considered as a supplier of, goods or services to us.
• If you apply for a position with us

We explain our personal data processing in more detail, below, in relation to each of these categories.

We process a limited amount of personal data relating to you (e.g. your name, organisation and email address) for the purpose of managing and administering your registration on the platform.  Otherwise, personal data relating to you will be processed for the purpose of enabling you to receive and manage reviews relating to you.  The purpose of the processing is therefore to:

• Enable us to manage and administer your registration and the services we provide to you, and you to manage and administer your registration and the data relating to you.
• Enable you to obtain reviews from other people of your behavioural characteristics (e.g. creativity), and enable other people to provide reviews in relation to you.

Once you have registered to use the platform, you will have a personal profile on the platform which may be seen by every other registered user within your organisation and by others outside your organisation if you give them permission.  Your profile includes a button which enables others who can see your profile to review you if they wish to do so.  Otherwise, someone can only review you if you ask them to.

Reviews of your behavioural characteristics that are processed on the platform may only be seen by the person who provided the review (only in relation to the review that they gave), by you and by any other people to whom you decide to give permission.  You may (but do not have to) make reviews relating to you visible to other registered users within your organisation, or to people outside your organisation; this is, however, your choice.

Processing of your personal data to the extent that it forms part of reviews is under your control; all reviews received from outside your organisation are subject to acceptance or rejection by you, and while reviews from inside your organisation are added automatically to your profile, you are able to delete them at any time (and the same is true of any other reviews that you have previously accepted).  You may at any time terminate your individual subscription and all reviews relating to you will be deleted.

If you move organisations, reviews relating to you remain under your control, although you may need to change the email address under which you are registered.  To help in making sure that you retain control over your reviews when you move from one organisation to another, before you use the reviews facility you will be asked to provide us with your personal email address or mobile phone number so that this can be used to enable you to recover your account if you have registered using your work email address and then move organisations without changing your account settings before you do so.

We will process your personal data as set out above to the extent necessary to provide our services. No one else will have access to your personal data other than as set out in this policy (see above and Other disclosures we may make, below).

The personal data processed comprises:

• Your name.
• The organisation that you work for (if applicable).
• Your address, phone number, email address or other contact details
• If you have registered using your work email address, you will also be asked to provide a personal email address or mobile phone number to aid recovery of your account if you move organisations without changing the settings on your account before you leave.
• Reviews of your behavioural characteristics.
• Any other information relating to you that is included in any communications between us and you or the organisation that work for in the course of provision of the services.
• Any feedback that we receive from other users of the platform in relation to your use of the platform.

The legal basis for the processing is:                                                                                                                                        

• You have given your consent to the processing of your personal data for one or more specific purposes - Article 6(1)(a) GDPR). This covers:
  1. The reviews relating to you.  Note that you can withdraw your consent to the processing of this personal data at any time either by deleting it yourself or by closing your individual account (in which case your individual account and all of the review data relating to you will be deleted). 
• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract - Article 6(1)(b) GDPR. This covers:
  1. The organisation that you work for (if applicable); 
  2. Your address, phone number, email address or other contact details.
• The processing is necessary for the purpose of legitimate interests pursued by: us in providing our services; or by the organisation for which you work in using our services to assist with the management of its business – Article 6(1)(f) GDPR. This covers: 
  1. Any other information relating to you that is included in any communications between us and you or the organisation that work for in the course of provision of the services; 
  2. Any feedback that we receive from other users of the platform in relation to your use of the platform.

We keep the personal data relating to you throughout the time during which we provide our services to you and until you delete it; and (if you do not delete it before that point) for a reasonable period after the provision of services to you ends, after which we will delete it or archive it (if there is an appropriate reason to maintain an archive copy of it for future reference).

We process a limited amount of personal data relating to you (e.g. your name, organisation and email address) to manage and administer your registration on the platform.    Otherwise, personal data relating to you will be processed for the purpose of enabling the provision of ratings to the extent that these relate to you as an individual (as opposed to in relation to a team or your organisation generally, where the information contained in the rating cannot be related to you as an individual).

Ratings will only include personal data relating to you:

• If the ratings are specifically of you as a "team of one" within your organisation; 
• If the ratings are of a team of which you are a member that is sufficiently small that the ratings of that team can be related to you as an individual; or 
• If ratings relating to larger teams or to the organisation as a whole contain information relating to you in the free-text section of the rating (although our acceptable use policy discourages people providing ratings from referring to individuals in the free-text section of ratings of teams or organisations).  

To the extent that ratings include personal data relating to you, then the purpose of the processing of that personal data is to:

• Enable us to manage and administer your registration and the services we provide to you, and you and your organisation to manage and administer your registration and the data relating to you, relevant teams and the organisation.
• Enable you to obtain performance ratings relating to you, to teams within your organisation or to the organisation as a whole, and to enable other people to provide ratings in relation to you, to teams within your organisation or to the organisation as a whole.

Performance ratings relating to you, to teams of which you are a part or to your organisation as a whole are controlled by your organisation, and may be seen by you, by others within your organisation, by any other people to whom your organisation gives permission to see them. When you first register, the default settings in relation to ratings relating to you as an individual will be that you will control who else can see them, provided that this may be changed by your organisation once it has established an appropriate policy for doing so.

We will process your personal data as set out above, to the extent necessary to provide our services, but no one else will have access to your personal data other than as set out in this policy (see above and other disclosures we may make, below).

The personal data processed comprises:

• Your name.
• The organisation that you work for (if applicable).
• Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
• Ratings of you, your teams or your organisation (which will only be personal data to the extent that the ratings concerned can be related to you as an individual).
• Any other information relating to you that is included in any communications between us and you or the organisation that you work for in the course of provision of the services.
• Any feedback that we receive from other users of the platform in relation to your use of the platform.

The legal basis for the processing is:

We keep the personal data relating to you throughout the time during which we provide our services to you or the organisation that you work for, and for a reasonable period after the provision of services ends, after which we will delete it or archive it (if there is an appropriate reason to maintain an archive copy of it for future reference).

Even if you are not registered to use our platform, anyone who has registered on our platform and who has your email address may use our platform to rate you, your team or your organisation.  The rating is sent to you by us (using your email address provided by the person who provided the review or rating), and you have the choice to reject it (in which case it is deleted), or to accept it (provided that you have to register to use our platform in order to do so).  If you decide to accept it and you register to use our platform, then after that point the personal data relating to you will be processed in accordance with the preceding sections of this policy.

Note that you are not obliged to accept any unsolicited rating as described above; you do not have to register to use our platform in order to reject it and, if you reject it or do not do anything, it will be deleted by us and not be subject to any further processing.  Ratings that are not accepted by you will be deleted immediately if you reject them and otherwise will be deleted at the end of one month from the date on which they are sent.

We will process your personal data as set out above, to the extent necessary to provide our services, but no one else will have access to your personal data other than as set out in this policy (see above and other disclosures we may make, below).

Note that you cannot be reviewed via our platform unless you are yourself a registered user.

The personal data processed comprises:

• Your name.
• The organisation for which you work (if applicable).
• Your email address
• Ratings of you, your team or your organisation (which will only be personal data to the extent that the ratings concerned can be related to you as an individual).

The legal basis for the processing is:

We keep the personal data relating to you until:

• You accept the relevant review or rating and register to use our platform (after which the personal data is processed in accordance with the preceding section of this policy;
• You reject the review or rating (in which case the personal data is deleted immediately); or
• You do nothing following receipt of the review or rating for a period of one month (in which case the personal data is deleted immediately).

You may use our platform to review or rate another person, a team within their organisation or their organisation.  The review or rating is then sent to the person concerned via our platform, at which point they have the choice to reject it (in which case it is deleted); or accept it (provided that that, if not already registered, they have to register to use our platform in order to do so).  If they decide to accept the review or rating, then after that point the review or rating will remain on the platform and be processed in accordance with this policy.

You will only be able to review or rate a person, a team or an organisation if you are invited to do so by them (in which case you do not need to register on the platform to provide a review or a rating, if you do not want to); or otherwise if you are yourself a registered user of the platform.

Any review or rating that you provide via our platform may be seen and processed by the person to whom you provide the review or rating, together with anyone to whom they give permission and other people within their team or organisation. Note that if, when providing a review or a rating, you choose to remain anonymous, the subject of your review or rating may still be able to tell who you are from the context (especially if they have invited you to review or rate them); we will also be able to tell who you are, although we will not disclose this information to anyone else without a good reason (for example, if you have breached our user guidelines or done anything unlawful). Anonymity cannot be guaranteed when providing a review or rating, and you should therefore proceed on the basis that the subject of your rating and others within the relevant organisation or elsewhere may become aware of your identity in relation to your review or rating.

If you use our platform other than in accordance with our acceptable use policy, or if anyone who is reviewed or rated by you complains about the way in which you are using our platform, then we may in appropriate circumstances use your personal data to suspend or block your use of the platform.

We will process your personal data as set out above, to the extent necessary to provide our services, but no one else will have access to your personal data other than as set out in this policy (see above and other disclosures we may make, below).

The personal data processed comprises:

• Your name.
• The organisation for which you work (if applicable).
• Your email address.
• Reviews that you provide of another person's behavioural characteristics (i.e. your opinion of the person).
• Ratings of another person, or of that person's team or organisation (i.e. your opinion of the person, the team or the organisation).
• Any feedback that we receive from other users of the platform in relation to your use of the platform.

The legal basis for the processing is:

We keep the personal data relating to you as follows:

• If you or your organisation, or the person or organisation you review or rate, have registered to use our platform, for as long as you or they use our services, and then for a reasonable time, following which it will be deleted.
• If you have not registered to use our platform: until the review or rating you provide is rejected or, if it is accepted, for as long as the person or organisation you review or rate uses our services and then for a reasonable time, after which it will be deleted.

We may collect personal information from you as part of surveys or other research carried out by us, although in that case we will normally provide you at the time with more detailed information about how we will process the personal information concerned (and the processing of your personal data may be subject to a more specific policy which will be provided to you at the time).

Information collected from you as part of a survey or research will normally not be disclosed to a third party without your prior consent, and any relevant disclosures will be explained to you in advance.  Otherwise, disclosures will only be made in accordance with this policy (see other disclosures we may make, below) or with the relevant policy that is provided to you prior to the relevant information being collected from you.

If you are a respondent to a public survey carried out via our platform (see below), unless you register to use our platform we will not retain any information relating to you other than the review or rating that you provide in response to the survey, so it will not be possible to identify you as the source of that review or rating.  If you register to use our platform, then your email address will be linked to the review or rating that you provide and we will be able to identify you as the provider of the relevant review or rating.

The personal data processed comprises:

• Name.
• Contact details (email address, phone number, address).
• Other personal details relevant to the market research being conducted.
• Age verification details.
• Consent forms (where relevant to market research in which the data subject is participating).
• Audio recordings of telephone surveys.
• IP addresses of online respondents
• Other information dependent on the survey or research – this will be communicated to you at the time.
• Special categories of personal data relating to you may be processed where this forms part of the market research being conducted and you have consented.

The legal basis for the processing is:

• You give consent to the processing – Article 6(1)(a) GDPR.  If you are a participant in the research, this will cover all of the personal data outlined above, as we would normally only carry out research involving you on the basis of your specific, prior, informed consent.
• The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – Article 6(1)(f) GDPR. This will cover any other processing outlined above.

Special categories of personal data relating to you will only be processed with your prior explicit consent – Article 9(2)(a) GDPR

We will keep the personal data for as long as is necessary to enable us to conduct the survey or research, and then normally for a period of 2 years after which we will delete it (or anonymise it if it is required for further research after that point).

We may from time to time conduct surveys via our platform inviting people to review or rate public figures such as politicians.  Information collected will be used only to publicise the aggregate results of the survey via our platform.   So, for example, a survey may be carried out in order to allow people to rate the perceived competence or leadership of identified political leaders; the survey would be based on defined criteria using a rating system.

The personal data processed comprises:

• Name of the person(s) to whom the survey relates.
• Reviews or ratings based on defined criteria of those persons, provided by individuals visiting our platform.

In relation to this type of survey, reviews or ratings will only be on the basis of pre-defined criteria and it will not be possible to leave free text comments as part of the review or rating.

The legal basis for the processing is:

We will keep the personal data for as long as is necessary to enable us to conduct the survey and display the results on our platform; we will delete it the personal data one month after the end of the survey.

We may collect information relating to you (as well as that of anyone who is attending the event with you) as necessary to enable you and any other relevant individuals to be invited to, and to participate in, the event and to facilitate your attendance (for example, dietary or special access requirements).

Other than our client (where relevant), no third parties will have access to your personal information other than as set out in this policy (see other disclosures we may make, below).

The personal data processed comprises:

• Name.
• Contact details (email address, phone number, address).
• Other personal details relevant to your involvement in the event.
• Professional or other accreditation details.
• Bank account or other financial details.
• Details relevant to hospitality being organised or provided (e.g. dietary requirements).

The legal basis for the processing is:

• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – Article 6(1)(b) GDPR.
• The processing is necessary for the purpose of legitimate interests pursued by us in providing and promoting our services – Article 6(1)(f) GDPR
• Medical details relating to you will only be processed with your prior explicit consent – Article 9(2)(a) GDPR

As long as reasonably necessary for the purposes of organising the event and then for up to 6 years afterwards, after which we will delete it.

We may process your individual contact details in order to send you direct marketing material by email in order to advertise, market or promote our services (either to you or the person that you work for, as appropriate).  We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.

You may at any time opt out of receiving marketing communications from us; please see our contact details at the end of this policy.

The personal data processed comprises:

• Name
• Job function; department.
• Work contact details (email address, phone number, address).
• Events to which invited or which are attended.
• Communications sent or received, and whether you have opened them or responded to them.
• Use of websites (e.g. tracking data from use of our website)

The legal basis for the processing is:

• You give consent to the processing – Article 6(1)(a) GDPR 
• The processing is necessary for the purpose of legitimate interests pursued by us in providing and promoting our services – Article 6(1)(f) GDPR 

We will keep the personal information for a reasonable period consistent with sending you marketing communications, after which we will either confirm that you are happy for us to continue to do so, or delete it (except to the extent we need to retain it for the sole purpose of suppressing further marketing communications to you).

We may collect information on your visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive.  We may keep a record of the content on our website that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests and which we have identified based on content you have looked at.  This may involve the use of cookies, which is explained in our cookies policy.

The personal data processed comprises:

• You name and/or other identifier (for example, your IP address)
• Who you work for
• Your visits to our website
• Content viewed by you
• Links followed by you
• Information downloaded by you

The legal basis for the processing is:

• You give consent to the processing – Article 6(1)(a) GDPR 
• The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – Article 6(1)(f) GDPR

We will keep the information for a reasonable period and then delete it.

If:

• You provide goods or services to us.
• You work for, or are an agent for or otherwise represent, someone who provides or is being considered as a provider of such goods or services.
• We are assessing your suitability (or that of the person you work for) to provide such goods or services.

We may process information relating to you to enable us or other suppliers of ours to manage and administer the provision of goods or services by you or the person that you work for and to communicate with you in relation to that provision.

The personal data processed comprises:

• Name
• Contact details (name, address, email address, phone number)
• Communications sent or received
• Goods or services purchased and/or delivered
• Other personal details relevant to your involvement in the services being provided (for example, your CV if you are an individual who is contracting to provide services)
• Professional or other accreditation details.
• Passport details.
• Bank account or other financial details.
• Images of you

The legal basis for the processing is:

• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual supplier) – Article 6(1)(b) GDPR.
• The processing is necessary for the purpose of legitimate interests pursued by us in operating our business and providing our services – Article 6(1)(f) GDPR

We will keep the information for as long as necessary to facilitate the provision by you of the relevant goods or services and then for a period of up to 6 years afterwards, after which we will normally delete it.  If we consider you, but decide not to select you, to provide such goods or services, then we will normally keep any relevant information provided by you for a period of 6 months, after which we will delete it (unless you have agreed to allow us to retain it in case, for example, we may wish to contact you in future regarding other opportunities to provide goods or services).

We may collect personal information in relation to you in connection with any application by you for a position with us.  In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.

The personal data processed comprises:

The legal basis for the processing is:

• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract – Article 6(1)(b) GDPR.
• The processing is necessary for the purpose of legitimate interests pursued by us in assessing job applicants for suitability– Article 6(1)(f) GDPR

If you are employed by us, we will keep the personal data for the duration of your employment and then for a further period of 6 years, after which the information will normally be deleted.

If you are an unsuccessful applicant, for up to 12 months after your application, after which we will delete it unless we have agreed otherwise with you.

Where appropriate, we may disclose your personal data to third parties:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
• Other appropriate third parties including:
  1. our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
  2. the media, where you are participating in advertising or other marketing or promotion that is intended to be publicly disseminated;
  3. our auditors, legal advisors and other professional advisors or service providers;
  4. credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
• In relation to information obtained via our website:
  1. Our advertisers and advertising networks that require the data to select and serve relevant adverts on our website, other websites and social media platforms to you and others.   We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
  2. Analytics and search engine providers that assist us in the improvement and optimisation of our site and are subject to the cookie section of this policy.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or our safety or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff who work for us, for a company in the same group as us or for one of our suppliers, and who are situated outside the EEA,. This includes staff engaged in, among other things, the fulfilment of service delivery, the processing of payment details and the provision of support services.

Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information, and that it is treated securely and in accordance with this privacy policy.  

All personal data processed by us is stored securely.  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 to our website and 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.

Under data protection law, you have certain rights.  Your rights depend on our reason for processing your personal information.

• You may request access to the personal data concerned (please see the section on obtaining access to your personal data, below).
• You may request that incorrect personal data that we are processing be rectified.
• In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
• Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned.

If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal complaint with the Information Commissioner.

Where personal data is being processed on the basis of consent by you, you can withdraw your consent to any relevant processing of personal data:

• By emailing us at  Contact Us
• By writing to us at the address below.

You can exercise your right of access to your personal data:

• By emailing us at Contact Us
• By writing to us at the address below.

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

Our full details are:

ViewsHub Ltd

Contact: The Data Protection Officer

Email: Contact Us

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.  This policy was last updated on 30/09/2020