Data & Privacy Statement

Hoxton Analytics Limited
Last Updated: 11 Jan 2022

Introduction

This statement relates to personal information collected and/or processed by Hoxton Analytics Limited (‘Hoxton’).

Hoxton is committed to protecting your privacy. The purpose of this statement is to help you understand what personal information we collect and why, and what we do with it. We have prepared this statement with due regard to the data protection laws in the countries in which we collect and process personal information, including the EU General Data Protection Regulation (EU Regulation 2016/679). We build all of our technologies and products from the ground up to protect people’s privacy and as such comply with the letter and spirit of the laws in the most stringent ways.

Hoxton provides products and services to our business customers (“Customers”) to gather statistical data on how busy their locations are. At no point do we share or publish any personal data, and our systems are set up from the outset not to collect or store any personal data.

Customers use our people counting devices in order to assess the traffic and occupancy of their spaces, for example to understand the busiest hours of a retail store or to know if a building is getting overcrowded.

The camera system is designed to only collect anonymised data, and each device we sell has onboard anonymisation technologies such as face-blurring, to ensure this is the case.

When you visit our website or contact us using our online channels (such as through our social media accounts) we collect your personal information as a controller. For more information, please see the section of this statement below on Website Visitors.

When we anonymise your personal information because you have visited a Customer site, our Customer is the data controller and is responsible for ensuring that the anonymising cameras are situated in locations that the visitor would reasonably be expected to have a people counting device – for example at the entrance of a retailer or a visitor attraction.

The system is designed such that neither the Customer or Hoxton stores personal data, and the only processing that may take place is the anonymisation of personal data before any other party can have access to it.

Hoxton Analytics Website Visitors

Hoxton Analytics Limited (HoxtonAi) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, hoxton.ai (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

2. Information About Us

2.1 Our Site is owned and operated by us. 

2.2 HoxtonAi is a trading name of Hoxton Analytics Limited.

2.3 Our Data Protection Officer can be contacted by email at support@hoxton.ai, by telephone on +44 20 3488 0568, or by post at 5 Merchant Sq, London W2 1AY, UK.

2.4 Hoxton Analytics Limited is registered under the Data Protection Act 2018 with the Information Commissioner’s Office (the, “ICO”). ICO Fee Payer Registration Number: ZB249306

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site and client portal. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the Data Protection Regulations, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 15);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site and/or our services, We may collect some or all of the following personal and non-personal data (please see Our use of Cookies detailed in Our Cookie Policy, which is available on our website): 

5.1 full name; 

5.2 business/company name

5.3 job title/profession;

5.4 contact information such as email addresses and telephone numbers;

5.5 demographic information such as postcode, preferences and interests;

5.6 financial information such as, bank name and account details; 

5.7 IP address;

5.8 cookies and tracker information from your browser and/or device;

5.9 web browser type and version;

5.10 operating system;

5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

5.12 where you contact us by phone, email or post a record of that contact;

5.13 Where you contact us by phone we will retain a recording of that call. 

Personal information we collect when you visit a Customer:

When you visit a Customer, our cameras passively collect and anonymise images from the devices. There is no personal data in the output of this processing as it is designed explicitly to anonymise and remove all personal data.

We process the anonymised data to build an aggregated statistical dataset of people counts and occupancy statistics to help our Customers track venue performance and make decisions to improve the visitor experience or maintain safe occupancy levels.

The information we collect from your device does not include information we or the Customer can use to identify you.

Hoxton as data processor

If we have anonymised your personal information on behalf of a Customer when you have visited them, your rights are facilitated by the Customer because they ultimately decided the purposes and means of the processing. Neither the Customer or Hoxton will however be holding personal data in relation to you, as this is deleted as part of the functionality of the system.

6.How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulations at all times. For more details on security see section 8 below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests (see section 7 below for further information). Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site and client portal;
6.2.3 Personalising and tailoring your experience on Our Site and client portal; 
6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 For monitoring of calls made to and from customers to ensure that we are meeting the standards that we set;
6.2.6 personalising and tailoring Our services for you;
6.2.7 replying to emails from you;
6.2.8 supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us on support@hoxton.ai)
6.2.9 market research;
6.2.10 analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.2.11 to manage your marketing preferences;
6.2.12 to manage your data processing preferences;
6.2.13 to compile anonymised data for analytical purposes.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Regulations (as may be updated from time to time).

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1 As a general rule, unless we have been requested to delete Your information, Customer personal data will be kept for the duration of the provision of the services and for a period of up to six years after the services have been terminated by You or Us. This is based upon the Limitation Act 1980 for the period in which someone can bring a breach of contract claim;
6.5.2 Where we have not provided You with any products or services (i.e. there has been no contract between You and Us), then we will keep your data for a period of 12 months.
6.5.3 We may keep data longer than stated in 6.6.1 and 6.6.2 where we are required to do so by law or a contractual obligation, however where we can we will anonymise such data so that it no longer identifies a living individual.
6.5.4 Call recordings are retained for a period of five years from the date that the call is made.

7. Legitimate Interest

7.1 Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.

7.2 You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 15.

7.3 Our legitimate interests include:

a) the maintenance of our IT/Data Security systems and processes;
b) putting in place fraud prevention mechanisms;
c) keeping our records up to date;
d) working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
e) developing products and services;
f) being efficient about how we fulfil our legal duties;
g) maintaining a marketing suppression list; and
h) complying with laws/regulations that apply to us.

How and Where Do We Store Your Data?

8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

8.2 All our customer data is sorted and accessed from our servers in the UK and European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein), excluding the customer data which we store in the Customer Relations Management (CRM) software we use. Our CRM is provided by HubSpot, which stores data on servers provided by Amazon Web Services (AWS) in the Eastern United States region.

8.3 However, some or all of your data may be stored/transferred outside of the UK. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Regulations including:

8.3.1 Carrying out due diligence on prospective parties to which we wish to transfer the data to;
8.3.2 Carrying out a risk assessment on the country to which we will transfer data to ensure that the protection offered to data subjects is equivalent to those provided in the UK, or accepted by the UK regulator as having adequate levels of protections (i.e. an adequacy decision exists);
8.3.3 Having in place written contracts on the transfer and use of the data (or using model contract clauses) that set out clearly the responsibilities of each party and the rights of data subjects;
8.3.4 Transferring data in an encrypted form or using a secure file transfer protocol;
8.3.5 Limiting the data transfer to only data that needs to be transferred to achieve the purpose.

9. Do We Share Your Data?

9.1 We may share your data with other companies for carrying out/putting in place the services or solution that you require.

9.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising and marketing companies. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

9.3 In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:

• Billing and payments platform 
• Shipping and fulfilment 
• Account management and CRM 
• Support and maintenance 
• Dashboard and reporting portal 
• Campaign management platform
• Emailing platform for sending email communications
• Customer feedback platform
• Compliance consultant

9.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

9.5 We may sometimes use third party data processors that are located outside of the UK. Where

We transfer any personal data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Regulations including:

9.5.1 Carrying out due diligence on prospective parties to which we wish to transfer the data to;
9.5.2 Having in place written contracts on the transfer and use of the data (or using model contract clauses) that set out clearly the responsibilities of each party and the rights of data subjects; and/or;
9.5.3 Transferring data in an encrypted form or using a secure file transfer protocol;
9.5.4 Limiting the scope of the data transfer to a ‘need to know basis’s only.

9.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9.7 We may share your data with regulators and disputes resolution bodies such as:

• The Financial Conduct Authority;
• The Information Commissioner Office;
• The Financial Ombudsman Service;
• Advertising Standards Authority; and
• Local Trading Standards.

9.8 Our service providers as listed in 9.3 and 9.7.

9.9 We use the services of Facebook Ireland Limited (Facebook) to carry out certain marketing activities on the Facebook Platform. Specifically, from time to time we use Facebook’s Audience Insights to help us to create targeted audiences for our advertising campaigns on Facebook. This involves sharing some of our customer personal data with Facebook to allow it to create for us information on the types of audiences (i.e. potential customers) on Facebook platform that would be best suited to see our adverts. In this respect Facebook acts as our joint processor.

For such processing of your personal data we and Facebook also act as a ‘Joint Controller’ this means that both Facebook and us can determine the reasons for processing of your personal data. Facebook has its own privacy policy on how Facebook processes personal data, including the legal basis which Facebook relies on and the ways to exercise Data Subject rights against Facebook. To review Facebook’s privacy policy, you can visit: https://www.facebook.com/about/privacy. You can also obtain full contact details of Facebook or its representative and the details of its Data Protection Officer from this policy.

In order to ensure the rights of data subjects (i.e. you) we have entered into a Controller Addendum with Facebook that sets outs each parties’ respective responsibilities in terms of this processing and our responsibility to inform you of the details in this section 9.9.

Any data subject requests with regard to the Personal Data stored by Facebook Ireland after the Joint Processing described in paragraph one of this section 9.9, is the responsibility of Facebook.

10. What Happens If Our Business Changes Hands?

10.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

10.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

11. How Can You Control Your Data?

11.1 In addition to your rights under the Data Protection Regulations, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you control on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Your Right to Withhold Information

12.1 You may access Our Site without providing any data at all.

12.2 You may restrict Our use of Cookies. For more information, Our Cookie Policy which can be accessed on our website.

13. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulations, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at support@hoxton.ai or using the contact details below in section

14. Our Use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve services. In addition, Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to Our Cookie Policy which can be accessed on our website.

15. Contacting Us

If you would like to contact us, please contact Us at support@hoxton.ai, by telephone on +44 20 3488 0568, or by post at Hoxton Analytics Limited, 5 Merchant Sq, London W2 1AY, UK.

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13 above).

16. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.