This page explains how we use your personal data.
“We” refers to DD Hub Limited (details below), “you” refers to you as a user of our services and “our services” includes our website and other services we provide.
We take seriously our responsibilities to look after your data and we are committed to protecting your privacy. There are steps you can take to control what we do with your data and we have explained those steps in this privacy notice.
This notice explains how and why we collect and store data, our lawful bases for it, and how we use it.
It also explains that we may also hold personal data as a data processor, on behalf of some of our Subscriber firms (explained below).
When we talk about data and personal data in this privacy notice, we mean personal data which identifies you or which could be used to identify you such as your name and contact details. It may also include information about how you use our website and services.
The “big picture”
We bring businesses together to share business information.
The personal data we hold relates only to individuals acting in a business capacity – for example, business phone numbers and email addresses.
Firms which provide products or services subscribe to our services (“Subscriber firms”) and provide responses to research and due diligence questions which we hold in our systems.
Those responses may be viewed by individuals:
- who register with us, or
- who register with a partner firm which displays our services within their website
(each referred to as Registered Users) or who access the responses via a Subscriber’s own website.
This privacy notice tells you about how we use your personal data – please ask if you have any questions.
What you need to know
1. Who is responsible for your data
DD Hub Limited is responsible for your data. We are registered in England under company number 10024950 and our registered office is 2nd Floor The Royals, Altrincham Road, Manchester, M22 4BJ. We are the data controller of the data which we collect from you, and as such we control the ways your personal data are collected and the purposes for which your personal data are used.
Some of our Subscriber firms pay to licence our services to manage their research and due diligence data. In such circumstances, a response given by the Subscriber firm to a question may include personal data – for example, names of key executives or contact details of representatives. In such cases, that Subscriber firm is the data controller and responsible for that data.
2. Information we collect
When you contact us or use our services, we collect the following types of information:
Information you, or your firm, provide to us (or to a partner firm of ours)
If you contact us to enquire about our services, we will use your name and contact details to respond to you and keep in contact with you, unless you ask us not to.
Some information is required to create an account on our services, such as your name, email address, password, and your telephone number. You might provide this information directly to us or, where you work for a firm, your firm might provide it to enable you to use our services on the firm’s behalf.
If you register with one of our partner firms and ask to access DD|hub's services via that partner's website, that firm will pass to us your name and business email address, and your firm’s name and FCA registration number.
Information we receive from your use of our services
When you log in to our services or access them via a partner’s website (or via a Subscriber’s website), we collect data about the devices and computers you use to access the services, including IP addresses, browser type, language, operating system, the referring web page, pages visited, and cookie information.
This includes information about your use of the services, for example, the products or services you look at and the reviews you undertake, or other interactions with DD|hub.
If you make your name and/or business contact details public (for example, on your firm’s website, LinkedIn, or other website), we may use those to contact you in relation to our services if we believe they are likely to be directly relevant to you.
3. How we use your data, and our lawful basis
We can only use your personal data if we have a proper reason for doing so, such as:
- To fulfil a contract we have with you (or with a firm you work for), or
- If we have a legal duty to use your data for a particular reason, or
- When you consent to it, or
- When it is in our legitimate interests.
Legitimate interests are our business or commercial reasons for using your data but, even so, we will not unfairly put our legitimate interests above what is best for you.
Here are the ways in which we use your personal data and the reasons we rely on for doing so:
|Your personal data||How we use it||Legal grounds for using it|
|Your name and contact details which you, or your firm, have given to us||To communicate with you in relation to core system functionality.||Our legitimate interests|
|Your communication preferences||To send relevant communications to you||Our legitimate interests|
|Your email address and password||To give you access to our services and to personalise content to you.||Fulfilling a contract|
|Your name and contact details||To show colleagues in your firm who has access to our services and who has changed any information.||Fulfilling a contract|
|Information about how you access our services, device, browser, etc||To remember your preferences and to develop and manage our services, and ensure they are delivered to you appropriately. For example, we use HelpHero to provide helpful tips on how to use our service, and you can choose to “turn off” these tips if you don’t want to see them.||Our legitimate interests|
|Information about your use of our services, your name and contact details||To personalise content and give you easy access to searches you’ve made and content relevant to you, including information which you’ve saved, amended or assessed, and to deliver information to help you meet your regulatory requirements such as updated responses to questions.
If you are a Registered User or if you access data via a Subscriber’s website, information about your use of a Subscriber firm’s data (or request to access such data) may be made available to that Subscriber. This “use” includes whether you have viewed or downloaded the data, whether you have Followed that Subscriber in order to keep informed of updates, or whether you have set any date for reviewing that data.
|Our legitimate interests|
|Business contact information you make publicly available||To communicate with you in respect of our services, to the extent that we believe the communication will be relevant to you and your business interests.||Our legitimate interests|
Where we rely on our legitimate interests for using your personal data, these may include:
- Keeping our records up to date
- Considering whether our services may be of interest and relevance to you
- Developing our services and calculating our charges
- Being efficient about how we fulfil our contracts, provide our services and fulfil our legal duties
- Identifying ways to improve the way we deliver services to our customers
We transfer information to the IT companies which host our services which process it for us, based on our instructions and in compliance with the data processing agreement we have with them.
Additionally, where we are processing data on behalf of a Subscriber firm:
|Your personal data||How we use it||Legal grounds for using it|
|(Applies only to data provided to us by a paying Subscriber firm)
May include an individual’s name, contact details and other information relevant to that person’s involvement with that Subscriber firm’s business
|The Subscriber firm must decide which user firms can view that information: we will make the information available to those firms.||Fulfilling a contract with that Subscriber firm|
4. How long do we keep personal data for? Asking for personal data to be erased.
Because many of our Registered Users work for firms which are authorised and regulated by the Financial Conduct Authority (“FCA”), they are bound by FCA rules, including the need to retain records. If any later question arose, it may be necessary to establish what information was held and displayed by our services at a particular point in time. We therefore intend to hold information (which may include personal data) for six years from the point at which it was last accessed. If you ask us to erase your personal data before then, we will do so unless there is a legal or regulatory reason to retain it.
5. Where is personal data stored and how do we protect it?
Data is encrypted within our secure servers and file systems all in the UK, with access controls to keep it safe. Regular daily backups ensure that integrity is preserved. Our services deliver the data via secure webpages, to ensure that it cannot be intercepted.
HelpHero provide the helpful usage tips and introductory tour for new users of our service. To do this, Information from your browser may be transferred to them with a user identifier reference (but no other personal data). HelpHero use Google Cloud servers in the US and we have a data processing agreement with them to ensure that this data is processed correctly and kept securely.
7. Mailing Lists
If you register with us to join our mailing list, we ask for your personal data and your consent to use it. We will send you information and updates following your sign up, and hope that they will be useful and interesting to you. You can ask us to remove you from the list at any time (see next paragraph).
8. Your rights
If you have any questions or concerns, or if you want to access or amend your data, please contact us at email@example.com or on 0203 633 2185.
In the unlikely event that you have a complaint about DD Hub and how we have used your personal data, that you don’t feel we can rectify, you have the right to contact the Information Commissioner’s Office: https://ico.org.uk.
Changes to this privacy notice
This notice may be amended from time to time. If we change it, the alterations will be published on these pages, and on our website.
This version: 1.10 4 July 2023