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). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.hurrcollective.com (the Platform) or using any services offered through or associated with our Platform (the Services), you are deemed to have accepted and consented to the practices described in this policy.
HURR processes personal data as a Data Controller, as defined in the Directive and the General Data Protection Regulation (GDPR). HURR has a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at firstname.lastname@example.org.
The Platform contains links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other Users. 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.
Any capitalised defined terms used are consistent with the definitions in our Terms of Service available here.
Data We Collect About You
We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect and process about you is explained in the sections below. You can visit our Website without registering for an account.
Data You Give Us
You give us information about you by filling in forms on our Platform or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you view publicly available content, register to use the Platform, request to rent an Item through the Platform, subscribe to our marketing database, subscribe to our Services, search for an Item or Service, participate in social media and messaging functions (with us and/or other Users) on our Platform, enter a competition, promotion or survey, leave a review for another Member or report a problem with the Platform.
The information you give us includes names, address, email address or login details, phone number, age, date of birth, place of birth, business information, financial and credit card information, personal identification number(s), personal description and characteristics (including photographs), spatial data (location data), behavioural data, purchase history, financial transaction history, asset information (internet protocol or media access control), gender and characteristics of the the Item(s) for rent (including photographs, original retail price, rental price and accurate description) and information about your communication with us and other Users.
You are required to register as a Member in order to make full use of our Platform. During the registration process, you will need to create a profile. Some of the above information, such as your profile picture, phone number, email address and gender, will be included on your profile and will be visible to other Users.
Parts of your profile will be public such as your first name, city and profile picture. Listings may be publicly visible, as such information relating to the listing (e.g. description, Item availability, Lender profile picture and first name) will be visible. Reviews from Lenders/Renters will be published and visible on your public profile. Any content submitted to a public forum or social media platform may be visible to others. Anything you share on the publicly available part of the Platform will also be catalogued by third party search engines. We are not responsible for their use of your information or the accuracy of it.
We rely upon the User’s explicit consent to collect and process the data described above. This data is necessary for our legitimate interests and for us to fulfill our contractual obligations to you, and we rely on this as an additional lawful basis to use and process the data described above.
If you choose to access our Platform from a shared computer or open wifi connection, we strongly recommend logging off and removing cookies and the history of the websites visited once you’ve finished.
Data We Automatically Collect
Each time you visit or use our Platform, we automatically collect the following information:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform.
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Platform (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and Services). Because we collect, use and share this information in the aggregate, it does not identify any individual.
We rely upon the User’s explicit consent to use and process the data described above. This data is necessary for us to fulfill our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above.
Data We Receive From Third Parties
We use third parties such as Yoti, Intercom, Google Analytics, Instagram, Facebook, Google APIs and other business partners including but not limited to technical subcontractors, payment and delivery services, advertising networks, analytic and search information providers or credit reference agencies. The information provided to us varies and is controlled by the specific service or as authorised by you via your privacy settings for that service.
For more information on how these companies handle your personal data, please refer to their privacy policies. We rely upon the User’s explicit consent to use and process the data described above.This data is necessary for us to fulfill our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above.
How We Use Your Data
We use your data to provide and improve our Platform and Services in the following ways:
- To administer and manage your account via email and SMS, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
- To ensure that content from our Platform is presented in the most effective manner for you and for your device.
- To allow you to personalise or otherwise customise your experience by, among other things, ranking search results or showing advertisements based on your search, booking history, and preferences.
- To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Platform or Services.
- To prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches and to enforce our Terms of Service.
- To offer services enabling you to sign in to your social media accounts via the Platform and to share information with third party social media websites such as Facebook, Instagram and Twitter.
- If you provide us with contact information for individuals you’d like to refer to the service, we may use and store this information to facilitate your referral invitations.
We also use your data to make our Platform and Services better in the following ways:
- To measure or understand the effectiveness of advertising and marketing we provide to you and others, deliver relevant advertising to you and make suggestions and recommendations to you and other Users of the Platform about goods or Services that may interest you or them.
- To administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep the Platform safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect our/your IT system.
- To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HURR or our third party business partners.
We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at email@example.com.
We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
How We Secure Your Data
All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party softwares. Your information is only accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.
It is explicitly prohibited to use our member-to-member communication system to send content that violates our Terms of Service or spam of any kind. We reserve the right to scan internal messages to check for spam, phishing, viruses and other malicious, prohibited or illegal behaviours or content. Please note, the messages sent through internal systems are not stored indefinitely and you must not rely on the storage of those messages.
How Long We Store Your Data
We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you delete your account by sending an email to firstname.lastname@example.org.
Sharing information between Renters and Lenders
In order to facilitate the renting of Items, we may share your information with other Members under the following circumstances:
- When a Renter submits a Rental Request, we will provide the relevant Lender with the Renter’s full name, cancellation history, reviews and any other information you agree to share. Once the Lender has accepted the Rental Request, we will share the requesting Renter’s information to co-ordinate the delivery of the Item such as the Renter’s phone number and address.
- When a Lender accepts a Rental Request we will share information with the Lender such as your full name, phone number and address for co-ordinating the return of the Item.
We will never share your billing or payment information with other Members.
In the interest of preventing fraud, carrying out risk assessments, investigating complaints, complying with regulations, researching and developing our offerings and effective customer service we reserve the right to review, scan and/or analyse the communications between Members on the Platform. We may do this using automated methods or manually as necessary. We will not use the information gathered to send marketing communications to you without your permission and we do not sell any resulting reviews or analyses. They are intended for internal use only.
Disclosure to Third Parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as Yoti for ID verification, Stripe for payments, Facebook, Google or Intercom (customer relationship management software). These third parties have access to data we share with their platforms.
The only other circumstances under which we would share your personal data are:
- If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- 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.
- If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms of Service and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- As required by any applicable tax authority to facilitate the collection of any applicable taxes resulting from your use of the Platform. You hereby give us your express permission (as a Renter or a Lender) to disclose to the relevant tax authorities your data and any other relevant information pertaining to you or your transactions, whether pending or completed, without further notice.
Parties with whom you may choose to share your information
You may choose to share any information, photographs or other content that you voluntarily submit to the Platform. Such data will become available and viewable by other Users as controlled by any applicable privacy settings that you define. To change your privacy settings on the Platform, please login and do so via your User dashboard. Once you have shared your content or made it public, that content may be re-shared by others.
Connecting Your Social Media
If you choose to connect to social media networks from our Platform (for example via Facebook Connect when you sign up) or post any of your content on our Platform to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other Users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties.
In the event you choose to link your HURR profile with a social media account, information you provide to us in the process may be included on your HURR profile. Additionally, your contacts on the social media platform(s) (‘Friends”) may be able to see your activity on the Platform. A link to your public profile on the social media site may be added to your HURR profile and other Users may be able to see any Friends or links (e.g.friends of friends) via that social network you may have in common with them.
When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Platform, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third parties who can use that information at their discretion.
You may review, modify, update, correct or remove any personal data you have submitted to the Platform at any time. If you remove information that you posted to the Platform, copies may remain viewable in cached and archived pages of the Platform, or if other Users or third party APIs have copied or saved that information.
You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). 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 as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. 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.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.
We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:
- You have given your clear consent to the processing of your personal data for a specific purpose.
- Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
- Processing is necessary for our compliance with the law.
- Processing is necessary to protect someone’s life.
- Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
- Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
Data Subject Rights
Under the GDPR, you have the right to:
- Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
- Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
- Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
- Correct or supplement any information we hold about you that is incorrect or incomplete.
- Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
- Object to the processing of your data.
- Obtain your data in a portable manner and re-use the information we hold about you.
- Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
- Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request in these circumstances.
You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at email@example.com, or by unsubscribing using the links contained in the marketing emails.
We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.
Some of the cookies we use are essential for the Platform to operate. If you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Platform.
Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. For further details, please consult the help menu in your internet browser.
We use the following cookies:
- Strictly necessary cookies. These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Platform. They include, by way of general example, cookies that enable you to log in to secure areas of the Platform, use secure checkout, or make use of Stripe. These cookies are session cookies, which means they’re temporary and will expire when you close your browser.
- Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they’re using it. These cookies help us improve the way the Platform works by, for example, ensuring that Users are finding what they’re looking for easily.
- Functionality cookies. These cookies are used to recognise you when you return to the Platform. They enable us to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies. These cookies record your visit to the Platform, the pages you visit, and the links you follow. We use this information to make the Platform and the advertising displayed on it more relevant to your interests. We also share this information with third parties for the same purpose, to enforce legal agreements that govern the use of the Platform and for fraud detection and prevention.
- Social media cookies. These cookies work together with social media plug-ins. For example, when we embed photos, video and other content from social media websites, the embedded pages contain cookies from these websites. Similarly, if you choose to share our content on social media, a cookie may be set by the service you have chosen to share content through.
- Third Party cookies. We use third party cookies on the Platform from for example: Yoti, Intercom, Google Analytics, Instagram, Facebook, Google APIs, Stripe for Identity verification, linking to social media sites, processing payments, Platform analytics and communication with our Members. Please note that we do not control cookies placed by third parties and our Platform does not block them. Please check the relevant third party website for more information about these cookies.
You have the right to opt out of social media cookies and third-party cookies and to object to automated profiling. To enforce either of these rights please contact us at firstname.lastname@example.org.
Last Updated: 5th October 2018