At Sub35, maintaining your privacy is important to us and we take precautions to safeguard your information. After all your relationship with us is built on trust and our goal is to preserve that trust. This policy applies where we are acting as a data controller with respect to your information; in other words, where we determine the purpose and means of the processing of that information. This policy sets out the basis on which your information is collected, stored and used by us.

1. Who we are and how to contact us

This is the Privacy Policy of Sub35 (also referred to throughout this policy as ‘we’, ‘us’, or ‘our’). By Sub35 we mean Sub35 www.subthirtyfive.com powered by www.hub.tv and its subsidiaries. Sub35 collects and uses information in the ordinary course of business and is therefore responsible for ensuring that it uses that information in compliance with all applicable data protection laws. This Privacy Policy governs the handling of your information by Sub35. This Privacy Policy explains how your information may be held and used by companies within Sub35. Note that information may be shared between Sub35 and Hub Productions Limited.

If you have any questions or concerns regarding our Privacy Policy, or how we process your information, please contact us via email at info@subthirtyfive.com.

2. Information we collect

By “information” we mean all of the personal and financial information about you that we collect, use, share and store. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing information to us when becoming a client of ours.

Information we collect from you when you visit and/or request to receive information from our website (by way of a non-exhaustive list):

Personal contact information (e.g. first name, family name, company name, company email address); and

How you access and use our website or other digital services (e.g. your IP address, your location, the device and software being used, pages visited, content viewed, links and buttons clicked through).

Information that we collect or generate about you includes (by way of a non-exhaustive list):

The Sub35 services or products which you have engaged with and our interactions with you; and

your visits to Sub35 websites including information collected through cookies and tokens that store technical information about the services that you use and how you use them. For more information on the cookies used by Sub35 please see our Cookie Policy below.

If you are looking to become a member of Sub35, or are already a member, in addition to the above, we may also collect or generate additional information about you. This includes (by way of a non-exhaustive list):

There may be some instances where we receive information about you from a third party. This includes (by way of a non-exhaustive list):

• Information received via a third party to join Sub 35;
• Background checks including information from social media; and
• Events which you registered for and/or attended run by Sub 35.

In addition to the categories of information described above, Sub 35 will also process further anonymised information and data that is not processed by reference to a specific individual. Your information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports which may be shared within Sub35.

3. How and why we use your information

We process your information to the extent necessary for us to carry out marketing and events, provide communications to you, meet our regulatory obligations and for other legitimate purposes permitted by applicable law. Your information may be stored and processed by us in the following ways and for the following purposes (by way of a non-exhaustive list):

• opening of accounts, administering and managing your account(s) (as applicable), updating your records and tracing your whereabouts to contact you about your account;
• understanding your needs and interests;
• allowing you to use and access the functionality provided by our website services;
• where you are an event delegate, to put you on our news and event email list and send marketing emails to you (unless you choose to opt out);
• communicating with you, where you have requested or consented, regarding any product or service or any other situation where you have engaged us to provide you with information;
• recording of incoming and outgoing calls for training, monitoring, and security purposes;
• notifying you about any change to your account, and/or to contact you about and enable you to exercise any rights in relation to your account;
• investigating any complaint, dispute and/or any concerns relating to your account and or activity on your account;
• maintaining a register of members;
• reviewing and improving the performance of our website and your use of it (including any personalisation which you may have indicated and which we have retained using cookies (refer to our Cookie Policy below for additional information));
• managing and administering our business;
• complying and assessing compliance with applicable law, rules and regulations and internal policies and procedures;
• administering and maintaining databases that store information;
• for some of our profiling and other automated decision making;
• anonymisation that enables us to undertake market research, analysis and developing statistics from information that is not referenced to a specific individual;
• for marketing communications (where it is lawful for us to do so and where you have not objected to the use of your information for these purposes);
• to deal with requests from you to exercise your rights under data protection laws.

Whenever we use information, we make sure that the usage complies with all applicable laws. Data protection laws require us to have one or more of the following reasons:

• ‘Contract performance’ – the information needed to deliver your account, product or service (e.g. we’ll need to hold your transaction history to give you an account statement).
• ‘Legal obligation’ – we are required by law to process your information (e.g. to verify your identity).
• ‘Legitimate interest’- we’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights (e.g. we have an interest in knowing what our members do and don’t like so we can offer better products and services).
• ‘Consent’- in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained (Whenever ‘consent’ is the only reason for us using the information you have the right to change your mind and change or withdraw your consent).

4. Sharing of your information

We may share your information within Sub35 for the purposes described above. All of our employees and contractors are required to follow our data privacy and security policies when handling information.

We may also share your information outside of Sub35 under the following circumstances.

Legal obligations: we share information: (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes (including fraud protection); (ii) in connection with any legal proceedings (including prospective legal proceedings); or (iii) in order to establish or defend our legal rights.

Service providers: we share information with service providers who perform services for us (including cloud services, data storage, sales, marketing, investigations, and customer support). Our contracts with our service providers include commitments that they agree to limit their use of information and to comply with privacy and security standards at least as stringent as the terms of our Privacy Policy.

Third-party relationships: if you attend our events and you are not a sole trader or attending in an individual capacity (ie you are attending through the company you work with), we will pass your name, company and email address to sponsors of the relevant event. These sponsors vary between events but they will be named in event materials. Sponsors are separate data controllers in respect of the data they process including this information and you can refer to their own privacy policies on their websites for details about this processing and how to contact them. Sponsors may decide to use your information to contact you after events but must comply with data protection laws in doing so.

Consent: when you request that we share your information with someone else (for example if you engage the services of a professional advisor after you have become a client of ours and request that we provide information about your account to that professional advisor) or when we have otherwise obtained your consent.

Business sale: if we sell some or all of our business or assets we may need to disclose your information to a prospective buyer for due diligence purposes. If we are acquired by a third party, the information held by us about you will be disclosed to the third party buyer.

5. Your rights

You have the following rights under data protection laws within the EU. In most cases you can exercise them free of charge.

You have the right to:

• be informed about the processing of your information;
• have your information corrected if it is inaccurate and to have incomplete information completed;
• object to or restrict processing of your information. Please note that there may be circumstances where you object to, or ask us to restrict our processing of your information but we are legally entitled to refuse that request;
• withdraw your consent to processing of your information at any time. Please note, however, that we may still be entitled to process your information if we have another legitimate reason for doing so (e.g. we may need to retain information to comply with a legal obligation);
• have your information erased in certain circumstances. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it;
• request access to your information and to obtain information about how we process it;
• move, copy or transfer your information;
• receive some information in a structured commonly used and machine-readable format and/or request that we transmit that data to a third party where technically feasible. Please note that this right only applies to information which you have provided directly to Sub 35 and may not always apply;
• lodge a complaint with the relevant data protection regulator if you think any of your rights have been infringed by us; and
• be informed how your information is used in relation to automated decision making which has a legal effect on or otherwise significantly affects you.

Please note that if you withdraw your consent for the future processing of your information we may be unable to send you some marketing communications or information regarding events sponsored by Sub35. Additionally note, when we send you marketing, you will always be provided with an option to unsubscribe or opt out of receiving further marketing from us.

If you wish to exercise any of the rights above please contact us at info@subthirtyfive.com.

In the EU, you have the right to complain to the data protection regulator in your jurisdiction. As our European headquarters are in the UK, you can also contact the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.

6. Storage, transfers and retention

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”). It may be processed by staff operations outside the EEA who work for us or for one of our service providers.

Where we transfer your information to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to information being transferred outside of the EEA, for example, this may be done in one of the following ways:

• the country that we send the information to might be approved by the European Commission as offering an adequate level of protection for information;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your information;
• the country that we send the information to may subscribe to an “international framework” intended to enable secure data sharing;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
• in other circumstances the law may permit us to otherwise transfer your information outside the EEA.

You can obtain more details of the protection given to your information when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your information) by contacting us via email at info@subthirtyfive.com

We will retain information as needed to fulfill the purposes for which it was collected. We will retain and use your information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. We will not retain your information for longer than is reasonably necessary.

7. Security

We have physical, administrative, procedural and technical safeguards in place to protect your information from unauthorised access, use or disclosure. We also contractually require that our third party service providers protect such information to the standard required in the EEA. We regularly adapt these controls to respond to changing requirements and advances in technology.

As a condition of employment, the Sub35 team are required to follow all applicable laws and regulations, including data protection laws. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Sub35 employee is prohibited and may result in disciplinary measures.

8. Making changes to this information

We’ll keep this information up to date and it will always be available at www.subthirtyfive.com or on request at any time.

Cookie Policy

This is the Cookie Policy of Sub35 (also referred to throughout this policy as ‘ we ’, ‘ us ’, or ‘ our’). When you visit our websites, we or a third party service provider may collect technical and navigational information. This is done through the use of cookies. A cookie is a small data file that is sent by a website’s server to your browser and stored on the hard drive of your computer (or internet enabled device).

1. How we use cookies

We collect information about your computer including your Internet Protocol address (“IP address”), operating system, browser type, pages visited and average time spent on our websites. We use this information for a variety of purposes, such as maintaining the security of your online session, online advertising of our products and services, facilitating site navigation, improving our websites’ design and functionalities, and personalising your experience. On their own cookies do not contain or reveal any personally identifiable information. However, if you choose to furnish us with any personal or financial information, this information can be associated with the data collected by the cookies.

If you continue without disabling our cookies we will assume that you are happy with our use of them as outlined in this Cookie Policy.

2. Types of cookies we use

Strictly necessary cookies: Generally these cookies will be essential first party session cookies and are required for the operation of our website. They include cookies that enable you to log into secure areas of our website and help ensure the content of the pages you request load quickly. Without these cookies, you will not be able to access our online services (e.g. our website or a service on our website) which you have requested.

Analytical/performance cookies: These cookies can be first or third party, session or persistent cookies. To fall within this category their usage typically is limited to performance and website improvement. These cookies don’t collect any information that could be used to identify you – all the information collected is anonymous and is only used to help us improve the performance of our websites. A first party example is a cookie that allows us to both count visitors and see how visitors navigate our websites. This helps us improve the way our websites work (e.g. improve the usability to ensure visitors easily find what they want).

Functional cookies: These cookies can be first party or third party, session or persistent cookies. These cookies allow us to provide you with a more personal experience so that you do not have to reset your preferences each time you visit one or more of our websites. To deliver a more personal experience, they enable us to personalise content for you, greet you by name, and remember your preferences (e.g. your choice of language or region).

Targeting cookies : These cookies can be first party or third party. They will always be persistent but time-limited cookies. Targeting cookies are used to send you relevant information and see which content you use. They do this by recording your visits to our websites, the pages you have visited and the links you have followed. We then use the information collected to tailor both our website and the relevance of our advertising displayed to your interests. In order to make our advertising displayed more relevant, we provide the information collected to advertising networks. Please note these cookies do not contain any of your personal or financial information.

3. Cookies we use

The following cookies may be placed on your computer or device by us:

The following cookies may be placed on your computer or device by third parties:

4. Managing cookies

The browsers of most computers, smartphones and other web-enabled devices are typically set up to accept cookies. You can manage cookies that are placed on your browser by activating the setting on your internet browser that allows you to refuse the setting of some or all cookies.

For more information about how to do this, you can use the following links for guidance: Disable/enable Adobe cookies, Control Google web analytics and cookies (browser add-on), Control all cookies with your browser (please note some parts of the website will not function when all cookies are disabled), and Understand Google’s use of advertising cookies.

We understand that some internet browsers have incorporated ‘Do Not Track’ features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. This is different from blocking or deleting cookies, as browsers with a ‘Do Not Track’ feature enabled may still accept cookies. Our websites do not currently recognise and respond to ‘Do Not Track’ requests.

If you have questions on our use of cookies, please get in touch at info@subthirtyfive.com.

5. Definitions

A number of terms used in this Cookie Policy are defined below. These definitions are based on those used in the ICO guidance.

First and third party cookies – whether a cookie is ‘first’ or ‘third’ party refers to the domain placing the cookie. First party cookies are those set by a website that is being visited by the visitor at the time – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than that of the website being visited by the visitor. If a visitor visits a website and another entity sets a cookie through that website this would be a third party cookie.

Session cookies —these cookies allow website operators to link the actions of a visitor during a browser session. A browser session starts when a visitor opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted

Persistent cookies – these cookies remain on a visitor’s device for the period of time specified in the cookie. On the date specified in the expiration, the cookie will be removed from the visitor’s disk unless deleted before by the visitor.