We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, any other applicable law or regulation relating to the Processing of Personal Data and to privacy (including the E-Privacy Directive and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR, and laws amending or supplementing the E-Privacy Regulations).
We fully respect your right to privacy in relation to your interactions with the Website and endeavour to guarantee to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual user details where we are legally entitled to do so. The legal basis for us handling your data is legitimate business interest. Information in relation to personal data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”).
We may collect Personal Data from you in the course of our business, including through your use of our Website, when you contact or request information from us, when you engage our Service or as a result of your relationship with one or more of our staff. The information that we process includes: (i) basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person; (ii) contact information, such as your postal address, email address and phone number(s); (iii) financial information, such as payment-related information; (iv) technical information, such as information from your visits to our Website or applications or in relation to materials and communications we send to you electronically; (v) information you provide to us for the purposes of attending meetings and events, including access and dietary requirements; (vi) identification and background information provided by you; or (vii) any other information relating to you which you may provide to us.
In the event that you use any of our social media platform via Facebook, Twitter, Instagram, Slack we may use that information only to keep you updated with any events or announcements which may be of interest to you that you had made us known via surveys, emails or chat messages.
Any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Data”). Hubspot and Mailchimp is the CRM platform that we use and is a Data Controller (as defined in Data Protection Legislation) in respect of the Your Data.
We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us.
If you are aged 18 or under, please get your parent/guardian’s permission before you provide Your Data to us.
We collect information from you as necessary in the course of providing our Service. We may collect your personal information while monitoring our technology tools and services, including our website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly. We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publically available sources.
We use that information: (i) to provide and improve our website, including auditing and monitoring its use; (ii) to provide and improve our Service to you; (iii) to provide information requested by you; (iv) to send you update, publications and details of events; (v) to manage and administer our relationship with you; (vi) to fulfil our legal, regulatory and risk management obligations; or (vii) or the purposes of recruitment.
We collect IP addresses from visitors to our Website (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). This allows us to identify the location of users, to block disruptive use and to establish the number of visits from different countries. We analyse this data for trend and statistics reasons, such as which parts of our Website users are visiting and how long they spend there.
A cookie is a small text file that is placed on your device by a web server which enables a website and/or mobile app to recognise repeat users, facilitate the user’s ongoing access to and use of a website and/or mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. We collate information on in relation to the Service which is represented in aggregate format through cookies. They help us to improve our Service and to deliver many of the functions that make your browser experience more user friendly.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
Tune Hoppers may from time to time use Facebook Advertising, Facebook Pixel Re-Marketing, and communications. This tool allows Tune Hoppers to understand and deliver ads and make them more relevant to you. The collected data remains anonymous and Tune Hoppers cannot see the personal data of any individual user.
HubSpot's tracking code sets a number of tracking cookies when a visitor lands on your website. These cookies fall into two general categories:
Essential/necessary cookies : HUBSPOT
This cookie is set when you give visitors the choice to opt out of cookies.
It contains the string "yes" or "no".
|It expires in 13 months.|
|__hs_do_not_track||This cookie can be set to prevent the tracking code from sending any information to HubSpot.|
Setting this cookie is different from opting out of cookies, as it still allows anonymized information to be sent to HubSpot.
It contains the string "yes".
|It expires in 13 months.|
|__hs_initial_opt_in||This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode.|
It contains the string "yes" or "no".
|It expires in seven days.|
|hs_ab_test||This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before.||It expires at the end of the session.|
|_key||When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again.|
The cookie name is unique for each password-protected page.
It contains an encrypted version of the password so future visits to the page will not require the password again.
|It expires in 14 days.|
|hs-messages-is-open||This cookie is used to determine and save whether the chat widget is open for future visits.|
It is set in your visitor's browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity.
It contains a boolean value of True if present.
|It expires in 30 minutes.|
|hs-messages-hide-welcome-message||This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed.|
It contains a boolean value of True or False.
|It expires in one day.|
|__hsmem||This cookie is set when visitors log in to a HubSpot-hosted site.|
It contains encrypted data that identifies the membership user when they are currently logged in.
|It expires in one year.|
|hs-membership-csrf||This cookie is used to ensure that content membership logins cannot be forged.|
It contains a random string of letters and numbers used to verify that a membership login is authentic.
|It expires at the end of the session.|
|hs_langswitcher_choice||This cookie is used to save the visitor’s selected language choice when viewing pages in multiple languages.|
It gets set when an end user selects a language from the language switcher and is used as a language preference to redirect them to sites in their chosen language in the future, if they are available.
It contains a colon delimited string with the ISO639 language code choice on the left and the top level private domain it applies to on the right. An example will be "EN-US:hubspot.com".
|It expires in two years.|
|__cfduid||This cookie is set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors to your website and minimizes blocking legitimate users.|
It may be placed on your visitors' devices to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare's security features.
Learn more about this cookie from Cloudflare.
|It is a session cookie that lasts a maximum of 30 days.|
|__cfruid||This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. Learn more about Cloudflare cookies.||It expires at the end of the session.|
|__hmpl||Collects information on user preferences and/or interaction with web-campaign content - This is used on CRM-campaign-platform used by website owners for promoting events or products.||Persistent|
|__ptq.gif||Sends data to the marketing platform Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.||It expires at the end of the session.|
|HUBLYTICS_EVENTS_53||Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement.||Persistent|
Consent banner cookies : HUBSPOT
|__hstc||The main cookie for tracking visitors.|
It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
|It expires in 13 months.|
|hubspotutk||This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.|
It contains an opaque GUID to represent the current visitor.
|It expires in 13 months.|
|__hssc||This cookie keeps track of sessions.|
This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.
It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
|It expires in 30 minutes.|
|__hssrc||Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser.|
If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
It contains the value "1" when present.
|It expires at the end of the session.|
Chatflow Cookie : HUBSPOT
|messagesUtk||This cookie is used to recognize visitors who chat with you via the chatflows tool. If the visitor leaves your site before they're added as a contact, they will have this cookie associated with their browser.|
If you chat with a visitor who later returns to your site in the same cookied browser, the chatflows tool will load their conversation history. The cookie is controlled by the Consent to collect chat cookies setting in your chatflow.
If this setting is disabled, the cookie is controlled by the Consent to process setting setting in your chatflow.
It contains an opaque GUID to represent the current chat user.
|It expires in 13 months.|
Chatflow cookie consent text: HUBSPOT
With the Consent to collect chat cookies setting enabled, HubSpot will prompt visitors for consent to drop a cookie in their browser when they open a chat on your website. This cookie is used to interact with website visitors and provide a visitor's chat history. If a visitor does not give consent, they will not be able to start the chat. With this setting disabled, a visitor can start a chat and give consent to process their information via the Consent to process setting.
Visitors can also accept or decline cookies on the HubSpot cookie banner if it is enabled on your pages.
You can find a list of other cookies we use and the purposes for which we use them in the tables below.
First party cookies
|rc::a||This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.||Persistent|
|rc::b||This cookie is used to distinguish between humans and bots.||It expires at the end of the session.|
|rc::c||This cookie is used to distinguish between humans and bots.||It expires at the end of the session.|
|rc::d-15#||This cookie is used to distinguish between humans and bots.||Persistent|
|JSESSIONID||Preserves users states across page requests.||It expires at the end of the session.|
|CookieConsent||Stores the user's cookie consent state for the current domain||It expires in 1 year.|
|wordpress_test_cookie||Used to check if the user's browser supports cookies.||It expires at the end of the session.|
|collect||Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels.||It expires at the end of the session.|
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||It expires in 2 years.|
|_gat||Used by Google Analytics to throttle request rate||It expires in 1 day.|
|_gid||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||It expires in 1 day.|
|mbed/v3/counters.gif||Collects information on user preferences and/or interaction with web-campaign content - This is used on CRM-campaign-platform used by website owners for promoting events or products.||It expires at the end of the session.|
|NID||Registers a unique ID that identifies a returning user's device. The ID is used for targeted ads.||It expires in 6 months.|
|__hssc||Collects statistical data related to the user's website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website's users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising.||It expires in 1 day.|
Thrid Party cookies
|IDE||cookie file connected with ads used on non-Google websites||360 days|
|__cfduid||Used by the content network, Cloudflare, to identify trusted web traffic.||1 year|
You should also be aware that there are cookies which are found in other companies’ internet tools which we may use to enhance the website. You may see ‘social buttons’ during your use of the website, including but not limited to Twitter and Facebook, which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.Third party cookies
We may contact you:
As a data subject, you have the following rights under Data Protection Legislation and we, as Data Controller in respect of Your Data, will comply with such rights in respect of Your Data:
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see ‘How To Contact Us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right of access to Personal Data relating to you
You may ask to see what Personal Data we hold about you and be provided with:
Requests for your Personal Data must be made to us (see ‘How To Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service and our website. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your Personal Data or correct any mistakes in your Personal Data
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How To Contact Us’ below).
Right to ask us to stop contacting you with direct marketing
We have a legitimate interest in sending you electronic communications/direct marketing in connection with the Service and related matters (which may include but shall not be limited to newsletters, announcement of new features etc). We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.
Rights in relation to automated decision taking (if applicable)
You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.
Right to restrict or prevent processing of Personal Data
In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:
If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
Right to erasure
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ below) to erase your Personal Data where:
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest to do so (e.g. retaining evidence of billing information etc.). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
We restrict access to personal information to employees, contractors, partners and agents who need to know that information in order to operate, develop, or improve our Service/website. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.
If Your Data contains any material which may reasonably be deemed to be offensive, inappropriate or objectionable or otherwise engage in any disruptive behaviour in relation to the Service, we may remove such content and/or suspend the use of Your Account.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Your Data to employees, contractors and agents who need to know Your Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of any data transmitted us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Data arising from such risks.
We will notify serious data breaches in respect of Your Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
Your Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Data as necessary to administer Your Account, comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Service.
Where we retain information for Service/website improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service/website, not to specifically analyze personal characteristics about you.
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to [email protected]