Guinness Hub Privacy Notice

Let’s treat everyone with respect. Healthy debates are natural, but kindness is required.

Bullying of any kind isn’t allowed, and degrading comments about things such as race, religion, culture, sexual orientation, gender or identity will not be tolerated.

Occasional promotion of LOCAL business is fine. Spam, irrelevant links or promotion of business outside of your neighbourhood isn’t allowed.

Do not upload images or information of others without their prior consent, and always get consent before sharing someone else’s post.

This goes for sale, advertising, rehoming or requests. Guinness Hub is not the place to buy or sell illegal goods, or pets.

This space is for all customers living in your neighbourhood. Please respect others by not posting any inappropriate language, content or imagery. If you see anything that goes against our community rules, please report it to us using the ‘report’ button.

The Guinness Partnership Ltd, 30 Brock Street, Regent’s Place, London, NW1 3FG as a Data Controller will be responsible for determining the use of your information for the purpose of customer engagement. Heyhub as a Data Processor will provide this service on our behalf through the use of the Guinness Hub App (The App)

Heyhub Ltd, Old School House, Ingham Road, West Stow, IP28 6EX as a Data Controller will be responsible for determining the use of your information for the purpose of improving the service it offers to Guinness and Guinness customers

In this privacy notice, ‘we’, ‘us’, and ‘our’ mean The Guinness Partnership Limited and its subsidiary companies within our Group and Heyhub.

The Guinness Hub App is an easy way for you to connect with Guinness Staff and other tenants. We’re committed to protecting the personal information we collect about you and this privacy notice explains what happens to the information you are providing to us.

It also explains how we and some of the companies we work with collect, use, share and protect information in relation to our mobile services, web site, and any software provided on or in connection with the App and your choices about the collection and use of your information.

By using the App, you understand and agree that we are providing a platform for you to post content, including photos, comments and other materials (“User Content”), to the Service and to share User Content publicly with other customers. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the App, consistent with the terms and conditions of this Privacy Policy and Heyhub’s Terms of Use.

Our obligations under Data Protection Regulations are overseen by the Information Governance Team who can be contacted on informationmanagement@guinness.org.uk

The Guinness Partnership has appointed a Data Protection Officer to monitor our compliance with Data Protection Regulations.

If you have any concerns our Data Protection Officer can be contacted at dataprotectionofficer@guinness.org.uk.

Data Protection Officer
The Guinness Partnership
Bower House
1 Stable Street
Hollinwood
Oldham
OL9 7LH

Our obligations under Data Protection Regulations are overseen by the Operations Team who can be contacted on operations@heyhub.com.

Heyhub has appointed a Data Protection Officer to monitor our compliance with Data Protection Regulations.

If you have any concerns our Data Protection Officer can be contacted at operations@heyhub.com.

Data Protection Officer

HeyHub Ltd
68 Hanbury St
Spitalfields
London
E1 5JL

We will only collect the minimum amount of personal data for us to engage with you and for you to engage with others through the use of the App.

To provide the App service, we must process information about you. The types of information we collect depend on how you use the App

Standard personal information

Some of the information we may hold about you is categorised as standard personal information. This includes:

• Your username, password, email address and phone number when you register for the Guinness Hub App;
• Profile information that you provide for your user profile (e.g. first and last name, picture). This information allows you or others be “found” on the App;
• Your interests (e.g. technology, running and other materials) that you post to the App;
• User Content (e.g. photos, comments, and other materials) that you post to the App;
• Communications between you and Guinness (e.g. activities that are taking place on your scheme) or you and Heyhub for example where you may be sent a service-related email (e.g., account verification, changes/updates to the features of the App, technical and security notices)

 Special category information

Other types of data we may collect from you is more sensitive and is considered to be special category information. Again, this will depend on how you use the App but could include:

• Disability or other health information
• Race
• Ethnic origin
• Religion

Information and content you provide

We collect the content, communications and other information you provide when you use the App, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through provided, such as the camera, so we can do things like, provide you with relevant content about what your camera is pointing at, suggest masks and filters that you might like, or give you tips on using portrait mode. The App automatically processes content and communications you and others provide, to analyse context and what’s in them for the purposes described below.

Networks and connections. We collect information about the people, accounts, and communities you are connected to and how you interact with them across the App, such as people you communicate with the most or communities you are part of.

Your usage. We collect information about how you use the App, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you’re using and have last used the App, and what posts, videos and other content you view on the App. We also collect information about how you use features like the camera.

Things others do and information they provide about you. We also analyse content, communications and information that other people provide when they use the App. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.

Device Information

 As described below, we collect information from and about the computers, phones, and other web-connected devices you use that integrate with the App, and we combine this information across different devices you use. For example, we use information collected about your use of the App on your phone to better personalise the features you see when you use the App on another device, such as your tablet, or to measure whether you took an action in response to a communication we showed you on your phone on a different device.

Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use.
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, and connection speed.

We use the information we hold to deliver the App, including to personalise features and content and make suggestions for you (such as communities or events you may be interested in or topics you may want to follow) on the App. To create personalised Services that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide where you have given your explicit consent); how you use and interact with the App; and the people, places, or things you’re connected to and interested in on the App.

Service research and development: We use the information we hold to develop, test and improve the App, including by conducting surveys and research, and testing and troubleshooting new Services and features.

We use third-party analytics tools to help us measure traffic and usage trends for the App. These tools collect information sent by your device or the App, including the web pages you visit, add-ons, and other information that assists us in improving the App. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User. Heyhub will share analytical information with Guinness in order to improve engagement with users.

• Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
• When you use the App, Heyhub servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the App, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the App.

• Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
• Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other’s APIs then, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature) if your photo is made public by you in accordance with your privacy settings.

We may also use information that we receive to:

• help you efficiently access your information after you sign in
• remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
• provide, improve, test, and monitor the effectiveness of our Service
• develop and test new Services and features
• monitor metrics such as total number of visitors, traffic, and demographic patterns
• diagnose or fix technology problems
• automatically update the App on your device

Parties with whom we may share personal information

• Guinness may share information across employees within the Guinness Partnership Group to enable us to improve your customer experience.
• So that we can provide effective services to you Guinness will be required to share your information with Heyhub to enable you to register with the Guinness App.
• Heyhub may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with Guinness for which Heyhub is contracted to in supplying this App and community experience. Guinness may use this information to help provide, understand, and improve their own service (including by providing you with better and more relevant experiences and activities).

• We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Parties with whom you may choose to share your User Content

• Any information or content that you voluntarily disclose for posting to the App, such as User Content, becomes available publicly within the Users on the App, as controlled by any applicable privacy settings that you set. Once you have shared User Content or made it public, that User Content may be re-shared by others.
• Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users.
• If you remove information that you posted to the App, copies may remain viewable in cached and archived pages of the App, or if other Users or third parties using the App have copied or saved that information.

 Responding to legal requests and preventing harm

• In some cases, we may have a duty to disclose your information to the police and other law-enforcement agencies to perform their duties for the purpose of crime prevention or detection, if we have a legal obligation to do so or it is required by a Court Order.
• This may include responding to legal requests from jurisdictions outside of the United Kingdom where the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards. We may also access, preserve and share information when it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of Heyhub’s and Guinness’s terms or policies, or otherwise to prevent harm.

What happens in the event of a change of control for Heyhub

•  If Heyhub sell or otherwise transfer part or the whole of HeyHub or their assets to another organisation (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the App may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honour the commitments Heyhub have made in this Privacy Policy.

• We apply appropriate measures to ensure your personal information is secure.  For example, we have systems in place so that access to personal information is restricted to authorised individuals on a strictly need-to-know basis, taking reasonable steps when requesting a unique password to verify your identity before granting you access to your account;
• Guinness and Heyhub have a contract in place that sets out both parties responsibilities as Data Controllers and for Heyhub as a Data Processor;
• Your information collected through the App will be stored and processed in the EEA, specifically Ireland;
• Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and us, at all times.

We need a lawful reason to use your information, for the majority of your personal information on the App we will use one of the following conditions:

• As necessary to comply with our legal obligations.
• Legitimate interests is one of the legal reasons why we may process your personal information taking into account your interests, rights and freedoms as necessary and for our (or others’) legitimate interests, including our interests in providing an innovative, personalised, safe, service to you.

If you wish to object to us using your information for any of these legitimate interests, please contact the Guinness Data Protection Officer at the details provided above.

Where you publish information on the App which is special category information to this will be processed under the following condition:

• processing relating to personal data which are manifestly made public by the data subject.

We will not use your personal information to send you marketing directly. However, the App will be used to promote activities that customers may wish to engage with such as the Guinness Aspire Awards, training events etc.

Personal data will be stored until it is no longer necessary to provide the service on the App or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

When you delete your account, we delete things you have posted, such as your photos and status updates, and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted.

Data Protection law gives you greater control as to how we can use your information. To enable this, you have the right to request us to take action in relation to your information. You have the following rights:

• Right of access – the right to request details as to how we use your information and to be provided with a copy of that information.
• Right to Rectification – the right to have inaccurate data corrected
• Right to erasure – the right to have certain information about you deleted
• Right to Restriction – the right to request us to limit the use of your personal information in certain circumstances
• Right to Object – the right to object to us using your information for a task carried out in the public interest, where we have informed you that we are processing in our or a third parties legitimate interests or if we use your information for direct marketing
• Right to Data Portability –
• Right to Withdraw Consent –if we have asked for your consent to process some of your personal information, you have the right to withdraw this at any time. We will never ask for consent for providing a service to you or if you would be disadvantaged if you did not want to consent.
• Automated Decision Making –

Please Note:

These rights are not absolute and will be considered on a case by case basis except where you withdraw consent or object to direct marketing. In each case we will let you know in our correspondence with you whether we can comply with your request and provide a full explanation if we cannot comply.

When you make a request, we need to be sure that it is you applying. You will need to either pass our data protection checks or we may ask you to provide 2 forms of identification if we have any doubts.

We will consider each and every request and respond within one month of receiving a valid request. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

If you would like to request access to your personal data, you can do so by using Guinness’s online form.

You can also request access to your personal data or to exercise any of your other rights, by contacting us at:

Information Governance Team
The Guinness Partnership
Bower House
1 Stable Street
Hollinwood
Oldham
OL9 7LH

Or use any of the following methods:

• e-mail: informationmanagement@guinness.org.uk
• call us on 0303 123 1890
• Use the contact us form on our website
• Live chat with us via our website

It would be really helpful if you could provide as much information as possible to help us assess and progress your request.

The App and its content are not directed at children under the age of 16. We will not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register for the App.

In the event that we learn that we have collected personal information from a child under age 16 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us.

Please remember that when you use a link to go from our App to another website or service such as MyGuinness, the Privacy Policy for the App does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorise to access your User Content. If you are using a third-party website or service and you allow them to access your User Content, you do so at your own risk.

It may be necessary for us to modify or update this Privacy Policy from time to time, for example to reflect updates to the App or where required by law. We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before continuing to use the App. Your continued use of the App after any modification to this Privacy Policy will constitute your acceptance of such modification.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officers at the details provided at the beginning of this privacy notice who will investigate the matter.

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can then make a complaint to the Information Commissioner’s Office (ICO).

Information Commissioner,

Wycliffe House, Water Lane,
Wilmslow,
Cheshire
SK9 5AF

Phone: 0303 123 1113

www.ico.org.uk