Introduction
HeadBox respects your privacy and is 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 set up an account or subscribe to marketing). 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.
This Privacy Policy forms part of and is incorporated into all terms and conditions for HeadBox products and services.
Important information and who we are
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.
Controller
HeadBox Solutions Limited is the controller and responsible for your personal data (collectively referred to as "HeadBox", "we", "us" or "our" in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Where your personal data is shared with a venue in connection with an enquiry or potential booking, the relevant venue will be a separate controller of your personal data and solely responsible for determining how they use and process your personal data. Please read the privacy notice of the relevant venue and contact them directly if you have any questions regarding how they treat your personal data.
Contact details
If you have any questions about this privacy notice or our privacy practices generally, please contact us:
By email: DPO@headbox.com.
By post: DPO, HeadBox Solutions Limited, 3RD FLOOR, Unit 3.01, 35 Luke St, London EC2A 4LH
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.
Changes to the privacy notice and your duty to inform us of changes
We may change this Privacy Policy from time to time so please check our website for the latest version.
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.
Third-party links
Our website and platforms may contain third party plug-ins, applications or links to third party websites. HeadBox does not have any control over such third party websites, plug-ins or applications and 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.
The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Where you use HeadBox services as a business user, Identity Data may also include your occupation, job title and details of your employer or business you work for. In certain circumstances, Identity Data may also include your image, voice and likeness (for example, if an avatar is created based on your likeness pursuant to a HeadBox 3D Studio agreement).
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details, as well as information about payments to and from you including any failed payments.
Transaction Data includes details about products and services you have received from us or have subscribed to.
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 HeadBox platforms. When you use certain features of our websites or platforms, 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.
Profile Data includes your username and password, purchases or orders made by you, your interests, enquiries submitted, preferences, bookings made and feedback responses.
Usage Data includes information about how you use our website, platforms, products and services.
Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
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.
If you fail to provide personal data
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 platforms). In this case, we may have to cancel a product or service you have requested or booking you have made through a HeadBox platform but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms, creating an account to access our platforms, using our platforms 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.
Collected from our clients. Where you work for are engaged by a business client (for example, where you are named as an authorised user or if an avatar is created based on your likeness pursuant to a HeadBox 3D Studio agreement).
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. Please see our cookie policy for further details. 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.
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.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
analytics providers such as Google based outside the EU;
advertising networks such as Google Adwords based inside and outside the EU; and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly availably sources such as Companies House.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HeadBox or our business partners;
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
where we need to perform the contract we are about to enter into or have entered into with you; and
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
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.
How HeadBox Uses and Processes User Communications
We may review, scan, or analyse your communications with other users for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, we may scan and analyse messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking users to send them money outside of HeadBox platforms, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings.
We will use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using our website, platforms or products, you consent that HeadBox, in its sole discretion, may review, scan, analyse, and store your communications, whether done manually or through automated means.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.
Purposes for which we will use your personal data
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.
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 enable you to access and use the HeadBox website, platforms, products and services |
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Performance of a contract with you |
To process and deliver your subscriptions, orders and bookings including:
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To manage our relationship including:
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| To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HeadBox or our business partners. |
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| To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HeadBox or our business partners (including venues) |
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| To help create and maintain a trusted and safer environment on our website and platforms, such as fraud detection and prevention, conducting investigations and risk assessments, verifying venue listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases |
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| To operate, protect, improve and optimize our website, platforms, products and services, HeadBox's business, and our users' experience, such as to perform analytics, conduct research, and for advertising and marketing |
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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 use data analytics to improve our website, platforms, products and services, marketing, customer relationships and experiences |
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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 send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you |
|
Necessary for our legitimate interests (customer management and to develop our products/services and grow our business) |
| To create bespoke avatars pursuant to the HeadBox 3D Studio terms and conditions |
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Performance of a contract |
Marketing
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.
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).
We do not sell your personal data to any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving marketing messages, this will not apply to any personal data provided to us in connection with your subscription or communications relating to enquiries and potential bookings.
Change of purpose
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.
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.
Disclosures of your personal data
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:
If you are a guest, parts of your public profile page that contain personal data may be displayed in other parts of the website or platforms to other users.
The public listing page for a venue will include some minimum information such as the city and neighbourhood where the venue is located (including a map of the location), any public profile photo provided by you and venue responsiveness in replying to guest queries. Parts of a venue listing page may be displayed in other parts of the website or platforms to other users.
Public profiles and public venue listing pages are indexed by third party search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the HeadBox platform. Please note that the relevant third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or any information on public profile or venue listing pages.
If you are a guest, your full name will be visible to the relevant venue when you submit a request to book a venue. We will not share your phone number unless there is a confirmed booking.
When a booking request is accepted by the relevant venue, we will disclose such Personal Data as relevant for the booking (for example, relevant Identity Data and Contact Data). However, your billing information will never be shared with another user.
Any reviews you provide (together with your username) may be made public on the HeadBox website.
You may link your account on a third party social networking site to your HeadBox account. We refer to a person's contacts on these third party sites as “Friends”. When you create this linkage:
some of the information you provide to us from the linking of your accounts may be published on your HeadBox account profile;
your activities on HeadBox platforms may be displayed to your Friends on our website and/or that third party site;
other HeadBox users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other HeadBox users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s); and
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.
The publication and display of information that you provide to HeadBox through this linkage is subject to your settings and authorizations on your HeadBox account and the relevant third party site.
We may distribute parts of the website (including venue listings) for display on sites operated by HeadBox's business partners, using technologies such as HTML widgets. Where a venue listing is displayed on a partner's site, information from the venue's profile page may also be displayed, including any personal data on such profile.
We may allow our related entities such as our subsidiaries, 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 also engage third party companies and individuals, who may be located outside of the EEA, to provide services to us, including services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed). We may provide personal data about you to these third parties, or give them access to this personal data, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this personal data and to not use it for unrelated purposes.
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.
Professional advisers acting as processors including lawyers, bankers, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
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.
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.
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.
International transfers
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.
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.
Data security
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.
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.
Data retention
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.
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.
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.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
For further details on the retention of your personal data, please see our data retention policy.
Your legal rights
Under data protection laws you have the right to:
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.
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.
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.
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.
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.
Request the transfer of your personal data to you or to a third party.
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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.