HURR PRIVACY POLICY

Last updated: May 2024

1. IMPORTANT INFORMATION ABOUT HURR

Privacy policy

1. This privacy policy gives you information about how HURR Limited (“HURR”) collects and uses your personal data, including any data you may provide HURR when you register for an account on the HURR website or app (the "HURR Platform”) or use HURR services (the “HURR Services”).
2. HURR operates the online fashion marketplace on the domain hurrcollective.com and connects both renters with lenders and buyers with sellers on the HURR Platform. HURR’s mission is to reinvent ownership by providing all the short-cuts to a sustainable wardrobe through renting, lending, monthly refreshes, purchase or sale of pre-owned clothing via the HURR Platform.
3. You are required to register as a member and create an account and profile in order to make full use of the HURR Services (“Member”).
4. The HURR Platform is not intended for children and HURR does not knowingly collect data relating to children.

Controller

5. HURR is a company registered in England and Wales with company number 11262189 and whose registered office is situated at 85 Great Portland Street, First Floor, London W1W 7LT. HURR is the data controller and is responsible for your personal information.

Defined terms

6. Any capitalised terms that are not defined in this policy are set out in HURR Terms of Service (“Terms”).
7. For the purposes of this policy the following definitions are adopted:

1. Renter means a Member who Rents product(s) on the HURR Platform from a Lender;
2. Lender means a Member who makes available product(s) to Rent and Lends Products to Renters via the HURR Platform;
3. Buyer means a Member who purchases products on the HURR Platform from a Seller; and
4. Seller means a Member who makes available products for sale to Buyers on the HURR Platform.

2. INFORMATION HURR MAY COLLECT ABOUT YOU

1. HURR is committed to protecting your Information (as defined below) and your right to privacy. Personal data, or personal information means any information about an identified individual or information from which that person can be identified. It does not include anonymous information, namely information which does not relate to an identified or identifiable individual, or personal data rendered anonymous in such a manner that the individual is not or no longer identifiable.
2. HURR may collect, process, use, store and transfer different types of personal data about you when you use the HURR Services, access the HURR Platform and/or when you otherwise deal with HURR (the “Information”) which we have grouped together as follows:

1. Identity Data includes first name, last name, date of birth, place of birth, clothes, accessories and shoe sizings, photographs, national insurance number, personal ID number, identity documents (e.g. passport), credit checks, personal characteristics and gender.
2. Profile Data includes your username and password, profile picture, purchases or orders made by you, your interests, preferences, feedback and survey responses.
3. Contact Data means the data HURR uses to contact you including your billing address, delivery address, work address, email address and contact numbers.
4. Financial Data means the bank account details, payment method and card association used to process payments for your orders. HURR does not store or process your bank account details and card details; they are processed and stored via one of HURR’s contracted third-party service providers. The bank account details and payment card details you provide via your browser when using the HURR Services on HURR webpages are encrypted via Hypertext Transfer Protocol Secure (HTTPS) and are then securely transferred to HURR’s relevant third-party payment service provider to process your payment.
5. Usage Data includes information about how you use the HURR Services. This includes your browsing patterns and information including but not limited to how long you might spend on one of HURR webpages on the HURR Platform and what items you look at and the page that referred you to the HURR Platform and the clickstream during your visit to HURR website, page response times and page interaction information (clicks you make on a page).
6. Marketing and Communications Data includes your preferences in receiving marketing from HURR and your communication preferences including push notifications and other information relevant to HURR Services, customer surveys and/or offers.
7. Social Media and Third-party Login Data. HURR provides you with the option to register using social media account details, like your Apple, Meta, Google or third-party login account. If you choose to register in this way, HURR will collect the Information described in the section called "Third-party logins" below. All information that you provide to HURR must be true, complete and accurate, and you must notify HURR of any changes to such Information.

Special category data

3. HURR does not collect any special categories of personal data about you (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). It is for you to decide whether you want to share such information in the content you submit through the HURR Platform and share with others. However, HURR may collect information about criminal convictions and offences when carrying out credit checks on HURR Members.

Minors

4. HURR takes steps to ensure that the HURR Services are only used by those over 18 years of age and HURR does not knowingly collect data from or market to children under 18 years of age.
5. HURR does not knowingly solicit data from or market to children under 18 years of age. By using the HURR Services, you represent that you are at least 18 years of age. If HURR learns that Information from users less than 18 years of age has been collected, HURR will deactivate the account and take reasonable measures to promptly delete such data from HURR’s records. If you become aware of any data HURR has collected from children under age 18, please contact HURR at [email protected].

3. HOW IS YOUR PERSONAL DATA COLLECTED?

6. HURR uses different methods to collect data from and about you including through:

1. Your interactions with HURR. You may give HURR your personal data by filling in online forms or by corresponding with HURR by post, phone, email or otherwise. This includes personal data you provide when you:

1. use the HURR Services or HURR Platform;
2. create an account on the HURR Platform;
3. request marketing to be sent to you;
4. enter a competition, promotion or survey; or
5. give HURR feedback or contact HURR.

2. Automated technologies or interactions. As you interact with the HURR Platform, HURR will automatically collect technical data about your equipment, browsing actions and patterns. HURR collects this personal data by using cookies and other similar technologies. Please see HURR’s cookie policy for further details. This information is primarily needed to maintain the security and operation of the HURR Platform, and for HURR’s internal analytics and reporting purposes. Most devices allow you to manage the use of location services through your settings menu. If you would prefer not to share your location, please disable use through your device directly. Additionally, parts of the HURR Platform may use Google Maps/Earth services. For further information on using their services, please see the Google Maps/Earth Terms of Use and Privacy Policy. HURR reserves the right to block certain IP addresses from accessing the HURR Platform.
3. Third parties or publicly available sources. HURR will receive personal data about you from various third parties such as public databases, joint marketing partners and social media platforms (such as Facebook or Instagram). Such information may include:

1. social media profile information (your name, due date, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public);
2. marketing leads and search results and links, including paid listings (such as sponsored links); and
3. information obtained when carrying out credit checks via credit agencies, such as Experian.

7. Where HURR needs to collect your Information by law, or under the terms of a contract HURR has with you, and you fail to provide that Information when requested, HURR may not be able to perform the contract HURR has or is trying to enter into with you (for example, to provide you with HURR Services). In this case, HURR may have to cancel a product or service you have with HURR, but HURR will notify you if this is the case at the time.

4. HOW DO HURR USE YOUR INFORMATION?

Legal basis

8. The law requires HURR to have a legal basis for collecting and using your personal data. HURR rely on one or more of the following legal bases:

1. where it is necessary for HURR’s legitimate business interests (“Business Purposes”) and your interests and fundamental rights do not override those interests;
2. in order to enter into or perform a contract with you (“Contractual”);
3. with your consent (“Consent”); and/or
4. for compliance with HURR legal obligations (“Legal Obligations”).

9. HURR has set out below a description of all the ways HURR plan to use the various categories of your personal data, and which of the legal bases HURR rely on to do so. HURR have also identified what HURR legitimate interests are where appropriate.

10. HURR will only use your Information for the purposes for which HURR collected it, unless HURR reasonably considers that HURR needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact HURR. If HURR needs to use your Information for an unrelated purpose, HURR will notify you and HURR will explain the legal basis which allows HURR to do so. Please note that HURR may process your Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Consent

11. You will be required to give Consent to certain processing activities before HURR can process your Information. Where applicable, HURR will seek Consent from you when you first submit Information to or through the HURR Services.
12. If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing data@hurrcollective.com.
13. If you withdraw your Consent, and if HURR does not have another legal basis for processing your Information, then HURR will stop processing your Information and delete it together with your Account. If HURR does have another legal basis for processing your Information, then HURR may continue to do so, subject to your legal rights.
14. Please note that if HURR needs to process your Information in order for you to use the HURR Services and you object or do not provide Consent to HURR processing your Information, the HURR Services will not be available to you.

Direct Marketing

15. If you have given Consent to marketing, HURR may contact you about HURR products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by unsubscribing from the communications via the link available in each communication.

16. HURR may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that HURR can then send you relevant marketing communications.

Cookies

17. For more information about the cookies HURR use and how to change your cookie preferences, please press “Privacy Preferences” in the footer of the website.

5. DISCLOSURES OF YOUR PERSONAL DATA

1. HURR only shares and discloses your Information in the following situations for the purposes set out above in "4. How do HURR use your Information?":

Contractual

2. To share information with Members to enable usage of the HURR Services including renting, lending, purchase or sale of Items. When a Renter submits a rental request (or a Buyer submits an offer), HURR will provide the relevant Lender/Seller with the Renter/Buyer's full name, cancellation history, reviews and any other information the Member has agreed to share. Once the Lender/Seller has accepted the rental request/offer, HURR will share the requesting Renter/Buyer's information to co-ordinate the delivery of the item such as the Renter/Buyer's phone number and address. HURR will never share your billing or payment information with other Members.

Compliance with Legal Obligations

3. HURR may disclose your Information where HURR is legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order (including in response to public authorities to meet national security or law enforcement requirements).
4. HURR may disclose your Information where HURR believes it is necessary to investigate, prevent, or take action regarding potential violations of HURR policies, suspected fraud or criminal activity, situations involving potential threats to the safety of any person or illegal activities, or as evidence in litigation in which HURR is involved. Such Information may be disclosed to government bodies, including but not limited to HMRC, the National Crime Agency and relevant police forces.

Third-Party Service Providers

5. HURR may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service, search information providers, delivery service providers, analytic providers, developers, credit reference agencies, ID verification service providers and marketing agencies. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as HURR ask them to and always in accordance with this policy. The third parties HURR use include but are not limited to Stripe, Zendesk, Google Analytics, Instagram, Facebook, delivery partners and various Google APIs. In some cases, the Information provided to HURR varies and is controlled by the specific service or as authorised by you via your privacy settings for that service. For more information on how these companies handle your personal data, please refer to their privacy policies.

Business transfers

6. HURR may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of HURR business to another company.

Business partners

7. Provided you have given HURR Consent to do so HURR may share your Information with HURR business partners to offer you certain products, services or promotions. HURR will get your express opt-in consent before HURR share your Information with any third party for marketing purposes. You can ask HURR or third parties to stop sending you marketing messages at any time by logging into the HURR Platform and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message or SMS sent to you or by sending an email to [email protected].

With your Consent

8. HURR may disclose your Information for any other purpose with your Consent.

Aggregated and anonymous information

9. HURR may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist HURR in the provision of services.

6. VISIBILITY OF PERSONAL DATA

1. Some of your profile information will be visible to other Members when you interact such as your profile photo and delivery address. Information which will be publicly available to users on your profile will be your first and second name and profile picture. Listings that are publicly visible will show any information relating to the Listing (e.g. description, item availability, Lender profile picture and name). Reviews from Lenders/Renters will be published and visible on your public profile. 
2. Always think carefully before disclosing your Information or other information to other users or otherwise posting Information on the HURR Platform. HURR does not control the content of communications made between users (although you can make a complaint about another user by contacting HURR using the information provided in the “13. Contact and complaints” section below).
3. You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their Information at any time.
4. To change your privacy settings on the HURR Platform, please login and do so via your user dashboard. Once you have shared your content or made it public, that content may be re-shared by other users. You may review, modify, update, correct or remove any Information you have submitted to the HURR Platform at any time. If you remove information that you posted to the HURR Platform, copies may remain viewable in cached and archived pages of the HURR Platform,  in the log of account details that HURR maintains for security purposes or if other users or third-party APIs have copied or saved that information.

7. INTERNATIONAL DATA TRANSFERS

1. HURR may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
2. Whenever HURR transfers your Information outside of the UK, HURR will take all reasonable measures that HURR can to protect your Information in accordance with this policy and applicable law. To the extent that any transfer of your Information outside of the UK is required, HURR ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. HURR will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data.
2. Where HURR uses certain service providers, HURR may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

8. DATA SECURITY

1. HURR aims to protect your Information through a system of organisational and technical security measures.
2. HURR has implemented appropriate technical and organisational security measures designed to protect the security of any Information HURR processes. Although HURR will do its best to protect your Information, transmission of Information to and from the HURR Platform is at your own risk. You should only access HURR services within a secure environment. All personal information is encrypted in transit and at rest. Your payment information is also encrypted in transit and at rest by HURR third party.
3. HURR has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where HURR is legally required to do so.

9. HOW LONG DOES HURR KEEP YOUR INFORMATION?

1. HURR will only keep your Information for as long as it is necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). HURR may retain your Information for a longer period in the event of a complaint or if HURR reasonably believe there is a prospect of litigation in respect of HURR’s relationship with you.
2. To determine the appropriate retention period for Information, HURR consider the amount, nature and sensitivity of the Information, the potential risk of harm from unauthorised use or disclosure of your Information, the purposes for which HURR process your Information and whether HURR can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
3. By law HURR have to keep basic information about HURR customers (including Contact Data, Identity Data and Financial Data) for six years after they cease being customers for tax purposes.
4. In some circumstances you can ask HURR to delete your data: see "12. Your Legal Rights" below for further information.
5. In some circumstances HURR will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case HURR may use this information indefinitely without further notice to you.
6. When HURR have no ongoing Business Purpose to process your Information, HURR will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then HURR will securely store your Information and isolate it from any further processing until deletion is possible.

10. THIRD-PARTY WEBSITES

1. HURR is not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the HURR Services. The HURR Platform features links to third-party websites and contains advertisements from third parties that are not affiliated with HURR and which may link to other websites, online services or mobile applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
2. HURR cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this policy. HURR is not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the HURR Platform. You should review the policies of such third parties and contact them directly to respond to your questions. Anything you share on the publicly available part of the HURR Platform will also be catalogued by third-party search engines. HURR is not responsible for their use of your information or the accuracy of it.

11. THIRD-PARTY LOGINS

1. If you choose to register or log in to the HURR Platform using a social media account or third-party website (e.g. Amazon), HURR may have access to certain Information about you.
2. The HURR Platform offers you the ability to register and log in using certain social media account details (like your Meta or Twitter logins) and third-party website providers. Where you choose to do this, HURR will receive certain information from your social media or third-party provider. The Information HURR receives may vary depending on the social media or third-party provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public. If you log in using Meta, HURR may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny HURR access to each individual permission. The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and HURR have no control over such viewing and use and cannot prevent further use of such information by third parties.
3. In the event you choose to link your HURR profile with a social media or third-party account, the information you provide to HURR in the process may be included on your HURR profile. Additionally, your contacts on the social media platform(s) (“Friends”) may be able to see your activity on the HURR Platform. A link to your public profile on the social media site may be added to your HURR profile and other users may be able to see any Friends or links (e.g. friends of friends) via that social network you may have in common with them.
4. When you interact with HURR through social media networks, you acknowledge that HURR may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under HURR control and remain solely your responsibility. You acknowledge that any information posted via social media through the HURR Platform, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third parties who can use that information at their discretion.
5. Please note that HURR does not control, and is not responsible for, other uses of your Information by your third-party social media provider. HURR recommends that you review their privacy policy to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.

12. YOUR LEGAL RIGHTS

1. You have certain rights under applicable data protection laws. These may include the right, under certain circumstances:

1. to withdraw consent as set out above (see "Your Consent to processing"). Please note however that this will not affect the lawfulness of the processing before its withdrawal;
2. to request access and obtain a copy of your Information;
3. to request rectification or erasure of your Information;
4. to restrict the processing of your Information;
5. if applicable, to data portability; and
6. to object to the processing of your Information.

2. If you wish to exercise any of the rights set out above, please contact HURR at [email protected]. HURR will consider and act upon any request in accordance with applicable data protection laws.
3. HURR may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. HURR may also contact you to ask you for further information in relation to your request to speed up your response.
4. No fee usually required. You will not have to pay a fee to access your Information (or to exercise any of the other rights). However, HURR may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, HURR could refuse to comply with your request in these circumstances.
5. Time limit to respond. HURR tries to respond to all legitimate requests within one month. Occasionally it could take HURR longer than a month if your request is particularly complex or you have made a number of requests. In this case, HURR will notify you and keep you updated.

13. CONTACT AND COMPLAINTS

1. HURR welcomes your feedback and questions on this policy. If you wish to contact HURR about this policy, about your Information or any other questions, please email HURR at [email protected].

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). HURR would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact HURR in the first instance.

14. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM HURR OF CHANGES  

3. HURR keeps the HURR privacy policy under regular review. If you do not agree to any changes to this policy then you must immediately stop using the HURR Services. In the event HURR makes any significant changes to this policy, HURR will use HURR best endeavours to inform you of such changes in advance in writing.
4. It is important that the personal data HURR holds about you is accurate and current. Please keep HURR informed if your personal data changes during your relationship with HURR, for example a new address or email address.