Business and Marketing Consultants Our Privacy Policy The Moon Hub Privacy Policy
INTRODUCTION Welcome to the The Moon Hub Limited (“The Moon Hub”) Privacy Policy.
The Moon Hub respects your privacy and is committed to protecting your personal data. This
Privacy Policy will tell you how we look after your personal data when you visit our website
and together referred to as the “website” and inform you of your privacy rights and how the
law protects you. Please use the Glossary at the end of this Privacy Policy to understand the
meaning of some of the terms used in it. Our Cookies Policy is set out below, at the end of
this Privacy Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY
POLICY
This Privacy Policy aims to give you information on how The Moon Hub collects and
processes your personal data through your use of our services, including any data you may
provide through the website when you sign up to receive our marketing material, purchase a
product or service or take part in a competition. It is important that you read this Privacy
Policy together with any other privacy notice on our website from time to time so that you are
fully aware of how and why we are using your data.
CONTROLLER
The Moon Hub is the controller and responsible for your personal data (collectively referred
to as, “we”, “us” or “our” in this Privacy Policy). If you have any questions about this Privacy
Policy, including any requests to exercise your legal rights, please contact us via our contact
page.
CONTACT DETAILS
Our full details are: Full name of legal entity: The Moon Hub Enterprises Limited, a limited
company with registered number 10341057. The Moon Hub is registered, and operates, in
the United Kingdom. Postal address: The Moon Hub, 14 East Bay Lane, E20 1GB. You can
also contact us through our customer contact page. 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 (https://ico.org.uk). In the UK, please read:
https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance. CHANGES TO THE PRIVACY POLICY AND YOUR
DUTY TO INFORM US OF CHANGES We may need to update this Policy at any time and
without notice and where we do this we will notify you by including pop up boxes on the
website and/or emailing our customers. This Policy was last updated on 22nd May 2018. It is
important that the personal data we hold about you is accurate and up to date. Please keep
us informed if your personal data changes during your relationship with us and periodically
review your account settings on our website.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. 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 websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the Privacy
Policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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: • Identity Data includes
first name and last name. • Contact Data means the data we use to contact you including
your billing address, delivery address, email address and telephone number. • Financial
Data means the data we use to process your payments for your orders including your
payment card details. We do not store or process your card details ourselves, they are
processed and stored via one of our contracted third party service providers. We encrypt
your payment card details in your browser and securely transfer this data to our relevant
third party payment provider to process a payment. • Transaction Data means details about
transactions you have made on our website including the payments to and from you along
with other details of products and services you have purchased from us. • Technical Data
means details abou
the device(s) you use to access our website including your internet
protocol (IP) address, browser type and version, location, browser plug-in types and
versions, operating system and platform and other technology on the devices you use to
access this website. • Profile Data includes your username (email address) and password,
your login data, purchases or orders made by you, your interests, preferences, feedback and
survey responses. • Usage Data includes information about how you use our website,
products and services. This includes your browsing patterns and information such as how
long you might spend on one of our webpages and what you look at and for on our website,
the click stream to and from our website, page response times and page interaction
information such as scrolling, clicks and mouseovers. • Marketing and Communications Data
includes your preferences in receiving marketing from us and your communication
preferences. We also collect, use and share aggregated and/or anonymised data
(“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 website 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 Privacy Policy.
IF YOU FAIL TO PROVIDE PERSONAL DATA 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. 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED? We use different methods to collect
data from and about you including through: • Direct interactions. You may give us your
Identity Data, Contact Data, Transaction Data, Profile Data, Financial Data and Marketing
and Communications Data by using our website, filling in forms or by corresponding with us
by post, phone, email or otherwise. This includes personal data you provide when you •
purchase a product or service through our website; • request marketing to be sent to you; •
enter a competition; or • provide us with feedback.
4. THIRD PARTY SOURCES OF DATA/DATA SHARING: We also collect from and share
data with the following providers: • Essential Service Providers: Sometimes, other
businesses give us data about you which we may need for our legitimate interests of
conducting business with you and on occasion they are necessary to perform our contract
with you. It usually comprises Financial Data or Transaction Data. This happens when we
link through to third party payment providers. They tell us that you have paid for your
products and, where relevant and/or necessary they will provide us with your Contact Data
and Transaction Data. • Professional Advisers and Investors: We may also share your data
with professional advisers such as our lawyers and insurers to manage risks and legal
claims, and/or as part of our relationship and obligations to our investor organisations. This
is in our legitimate interests. • Group: It is possible we could sell our business to a third party
or re-organise our business or become insolvent. In that scenario, our database of
customers is one of the biggest parts of that business and so we would need to share it with
the third-party buyer and their advisers. This is in the legitimate interests of selling our
business. We may also expand our group of companies and in this scenario we may share
your data within our group in order to improve our products and services and because of
some of our internal support services may be shared across the group. This is in our
legitimate interests of cost efficiency and growing our business. Where this occurs, we will
post a link to all group companies and their locations in this Privacy Policy and they will use
it in the ways set out in this Policy. • Law Enforcement/Legal Compliance: We will cooperate
with all third parties to enforce their intellectual property or other rights. We will also
cooperate with law enforcement requests from within or outside your country of residence.
This may include disclosing your personal information to government or law enforcement
agencies, or private parties, when we have a good faith belief that disclosure is required by
law or when we, in our discretion, believe that disclosure is necessary to protect our legal
rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud
reduction or legal process served on us. In such cases, we may raise or waive any legal
objection or right available to us. These uses of your data are in our legitimate interests of
protecting our business security. We may also use your data and share it with the recipients
listed in this Privacy Policy for the purpose of complying with our legal obligations. The lawful
bases for sharing and processing this data is set out below and please refer to the External
Third Parties listed in the Glossary for further information.
5. HOW WE USE YOUR PERSONAL DATA 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: • Where we need to perform the contract we are about to enter into or have
entered into with you. • Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those interests. • Where we
need to comply with a legal or regulatory obligation. See the Glossary at the end of this
Privacy Policy to find out more about the types of lawful basis that we will rely on to process
your personal data. Generally we do not rely on consent as a legal basis for processing your
personal data other than in relation to sending third party direct marketing communications
to you via email or text message. You have the right to withdraw consent to marketing at any
time by contacting us via email or through our website. PURPOSES FOR WHICH WE WILL
USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all
the ways we may 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. Purpose/Activity
Type of data Lawful basis for processing including basis of legitimate interest To register you
as a new customer (a) Identity (b) Contact Performance of a contract with you. To process
and deliver your order, including: 1. managing payments, fees and charges; and 2.
managing your queries through our Customer Service team – this may include recording
calls to our teams. (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and
Communications Performance of a contract with you. We may also use some of the data
related to your queries for our legitimate interests of ensuring our customer service quality
standards are met. To collect and recover money owed to us in respect of your order (a)
Identity (b) Contact (c) Financial (d) Transaction Necessary for our legitimate interests (to
recover debts due to us). To carry out fraud assessments (a) Identity (b) Contact (c)
Financial (d) Transaction (e) Technical Necessary for our legitimate interests of ensuring
payments are not fraudulent To notify you in relation to our legal obligations and documents,
including changes to our terms or Privacy Policy (a) Identity (b) Contact Necessary for our
legitimate interests of ensuring our customers are updated on these changes. To enable you
to partake in a prize draw or competition (a) Identity (b) Contact (c) Usage (d) Marketing and
Communications Performance of a contract with you to fulfil the promotion and run the
competition/prize draw. We may also subsequently use your entries for the legitimate
interests of understanding our customer base more effectively. To administer and protect our
business and this website (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical
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). To use data analytics to improve our
website, 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 website 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 Necessary for our legitimate interests (to develop our products/services and grow
our business, and to improve our offering to you). We do not conduct any automated
decision making. We may on occasion profile our customers for the purposes of targeting
marketing at them and where this is done, this is undertaken for our legitimate interests of
ensuring our marketing is relevant to its audience. For example, we may classify an
appropriate audience for a promotion by what products on our website they have previously
looked at or expressed an interest in. We do not conduct any online behavioural tracking.
MARKETING 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 only use the
data you provide to us directly for this purpose along with the Aggregated Data provided to
us by our analytics partners and we do not track what other websites you may visit after
visiting our site, though in common with most websites, we may register the site which
referred you to our site (e.g. a search engine). We strive to provide you with choices
regarding certain personal data uses, particularly around marketing and advertising. We
generally only send electronic marketing – such as email marketing – to people who have
previously bought similar products from us and this is in our legitimate interests. We will
always offer a way out of receiving this marketing when you first purchase our products and
in every marketing communication afterwards. We may on occasion send out postal
marketing for the purpose of growing our sales which is in our legitimate interests and in this
scenario we will rely on you to let us know if you do not want to receive this by opting out of
marketing (see Opting out below). Where you have not previously bought from us but have
registered your details with us (for example by entering a competition or signing up for a
newsletter), we will only send you marketing communications if you opted into receiving
marketing at the time and so given us your express consent (which you may withdraw at any
time – see Opting out below). OPTING OUT You can ask us to stop sending you marketing
messages at any time by sending us an email or contacting us through our contact page at
any time. If you opt out of receiving email marketing from us, you will no longer receive
emails about offers, news and updates from us. However, you may continue to see our ads
through social media, due to their general demographic targeting. Please check the social
media platforms for more detail of how to opt out from seeing these ads. 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, or related correspondence, and we will continue to
process such data in accordance with this Privacy Policy and only ever as permitted by law.
COOKIES The Moon Hub, at this time, does not use cookies on its website or any of its
apps. CHANGE OF PURPOSE 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.
6. DISCLOSURES OF YOUR PERSONAL DATA We require all third parties to respect the
security of your personal data and to treat it in accordance with the law and they may only
use your data for the purposes we specify in our contract with them. We will always work
with them to protect your privacy.
7. INTERNATIONAL TRANSFERS Some 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. 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 will only transfer your personal data to countries
that have been deemed to provide an adequate level of protection for personal data by the
European Commission. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries. • Where we use certain service providers,
we may use specific contracts approved by the European Commission which give personal
data the same protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries. • Where we use providers
based in the US, we may transfer data to them if they are part of the Privacy Shield which
requires them to provide similar protection to personal data shared between the Europe and
the US. For further details, see European Commission: EU-US Privacy Shield. Please
contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
8. DATA SECURITY 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. 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. You acknowledge that the Internet is not a completely secure medium for
communication and, accordingly, we cannot guarantee the security of any information you
send to us (or we send to you) via the Internet. We are not responsible for any damages
which you, or others, may suffer as a result of the loss of confidentiality of such information.
9. DATA RETENTION HOW LONG WILL THE MOON HUB USE YOUR PERSONAL DATA?
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. In some circumstances you can ask us to delete your
data.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 notice to you.
10. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under UK data
protection laws in relation to your personal data. You have the right to: 8 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 for example where you consider that we do
not need it any longer for the purposes for which we originally collected it as explained to
you in this Privacy Policy, where you have withdrawn your consent to our using it and we
had relied on that consent according to this Policy, where you consider that we cannot show
a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest
to process it as explained to you in this Policy . 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 wish to exercise any of these rights, please Contact
Us. NO FEE USUALLY REQUIRED 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.
9 WHAT WE MAY NEED FROM YOU 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. TIME LIMIT
TO RESPOND We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month 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.
11. GLOSSARY LAWFUL BASIS 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.
THIRD PARTIES EXTERNAL THIRD PARTIES Partners – when you place an order, we
share your information with the relevant seller on our marketplace (“Partner”) so that they
can process and deliver your order. Cloud storage providers – we use cloud computing
platforms that securely store all of our data, including customer details. Email service
providers – in order to send you marketing content and transactional emails, we share your
details with our email service providers. See the ‘Marketing’ section of this Privacy Policy
above. Analytics tools – we use analytics tools to track the way that users interact with our
website. Profiling tools – we use profiling tools to understand how you engage with our
website and show you content we think will be most relevant to you, based on our
understanding of your interests and preferences. Payment providers – in order to facilitate
any payments made on our site, we facilitate the sharing of your Financial Data with
payment providers. Delivery providers – in order to package and mail your orders to you, it is
necessary to share your information with delivery providers. Marketing and insights providers
– marketing and insights tools allow us to understand our customers better so that we may
provide you with the best possible website, products and customer service experience. We
may share certain information about our customers to facilitate this process. Customer
service platforms – when you interact with our customer service team, your details are
shared with our customer service platform providers. Feedback forms – when you make a
purchase, we engage a third party to send out feedback forms on our behalf. Sharing with
social networks If you use the buttons that allow you to share products and content with your
friends via social networks like Twitter and Facebook, these companies may set a cookie on
your computer memory. Find out more about these here:
https://www.facebook.com/about/privacy/ http://twitter.com/privacy
http://www.google.com/intl/en-GB/policies/privacy/