Last updated: October 2021
This Policy (Policy) relates to your personal information in connection with your use of and access to the HURR Services.
We are committed to protecting your Information (as defined below – see "Information we may collect about you") and your right to privacy. Personal data, or personal information means any information about an identified individual or information from which that person can be identified. It does not include anonymous information, namely information which does not relate to an identified or identifiable individual, or personal data rendered anonymous in such a manner that the individual is not or no longer identifiable. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].
When you use the HURR Services, you trust us with your Information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the HURR Services.
Any capitalised terms that are not defined in this Policy are set out in our Terms.
Changes to this Policy or your personal information
We review this Policy regularly and it is your responsibility to check regularly and determine whether this Policy has changed. If you do not agree to any changes to this Policy then you must immediately stop using the HURR Services. In the event we make any significant changes to this Policy we will use our best endeavours to inform you of such changes in advance in writing.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes for example you change your email address.
The HURR Services are owned and operated by HURR Limited (trading as "HURR") a company registered in England and Wales with company number 11262189 and whose registered office is situated at 85 Great Portland Street, First Floor, London W1W 7LT (HURR/we/us/our). HURR is the controller (also known as a data controller) and is responsible for your personal information. The term "you" refers to the user wishing to access the HURR Platform and/or use the HURR Services.
The HURR Platform provides a platform reinventing ownership by providing all the short-cuts to a sustainable wardrobe through renting, lending, monthly refreshes, purchase or sale of pre-owned clothing.
Information we may collect about you
Personal information you disclose to us
In Short: We collect personal information that you provide to us, including information such as name, address, contact information, clothes sizing and payment card information.
We collect personal information that you voluntarily provide to us when registering to use the HURR Services, accessing the HURR Platform or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the products and features you use. When you use the HURR Services, access the HURR Platform and/or when you otherwise deal with us, we may collect the following information about you (the Information):
- Identity Data includes first name, last name, date of birth, place of birth, clothes, accessories and shoe sizings, photographs, national insurance number, personal ID number, identity documents (e.g. passport), credit checks, personal characteristics and gender.
- Profile Data includes your username and password, profile picture, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Contact Data means the data we use to contact you including your billing address, delivery address, work address, email address and contact numbers.
- Financial Data means the bank account details, payment method and card association used to process your payments for your orders. We do not store or process your bank account details and card details ourselves, they are processed and stored via one of our contracted third party service providers. The bank account details and payment card details you provide via your browser when using the HURR Services on our webpages are encrypted via Hypertext Transfer Protocol Secure (HTTPS) and are then securely transferred to our relevant third party payment service provider to process your payment.
- Usage Data includes information about how you use the HURR Services. This includes your browsing patterns and information including but not limited to how long you might spend on one of our webpages on the HURR Platform and what Items you look at and for, the page that referred you to the HURR Platform and the clickstream during your visit to our website, page response times and page interaction information (clicks you make on a page).
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences including push notifications.
- Social Media and Third Party Login Data. We provide you with the option to register using social media account details, like your Apple, Facebook, Google or third party login account. If you choose to register in this way, we will collect the Information described in the section called "How do we Handle your Social and Third Party Logins" below. All Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Information.
- Other information relevant to our services, customer surveys and/or offers.
THE HURR Services AND YOUR INFORMATION:
You are required to register as a Member and create an account and profile in order to make full use of the HURR Services. Some of your profile information shall be visible to other Members when you interact such as your profile photo and delivery address. Information which will be publicly available to Users on your profile will be your name and profile picture.
Listings that are publicly visible will show any information relating to the listing (e.g. description, Item availability, Lender profile picture and name). Reviews from Lenders/Renters will be published and visible on your public profile. Any content submitted by you to a public forum or social media platform may be visible to Users.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). It is for you to decide whether you want to share such information in the contents you submit through the HURR Platform and share with others. This information is subject to special protections under EU law. However we may collect information about criminal convictions and offences when carrying out credit checks on our Users/Members.
If you fail to provide Information
Where we need to collect your Information by law, or under the terms of a contract we have with you, and you fail to provide that Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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.
Information we may collect from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain Information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook or Instagram), as well as from other third parties. Such information may include:
- Social media profile information (your name, due date, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public);
- marketing leads and search results and links, including paid listings (such as sponsored links); and
- information obtained when carrying out credit checks via Experian;
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.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use the HURR Platform.
How do we use your Information?
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the HURR Services for a variety of business purposes described below. We will only use your Information when the law allows us to. Most commonly, we will use your Information in the following circumstances:
a. where it is necessary for our legitimate business interests (Business Purposes) and your interests and fundamental rights do not override those interests;
b. in order to enter into or perform a contract with you (Contractual);
c. with your consent (Consent); and/or
d. for compliance with our legal obligations (Legal Obligations).
We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes. We will only use your Information 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 Information 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 Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Fulfil and manage any orders and payments in connection with the HURR Services and administer and manage your account (Contractual). We may use your Information or pass it onto other Members in order to enable the HURR Services including the Rental of Items.
- To send administrative information to you for Business Purposes (to develop our products/services), Legal Obligations and/or possibly Contractual. We may use your Information to send you product, service and new feature information and/or information about changes to our Terms and policies.
- To send you marketing and promotional communications for Business Purposes (to develop our products/services and grow our business) and/or with your Consent. We and/or our third party partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails, see below for further details.
- To facilitate account creation and sign in process with your Consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
- Request Feedback for our Business Purposes (to study how customers use our products/services, to develop them, grow our business and inform our marketing strategy) and/or with your Consent. We may use your Information to request feedback and to contact you about your use of the HURR Platform.
- To protect the HURR Services for Business Purposes (for running our business, provision of administration and IT services, network security, to prevent fraud) and/or Legal Obligations. We may use your Information as part of our efforts to keep the HURR Services safe and secure (for example, for fraud monitoring and prevention). This includes reviewing, scanning or analysing communications between Members on the HURR Platform, either by automated or manual methods.
- To enforce our Terms and policies for Business Purposes (for running our business and recover debts due to us), Legal Obligations and/or Contractual.
- To respond to legal requests and prevent harm under Legal Obligations. If we receive a subpoena or other legal request, we may need to inspect the Information we hold to determine how to respond.
- For other Business Purposes which are compatible with the above purposes. We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the HURR Services, products, services, marketing and your experience.
Always think carefully before disclosing your Information or other information to other Users or otherwise posting Information on the HURR Platform. It's important that you're aware that any information you choose to disclose on the HURR Platform may then be viewed and even used by other Users. We do not control the content of communications made between Users (although you can make a complaint about another User by contacting us using the information provided in the Contact section below).
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 Information at any time.
Will your Information be shared with anyone?
In Short: We only share information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent.
We only share and disclose your Information in the following situations for the purposes set out above in "How do we use your Information?":
- Contractual. To share information with Members to enable usage of the HURR Services including renting, lending, purchase or sale of Items. When a Renter submits a Rental Request (or a Buyer submits an Offer), we will provide the relevant Lender/Seller with the Renter/Buyer's full name, cancellation history, Reviews and any other information the Member has agreed to share. Once the Lender/Seller has accepted the Rental Request/Offer, we will share the requesting Renter/Buyer's information to co-ordinate the delivery of the Item such as the Renter/Buyer's phone number and address. When a Lender/Seller accepts a Rental Request/an Offer we will share information with the Lender/Seller 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.
- Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Third-Party Service Providers. We may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service, search information providers, delivery services, analytic providers, credit reference agencies and marketing agencies. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy. The third parties we use include Stripe, Passbase, Zendesk, Google Analytics, Instagram, Facebook, and various Google APIs. In some cases 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.
- Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions. We will get your express opt-in consent before we share your Information with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by logging into the HURR Platform and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, by sending an email to [email protected].
- With your Consent. We may disclose your Information for any other purpose with your Consent.
We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the provision of services.
Is your Information transferred internationally?
In Short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. To the extent that any transfer of your Information outside of the UK is required we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. We will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data.
b. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the HURR Services.
The HURR Platform features links to third-party websites or contains advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the HURR Platform. You should review the policies of such third parties and contact them directly to respond to your questions. Anything you share on the publicly available part of the HURR 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.
How long do we keep your Information?
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). We may retain your Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Information, we consider the amount, nature and sensitivity of the Information, the potential risk of harm from unauthorised use or disclosure of your Information, the purposes for which we process your Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity and Financial Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see "What are your privacy rights?" below for further information.
In some circumstances we will 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.
When we have no ongoing Business Purpose to process your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
How do we keep your Information safe?
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of Information to and from the HURR Platform is at your own risk. You should only access our services within a secure environment. All personal information is encrypted in transit and at rest. Your payment information is also encrypted in transit and at rest by our third party.
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.
It is explicitly prohibited to use our member-to-member communication system to send content that violates our Terms 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 do we handle your Social and Third Party Logins?
In Short: If you choose to register or log in to our website using a social media account or third party website (e.g. Amazon), we may have access to certain Information about you.
The HURR Platform offers you the ability to register and log in using certain social media account details (like your Facebook or Twitter logins) and third party website providers. Where you choose to do this, we will receive certain information from your social media or third party provider. The Information we receive may vary depending on the social media or third party provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public. If you log in using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. The 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 or third party account, the 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 HURR 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.
Do we collect information from minors?
In Short: We take steps to ensure that the HURR Services are only used by those over 18 years of age and we do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the HURR Services, you represent that you are at least 18 years of age. If we learn that Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].
YOUR CONSENT TO PROCESSING:
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the HURR Services.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing [email protected].
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information and delete it together with your account. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the HURR Services and you object or do not provide Consent to us processing your Information, the HURR Services will not be available to you.
MARKETING AND OPTING OUT:
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by unsubscribing from the communications via the link available in each communication.
If you have given Consent, we may share your Information with carefully selected third-party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third-party please contact them directly to withdraw the Consent.
You may at any time review or change the information in your account by logging into your HURR account. You may choose to share any information, photographs or other content that you voluntarily submit to the HURR 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 HURR 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 other Users. You may review, modify, update, correct or remove any Information you have submitted to the HURR Platform at any time. If you remove information that you posted to the HURR Platform, copies may remain viewable in cached and archived pages of the HURR Platform, or if other Users or third party APIs have copied or saved that information.
What are your privacy rights?
In Short: You have certain rights in respect of your Information.
You have certain rights under applicable data protection laws. These may include the right, under certain circumstances:
a. to withdraw consent as set out above (see "Your Consent to processing"). Please note however that this will not affect the lawfulness of the processing before its withdrawal;
b. to request access and obtain a copy of your Information;
c. to request rectification or erasure of your Information;
d. to restrict the processing of your Information;
e. if applicable, to data portability; and
f. to object to the processing of your Information.
If you wish to exercise any of the rights set out above, please contact us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.
We may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response.
No Fee Usually Required
You will not have to pay a fee to access your Information (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 could refuse to comply with your request in these circumstances.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy, about your Information or any other questions, please email us at [email protected].
You have the right to make a complaint at any time to the Information Commissioner's Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.