Our Privacy policy

• 1.1 You may provide us with your personal information voluntarily. However, we may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, planning authorities, public websites and public agencies, which we refer to as “third-party sources” or “suppliers” throughout this policy. We may also collect personal information from you using a variety of technologies that automatically and passively collect information when you use our website (usage data).
• 1.2 You may give us personal information by completing forms on our website, paper order forms, registering for an account, when enquiring about or ordering broadband services from us, entering a competition, completing customer satisfaction surveys or otherwise providing feedback on the services received (including via social media channels such as Facebook or Twitter), or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.

2.1 Visitors to our website

What personal information we collect about you

• your name
• your postal address
• your email address
• your telephone number
• information provided when you correspond with us
• any updates to information provided to us
• personal information we collect about you or that we obtain from our third-party sources
• the following information created and recorded automatically when you visit our website

1. Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address or other unique identifier for the computer or other electronic device that you use to access the website; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system and platform; and
2. Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.

How we use your personal information

• to allow you to access and use our website
• to receive enquiries from you through the website about our broadband services
• to ensure that content from our website is presented in the most effective manner for you and for your computer or other electronic device
• to understand how you access and use our website
• to understand you better and tailor our website content and services to your needs and interests
• to allow you to take part in interactive features we may provide from time to time
• to administer and improve our website and broadband services, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our
• webpages
• to give you an overall better user experience on our website.

A word about cookies

2.2 Customers

What personal information we collect about you

• your name
• your postal address
• your email address
• your telephone number
• your age
• your gender
• information provided when you correspond with us
• any updates to information provided to us
• information about the current broadband providers you use
• information you provide to help us provide you with improved broadband services, for example if we ask you to fill in a survey or questionnaire
• information about your preferences
• your payment details
• information about broadband services and equipment we provide to you:
  1. information needed to provide the broadband services and equipment to you (including information on completed forms, order details, information about your property or access to your property, order history and payment details)
  2. customer services information and
  3. customer relationship management and marketing information;

How we use your personal information

• to provide you with our broadband services and related equipment, including installation of equipment
• to carry out our obligations under any contracts we have entered into with you
• to deal with any enquiries or issues you have about our broadband services or equipment
• to ensure that content from the broadband services is presented in the most effective way for you and your computer or other electronic device
• to provide support for any faults in our broadband services
• to send you certain communications (including by email or post) about our broadband services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges)
• quality assurance of our broadband services
• to carry out statistical analysis and market research on people who may be interested in our broadband services; and
• if you have consented or, otherwise, if it is in our legitimate interests, for marketing purposes, to contact you (including by email or post) with information about our broadband services and related equipment which either you request, or which we feel will be of interest to you (including newsletters).

Special categories of data

Information we need to provide services to you

2.3 Prospective customers who we send marketing communications to

We, or third parties on our behalf, may collect and use any of the following information about you:

• your name
• your postal address
• your email address
• your telephone number
• information about your preferences
• your property type
• how you heard about us and
• your building management contact details.

How we use your personal information

We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for marketing purposes, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you.

Please see sections 2.7 and 2.8 for more details about how we use your personal information.

2.4 People who contact us with enquiries or that we contact in relation to fiber broadband installation works

We, or third parties on our behalf, may collect and use any of the following information about you:

• your name
• your postal address
• your email address
• your telephone number
• information provided when you correspond with us
• any updates to information provided to us

How we use your personal information

We will collect, use and store the personal information listed above to: (a) deal with any enquiries or issues you have about our business, broadband services or works to install new fiber broadband,including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you; and to obtain and share information we need to carry out installation works for new fibre broadband. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes, for the carrying on our business or to meet our customer and future customer demand for fibre broadband.

Please see sections 2.7 and 2.8 for more details about how we use your personal information.

2.5 Our suppliers and employees of our suppliers and other third parties who work for or with us

We, or third parties on our behalf, may collect and use any of the following information about you:

• your name
• work contact information (phone number and email address)
• your job title
• your gender
• your date of birth
• your emergency contact information
• information provided when you correspond with us
• any updates to information provided to us
• personal information we collect about you from third-party sources such as LinkedIn
• work place accident information
• company name
• office address
• CVs, pitch and tender information
• proof of identification and address
• visa or work permit documentation
• details of compensation, expense claims and bank details
• information required to access company systems and applications (such as system ID)
• work hours (overtime and hours worked)
• if you attend our sites, CCTV recordings

How we use your personal information

We will collect, use and store the personal information listed above for general communication between us, including the following:

• to enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and financial audits)
• to assess your working capacity
• to confirm information on CVs and performance reference checks, to assess you or your employer’s suitability to work for us
• for equal opportunities monitoring
• for health and safety records and management
• to contact your next of kin in an emergency
• for security vetting and criminal records checks (where applicable and allowed by law)
• for CCTV monitoring and other security of company facilities

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

Source of personal information.

We may receive some of your personal information from third-party sources, such as your employer or your employer’s company website. We may also collect this personal information from publicly available sources, such as LinkedIn.

Special categories of data.

Some of the personal information that we collect about you or which you provide to us about you or your employees may be special categories of data. Special categories of data include information about your physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

Information we need to provide services to you.

Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer ask us to delete it, you may no longer be able to provide services to us.

Use of your family and next of kin information

Separately, we may process personal information about your family and next of kin so that we may contact them in an emergency. We will only process your or your family/next of kin’s personal information for this specific purpose or for any other purposes specifically permitted by law.

2.6 Job applicants

We, or third parties on our behalf, may collect and use any of the following information about you:

• to facilitate any application you make to us, including inviting you to and conducting interviews
• if you have asked us to keep you informed of other opportunities at with us, we may periodically
• contact you to tell you about these for up to 6 months
• to respond to your queries and requests
• to communicate with you
• to provide you with updates about your application
• to confirm information on CVs and performance reference checks, to assess your suitability to work for us
• for equal opportunities monitoring
• for security vetting and criminal records checks (where applicable and allowed by law)
• for CCTV monitoring and other security of company facilities

Source of personal information

We may receive some of your personal information from third-party sources, such as your employer,your employer’s company website or a recruitment agency. We may also collect personal information from publicly-available sources, such as LinkedIn.

Special categories of data

Some of the personal information that we collect about you or which you provide to us about you may be special categories of data. Special categories of data include information about your physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

2.7 Other reasons we may store your personal information

Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

• to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests
• for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so
• to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so
• to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.8 Further processing

We will not use your personal information in any way that is incompatible with the purposes set out in this section 2. Please contact us using the details in section 13 if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

2.9 Aggregated and anonymous information

We may use your personal information and combine it with the personal information of others to identify trends and share or provide this trend information in an aggregated and anonymous form with third parties. For example, we may use information about your browsing habits as part of an aggregated number to identify which are our most popular website pages.

3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

• our use of your personal information is necessary to perform our obligations under any contract with you (for example, to sell and provide you with broadband services and related equipment, to fulfil an order which you place with us, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or
• our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
• where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
  1. run, grow and develop our business
  2. appropriately skilled and qualified suppliers
  3. marketing, market research and business development
  4. provide broadband services to our customers, make and receive payment and provide customer services
  5. invest in and roll out fibre broadband to benefit the communities in which we operate
  6. place, track and ensure fulfilment of orders with our suppliers
  7. for internal group administrative purposes.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

3.2 We may use your special categories of data (such as health information) where you have provided your consent (which you may withdraw at any time after giving it, as described below).

3.3 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

3.4 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at info@cre8hub.co.uk and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide broadband services to you.

4.1 We will share your personal information with the following third parties or categories of third parties:

• our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of broadband services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance)
• our partners and joint venture partners (“Partners”), where we provide the broadband service or our website to you as part of a partnership or joint venture. Our Partners will process your information in accordance with their privacy policy and it is your responsibility to read our Partner’s privacy policies;
• our service providers and sub-contractors, including but not limited to payment processors, utility providers, suppliers of technical and support services, insurers, and cloud service providers, for example Amazon Web Services
• public agencies and the emergency services
• companies that assist us in our marketing, advertising and promotional activities
• analytics and search engine providers that assist us in the improvement and optimisation of our website.

4.2 Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.3 We will also disclose your personal information to third parties:

• where it is in our legitimate interests to do so to run, grow and develop our business:

6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at info@cre8hub.co.uk at any time. You have the following rights:

Right of access.

You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area (“EEA”).

Right to update your information.

You have a right to request an update to any of your personal information which is out of date or incorrect.

Right to delete your information

You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 13.

Right to restrict use of your information

You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contract details in section 13.

Right to stop marketing

You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

Right to data portability

You have a right to ask us to provide your personal information to a third-party provider of services.

Right to object

You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

6.3 If an exception applies, we will tell you this when responding to your request. We may request you to provide us with information necessary to confirm your identity before responding to any request you make.

7.1 You must be aged 18 or over to purchase broadband services from us. Our website and broadband services are not directed at children and we do not knowingly collect any personal information from children.

7.2 If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

7.3 Please contact us at info@cre8hub.co.uk you are aware that we may have inadvertently collected personal information from a child.

8.1 We may collect and use your personal information for undertaking marketing by email telephone and post.

8.2 We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing purposes.

8.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third-party for such marketing.

8.4 If you wish to stop receiving marketing communications, you can contact us by email at info@cre8hub.co.uk.

The Website and Services may contain hyperlinks to and from the websites of our partner networks advertisers and affiliates or other third parties.Any hyperlinks we provide are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third-party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties.Third-party websites have their own terms and conditions and privacy policies, and you should readthese carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.

13.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact info@cre8hub.co.uk. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

13.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.