Privacy Policy
1. Introduction
1.1 Here at Hastel, we respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we collect and use your personal data, including when you visit our website (regardless of where you visit it from) or use our services or when you contact us or engage with us (for example, when you request a quote or set up an account). In this privacy notice we also explain how we protect your personal data and tell you about your privacy rights and how the law protects you.
1.2 This privacy notice forms part of and is incorporated into all terms and conditions for Hastel products and services.
2. Important information and who we are
2.1 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice is supplementary to and does not override any other notice.
3. Controller
3.1 Hastel Limited is the controller and responsible for your personal data (referred to as "Hastel", "we", "us" or "our" in this privacy notice).
4. Contact Details
4.1 If you have any questions about this privacy notice or our privacy practices generally, please contact us:
(a) By email: info@hastel.co.uk
(b) By post: Attention: The Data Protection Officer, Hastel Limited, LDH House, St. Ives Business Park, Parsons Green, St. Ives, Cambridgeshire PE27 4AA
4.2 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
5. Changes to the privacy notice and your duty to inform us of changes
5.1 We may change this Privacy Policy from time to time so please check our website for the latest version.
5.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
6. Third-party links
6.1 Our website and platforms may contain third party plug-ins, applications or links to third party websites. Hastel does not have any control over such third party websites, plug-ins or applications and we are not responsible for their privacy statements. These third parties may place their own cookies, web beacons or other files on your device, or collect and share personal data about you. They will have their own rules about the collection, use and disclosure of personal data. We encourage you to read the terms of use and privacy policies of the other websites that you visit and any applications or plug-ins you use.
7. The data we collect about you
7.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
7.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
(a) Identity Data includes first name, last name, maiden name or other previous name(s), username or similar identifier, marital status, title, date of birth and gender. Where you use Hastel services as a business user, Identity Data may also include your occupation, job title and details of your employer or business you work for.
(b) Contact Data includes billing address, delivery address, email address and telephone numbers.
(c) Financial Data includes bank account and payment card details, as well as information about payments to and from you including any failed payments.
(d) Transaction Data includes details about products and services you have requested from us or have subscribed to.
(e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and the Hastel platform. When you use certain features of our website or platform, we may receive, store and process different types of information about your location, including general information (e.g., IP address) and more specific information (e.g. GPS-based functionality on mobile devices used to access the website or platforms). If you access our website or platforms through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
(f) Profile Data includes your username and password, quotes requested, purchases or orders made by you, enquiries submitted, your preferences, feedback responses and other communication with you.
(g) Usage Data includes information about how you use our website, platform, products and services.
(h) Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
7.4 Special Category Data is personal data that is considered as likely to be more sensitive and requiring extra protection. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not seek to collect Special Category Data, nor do we collect any information about criminal convictions and offences.
8. If you fail to provide personal data
8.1 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or access to our platform). In this case, we may have to cancel a product or service you have requested but we will notify you if this is the case at the time.
9. How is your personal data collected?
9.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your personal data by filling in forms, creating an account to access our platform, using our platform and services, subscribing to our services or publications or receiving marketing from us, giving us feedback or by corresponding with us by post, phone, email or otherwise.
(b) Collected from our client, where you work for or are engaged by a business client (for example, where you are named by a business client as an authorised user of the client’s account).
(c) Automated technologies or interactions. As you interact with our website, platforms and services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may also receive, store and process the date and time you access or use our website or platforms, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
(d) Third-party social plugins. Our website or platforms may use social plugins that are provided and operated by third-party companies, such as Facebook’s Like Button. As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our website or platforms. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our website to your account with them. Similarly, a third party may record your interactions with the social plugin. Please refer to the third party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.
(e) Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
9.2 Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Google Adwords based inside and outside the EU; and
(c) search information providers.
9.3 Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
9.4 Identity and Contact Data from publicly availably sources such as Companies House.
10. How we use your personal data
10.1 We will only use your personal data when the law allows us to. The law requires us to have a legal basis for collecting and using your personal data. Most commonly, we rely on one or more of the following legal bases:
(a) performance of a contract - where we need to use your personal data to perform the contract we are about to enter into or have entered into with you;
(b) legitimate interests - where use of your personal data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
(c) compliance with legal obligation – where we need to use your personal data to comply with our legal obligations.
10.2 See below to find out more about the types of lawful basis that we will rely on to process your personal data.
10.3 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
11. Purposes for which we will use your personal data
11.1 We set out below a description of the ways we use your personal data, and which of the legal bases we rely on. We have also identified our legitimate interests where appropriate.
11.2 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you. | a. Identity b. Contact c. Technical d. Usage e. Profile | Performance of a contract with you. |
To use data analytics to improve our website, platform, products and services, marketing, customer relationships and experiences. | a. Technical b. Usage | a. Performance of a contract with you. b. Necessary for our legitimate interests (account management). |
To operate, protect, improve and optimize our website, platform, products and services, Hastel’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing. | a. Identity b. Contact c. Profile d. Usage e. Marketing f. Technical | a. Performance of a contract with you. b. Necessary to comply with a legal obligation. c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). |
To help create and maintain a trusted and safer environment on our website and platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying identification provided by you, and conducting checks against databases such as public government databases. | a. Identity b. Contact c. Profile d. Technical | a. Performance of a contract with you. b. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business). |
To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Hastel or our business partners. | a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications | a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). b. Necessary to comply with a legal obligation. |
To manage our relationship including: a. notifying you about changes to our services, terms or privacy policy. b. asking you to leave a review or take a survey or provide feedback. | a. Identity b. Contact c. Profile d. Marketing and Communications | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). |
To enable you to access and use the Hastel website, platform, products and services. | a. Identity b. Contact | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and platforms updated and relevant, to develop our business and to inform our marketing strategy). |
To process and deliver your orders including: a. managing payments, fees and charges. b. collecting and recovering money owed. | a. Identity b. Contact c. Financial d. Marketing | Necessary for our legitimate interests (customer management and to develop our products/services and grow our business). |
12. Marketing
12.1 You will receive marketing communications from us if you have requested information from us or have an account with us and, in each case, you have not opted out of receiving that marketing.
12.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on which products, services and offers may be relevant to you or of interest to you (we call this profiling).
12.3 We do not sell your personal data to any third party for marketing purposes.
13. Opting out
13.1 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us directly.
13.2 Where you opt out of receiving marketing messages, you will still receive communications relating to enquiries you submit or orders for goods or services placed through the Hastel platform.
14. Change of purpose
14.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
14.2 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
15. Disclosures of your personal data
15.1 We may share your personal data with the parties set out below for the purposes set out in the table under the paragraph headed Purposes for which we will use your personal data:
(a) Any reviews you provide, together with your username, may be made public on the Hastel website.
(b) We may allow our related entities such as our Group companies, and their employees, to use and process your personal data in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your personal data under this Privacy Policy.We may allow our related entities such as our Group companies, and their employees, to use and process your personal data in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your personal data under this Privacy Policy.
(c) Service providers acting as processors who support our business in a variety of ways including provision IT and system administration services, hosting services, banking and payment services.
(d) Professional advisers acting as processors including lawyers, bankers, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(e) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(f) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
15.2 We use certain subprocessors in the general running of our business and to assist us in providing our services to our clients. A subprocessor is a third party service provider or data processor engaged by us, who has, or potentially will have, access to or process personal data. We engage different types of subprocessors to perform various functions, as explained in the table below.
Sub-processor | What data is shared? |
|---|---|
Amazon Web Services (AWS) (EU) Cloud Service Provider. | Customer content: application data, databases, documents, files, backups, and any information uploaded by you or your users. System & operational data: virtual machine images, configuration files, logs, metrics, monitoring data. Network data: traffic metadata, IP addresses, routing information, API requests/responses. Backups & disaster recovery data: replicas of customer data for availability and resilience. |
Google (US) Google Analytics is used to analyse how customers use our website and guide improvements to our service. | Device & technical data: browser, OS, device type, screen size, IP (anonymizable), language. Usage data: page views, session duration, clicks, scrolls, referrers, UTM tags |
New Relic (EU) Cloud service monitoring software. | Application performance data: response times, error rates, transaction traces, service dependencies. System & infrastructure metrics: CPU, memory, disk usage, server health, container metrics. Logs & events: application logs, error messages, debug information (may include snippets of request data if logged). Network data: request/response metadata, throughput, latency, service calls. User interaction metadata (if instrumented): page load times, JavaScript errors, click paths, browser type/OS. Potential incidental personal data: e.g. IP addresses or request parameters included in logs/traces, depending on configuration. |
Databarracks (UK) Manages our cloud infrastructure. | Customer applicatin data such as personal data stored in our databases, file storage or apps Logs and monitoring data such as application logs and error traces. User identifiers such as IP addresses, session IDS or other identifiers that might appear in logs. |
AIR IT (UK) Managed Service Provider for Boilerjuice/Hastel. | By virtue of providing a backup service: |
Twilio (US) Communication technology provider for SMS product notifications. | Personal identifiers such as phone numbers. |
Boilerjuice (EU) We may share data with Boilerjuice, our sister compay from time to time to help diagnose issues, or improve service levels. We will only share details of Boilerjuice customers. | Device & technical data relating to the fuel monitor and fuel tank Location data. |
APC (UK) Fulfilment house. | Identification data e.g. Full name of recipient. |
WorldOptions (EU) Fulfilment house. | Identification data e.g. Full name of recipient. |
15.3 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
16. International transfers
16.1 Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside of the UK.
16.2 Where we transfer your personal data out of the UK, we do so under the terms of a contract with the external third party, and take steps to address that a similar degree of protection is afforded to your personal data, such as ensuring that the country where the personal data will be transferred has been deemed to provide an adequate level of protection for personal data, or by entering into specific contracts approved for use in the UK to give personal data the same protection it has in the UK.
17. Data security
17.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
17.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
18. Data retention
18.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
18.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
18.3 By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
18.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
18.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
19. Data retention
19.1 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
20. Your legal rights
20.1 Under data protection laws you have the right to:
(a) Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want to establish its accuracy or the reason for processing it.
(f) Request the transfer of your personal data to you or to a third party.
(g) Withdraw consent at any time in the limited circumstances where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing conducted before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
20.2 If you wish to exercise any of the rights set out above, please contact us.
21. No fee usually required
21.1 Generally, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
22. What we may need from you
22.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to assist us in responding.
23. Time limit to respond
23.1 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.