“HUB Group”, “us”, “we” or “our” means one or more of the applicable companies set out in the “Important Information” section of the Website which are collectively referred to as HUB Group. HUB Group is a trading name used collectively by those companies. HUB Group companies are all part of the Just Group of companies. For more information on Just Group please visit the website at www.wearejust.co.uk or www.justgroupplc.co.uk
HUB Group takes all reasonable care to prevent any unauthorised access to your personal data.
HUB Financial Solutions Limited is authorised and regulated by the Financial Conduct Authority. It is registered with the Information Commissioner’s Office with number Z964954X. HUB Pension Consulting Limited is an appointed representative of HUB Financial Solutions Limited. It is registered with the Information Commissioner’s Office with number Z339065X. TOMAS Online Development Limited (trading as HUB Digital Solutions) is registered with the Information Commissioner’s Office with number ZA789809.
We respect the privacy of every individual who visits our website and have developed this policy because we want you to feel confident about the privacy and security of your personal information.
Personal information means any information about you which is personally identifiable, including your name, age, address, telephone number, email address, financial details, and any other information from which you can be identified.
It also includes genetic and biometric data, location data and online identifiers which may identify you, such as your internet protocol (IP) address (the unique personal address which identifies your device on the internet) and mobile device IDs.
What types of personal information do we collect from you?
We collect the following information about you and any dependants (this includes a person to whom you have granted a power of attorney) when you use any of our products or services and we may also collect personal information indirectly from our business partners, for example financial intermediaries:
We will process your personal information for legitimate business purposes or for the performance of a contract in order for us to provide the following:
HUB Group provides an extensive range of different products and services and may use the personal information you have provided (when applicable) to help identify and tailor products and services that may be of interest to you.
In order to:
We will seek to obtain your explicit consent where we are required to process any special categories of personal data (such as medical information).
In the event that we intend to process your personal data for new purposes requiring your consent, we will contact you to obtain your consent for such new purposes.
The personal information we hold about you may be shared with the following recipients subject to security, contractual and transfer adequacy safeguards as appropriate:
(a) our Group affiliates;
(b) our agents; and
(c) business partners/service providers who assist us in providing the services we offer through our website applications and third party comparison portal(s).
The following categories of agents, business partners and close affiliations assist us in the provision of ancillary services and only use your personal information to the extent necessary to perform their functions:
If you’re a HUB Financial Solutions customer: Where we have provided you with a service, we will keep your personal information for as long as is necessary for the purposes described in this policy (in line with the data minimisation principle) for a maximum period of 7 years after the service has expired, after which your personal information will be deleted or anonymised in compliance with our established data protection policy.
If you’re a HUB Pension Consulting customer: Any information that is received about you may be retained indefinitely once we have made a recommendation that relates to a defined benefit transfer. This type of advice requires information to be held for a longer term, due to the time period over which such advice can have an effect.
Anonymised personal information will not be considered as personal since no individual can be identified by that information. We use anonymised information for further actuarial and business analysis, business research and reporting to help us to develop our products and services.
Cookies may contain information about your general internet usage; the type of internet browser or mobile device in use; your IP address and operating system and how you have arrived on our web page.
We will only use this information to assist us in providing a more effective service and to collect broad demographic information for aggregate use and to help us to improve our website to deliver a better and more personalised service to:
(a) estimate our audience size and usage pattern;
(b) store information about your preferences, and allow us to customise our website according to your individual interests;
(c) speed up your searches; and
(d) recognise when you return to our Site.
When you visit our website, you can change your cookie preferences through your browser settings.
Monitoring our communications with you
We may monitor or record your calls and text messages and other communications, such as emails, in accordance with UK law, and in particular for business purposes such as:
(a) quality control;
(b) processing necessary for the entering into or the performance of a contract;
(c) to prevent unauthorised use of our telecommunications systems and web sites and/or services;
(d) to ensure effective systems operation;
(e) to meet our legal obligations;
(f) in your vital interests;
(g) to prevent or detect crime; and
(h) in relation to our legitimate interests.
We have security measures in place to protect against the loss, misuse and alteration of personal information under our control as required by current data protection laws and the EU General Data Protection Regulation 2016/679 ("GDPR").
For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information.
Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
Transfers of personal data outside of the EEA
Your personal data is sent to and stored on secure servers located in the UK or other countries within the European Economic Area (EEA).
If at any point we decide to use or disclose information we have collected in a manner different from that stated at the time it was collected, we will notify you.
Your rights to your personal information
You have options and choices over how we use your personal information. We may provide you with the tools to manage your account or to change your marketing communication preferences at any time.
We may retain a record of your stated objection to the processing of your personal information including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.
In terms of your rights, you can:
Requests for your personal information shall be provided free of charge. However, where requests are repetitive, or manifestly unfounded or excessive, we may charge you a reasonable fee to cover the administrative costs of providing the information, or may refuse to act on the request.
By email at: firstname.lastname@example.org
By telephone on: 01737 233288
By writing to us at: Data Protection Officer, Just Group plc, Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP
If you remain unhappy with a response you receive from us, you can also refer the matter to the Information Commissioner's Office.