Privacy Policy
Background
Hotkey Hub Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://hotkeyhubltd.com/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions & Interpretation
In this Policy the following terms shall have the following meanings:
- Data Protection Regulations means the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019, which incorporates the EU Regulation 2016/679 General Data Protection Regulation into UK law (“UK GDPR”).
- Personal data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data.
- We/Us/Our means Hotkey Hub Limited, a company registered in England under number 14808588, with a registered office at 113 Halliwell Road, Bolton, England, BL1 3NE.
- EU means the European Union.
- UK means the United Kingdom.
2. Information About Us
2.1 Our Site is owned and operated by us.
2.2 We are registered with the Information Commissioner’s Office under the Data Protection Act 2018. ICO Registration Number: ZB554979
2.3 Our Data Protection Officer can be contacted via admin@hotkeyhub.com
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and advise you to check their privacy policies before providing any data.
4. Your Rights
You have rights under the Data Protection Regulations, including:
- The right to be informed
- The right of access
- The right to rectification
- The right to be forgotten
- The right to restrict processing
- The right to data portability
- The right to object
- Rights related to automated decision making and profiling
- For more, contact us (see section 15) or the Information Commissioner’s Office.
5. What Data Do We Collect?
We may collect the following types of data:
- Full name, address, date of birth, gender, contact details
- Employment and financial information
- Browser and technical data (IP address, cookies, web history)
- Records of communications (calls, emails, etc.)
6. How Do We Use Your Data?
We use your data for:
- Providing and managing your account
- Personalising your experience
- Fulfilling legal and contractual obligations
- Marketing (with consent)
- Improving services via analytics
- Handling reviews (via platforms like Trustpilot)
7. Legitimate Interest
We may use your data under legitimate interests, such as:
- Security and fraud prevention
- Direct marketing
- Improving products and services
- Legal compliance
- You may object to this at any time.
8. How and Where Do We Store Your Data?
- Stored in the UK/EEA or securely outside with adequate protection
- Data transfers include encryption, secure protocols, contracts
- Retention depends on purpose, usually up to 6 years
9. Do We Share Your Data?
We may share your data with other companies for carrying out/putting in place the services or solution that you require.
We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising and marketing companies. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:
- FCA Authorised Firms
- CRM system
- Postal mailing services
- Emailing platform for sending email communications
- Hosting and server provider
- Campaign management platform
- Customer feedback and reviews platform
- Compliance consultant
We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We may sometimes use third party data processors that are located outside of the UK. Where We transfer any personal data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Regulations including:
Carrying out due diligence on prospective parties to which we wish to transfer the data to; Having in place written contracts on the transfer and use of the data (or using model contract clauses) that set out clearly the responsibilities of each party and the rights of data subjects; and/or; Transferring data in an encrypted form or using a secure file transfer protocol; Limiting the scope of the data transfer to a ‘need to know basis’s only.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
We may with your consent, or where it in our legitimate interest, also share some or all of your personal information with the following organisations:
- Our Technology Service Provider
- Our Third-Party Marketing Partners
- A third party acting on your behalf, such as a financial or legal adviser
We may share your data with regulators and disputes resolution bodies such as:
- The Financial Conduct Authority
- The Information Commissioner Office
- The Financial Ombudsman Service
- Advertising Standards Authority
- Local Trading Standards
We use the services of Facebook Ireland Limited (Facebook) to carry out certain marketing activities on the Facebook Platform. Specifically, from time to time we use Facebook’s Audience Insights to help us to create targeted audiences for our advertising campaigns on Facebook. This involves sharing some of our customer personal data with Facebook to allow it to create for us information on the types of audiences (i.e. potential customers) on Facebook platform that would be best suited to see our adverts. In this respect Facebook acts as our joint processor.
For such processing of your personal data we and Facebook also act as a ‘Joint Controller’ this means that both Facebook and us can determine the reasons for processing of your personal data. Facebook has its own privacy policy on how Facebook processes personal data, including the legal basis which Facebook relies on and the ways to exercise Data Subject rights against Facebook. To review Facebook’s privacy policy, you can visit: https://www.facebook.com/ about/privacy. You can also obtain full contact details of Facebook or its representative and the details of its Data Protection Officer from this policy.
In order to ensure the rights of data subjects (i.e. you) we have entered into a Controller Addendum with Facebook that sets outs each parties’ respective responsibilities in terms of this processing and our responsibility to inform you of the details in this section 9.10.
Any data subject requests with regard to the Personal Data stored by Facebook Ireland after the Joint Processing described in paragraph one of this section is the responsibility of Facebook.
10. Business Transfers
If our business changes hands, your data may be transferred to the new owner under the same privacy terms.
11. Controlling Your Data
You can:
- Opt out of marketing
- Use TPS/MPS/CTPS preference services
- Control cookie usage (see section 14)
12. Withholding Information
You may access our site without providing personal data.
13. Accessing Your Data
You may request a copy of your data from us at no cost. Email: admin@hotkeyhub.com
14. Use of Cookies
We only use strictly necessary cookies for website functionality. No tracking, analytics, or marketing cookies are used.
15. Contact Us
- Email: admin@hotkeyhub.com
- Post: Hotkey Hub Limited, 113 Halliwell Road, Bolton, England, BL1 3NE
16. Changes to This Policy
We may update this Privacy Policy from time to time. Updates will be posted on Our Site. Check this page regularly.