Privacy policy

This privacy policy applies between you, the User of this Website and ESBM Hub, the owner and provider of this Website. ESBM Hub takes the privacy of
your information very seriously. 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.

Please read this privacy policy carefully
.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Datacollectively all information that you submit to ESBM Hub
via the Website. This definition incorporates, where
applicable, the definitions provided in the Data Protection
Laws;
Cookiesa small text file placed on your computer by this Website
when you visit certain parts of the Website and/or when you
use certain features of the Website. Details of the cookies
used by this Website are set out in the clause below ( Cookies);
Data Protection Lawsany applicable law relating to the processing of personal
Data, including but not limited to the Directive 96/46/EC
(Data Protection Directive) or the GDPR, and any national
implementing laws, regulations and secondary legislation,
for as long as the GDPR is effective in the UK;
GDPRthe General Data Protection Regulation (EU) 2016/679;

ESBM Hub,
 

we

or us

ESBM Hub, a company incorporated in England and Wales with
registered number 12057238 whose registered office is at 20
Green Glade, Theydon Bois, Essex, CM16 7LY;
UK and EU Cookie Lawthe Privacy and Electronic Communications (EC Directive)
Regulations 2003 as amended by the Privacy and Electronic
Communications (EC Directive) (Amendment) Regulations 2011;
User
or you
any third party that accesses the Website and is not either
(i) employed by ESBM Hub and acting in the course of their
employment or (ii) engaged as a consultant or otherwise
providing services to ESBM Hub and accessing the Website in
connection with the provision of such services; and
Websitethe website that you are currently using,
www.esbm-hub.co.uk, and any sub-domains of this site unless
expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. reference to any statutory provision includes any modification or
amendment of it;

f. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of ESBM Hub and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, ESBM Hub is the “data controller”. This means that ESBM Hub determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

a. demographic information such as postcode, preferences and interests;

b. IP address (automatically collected);

c. web browser type and version (automatically collected);

d. operating system (automatically collected);

e. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

a. data is given to us by you ;

b. data is received from other sources; and

c. data is collected automatically.

Data that is given to us by you

7. ESBM Hub will collect your Data in a number of ways, for example:

a. when you contact us through the Website, by telephone, post, e-mail or through any other means;

in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its
content.

b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Keeping Data secure

9. We will use technical and organisational measures to safeguard your Data, for example:

a. access to your account is controlled by a password and a user name that is unique to you.

b. we store your Data on secure servers.

10. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised
access to your Data, please let us know immediately by contacting us via this e-mail address: info@esbm-hub.co.uk.

11. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity
theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and
leading businesses.

Data retention

12. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil
the purposes outlined in this privacy policy or until you request that the Data be deleted.

13. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

14. You have the following rights in relation to your Data:

a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase – the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

e. Right to data portability – the right to request that we move, copy or transfer your Data.

f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

15. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our
legal basis for processing your Data), please contact us via this e-mail address: info@esbm-hub.co.uk.

16. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to
the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on
their website at https://ico.org.uk/.

17. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for
which we hold it.

Links to other websites

18. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the
content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement
of other websites prior to using them.

Changes of business ownership and control

19. ESBM Hub may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of ESBM
Hub. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new
owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was
originally supplied to us.

20. We may also disclose Data to a prospective purchaser of our business or any part of it.

21. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

22. This Website may place and access certain Cookies on your computer. ESBM Hub uses Cookies to improve your experience of using the Website. ESBM Hub has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

23. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

24. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies.
By giving your consent to the placing of Cookies, you are enabling ESBM Hub to provide a better experience and service to you. You may, if you wish,
deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

25. This Website may place the following Cookies:

Type of CookiePurpose
Analytical/performance cookiesThey allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

26. You can find a list of Cookies that we use in the Cookies Schedule.

27. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed.
For further details, please consult the help menu in your internet browser.

28. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

29. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the
developer of your internet browser if you are unsure about adjusting your privacy settings.

30. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how
to delete cookies from your computer.

General

31. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy
where we reasonably believe your rights will not be affected.

32. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or
unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of
the other provisions of this privacy policy will not be affected.

33. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any
other, right or remedy.

34. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be
subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

35. ESBM Hub reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes
will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website
following the alterations.

You may contact ESBM Hub by email at info@esbm-hub.co.uk.

Attribution

36. This privacy policy was created using a document from Rocket Lawyer
(https://www.rocketlawyer.com/gb/en).

01 November 2019

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or
there is any discrepancy, please let us know.

Analytical/performance

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.