Privacy

About this notice

Orion Hub Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.

Data protection law says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely

If you have any questions about this notice or how we collect and use personal information about you please contact us.

1. Information about us

   1. We are Orion Hub Limited. Our registered office is at ADDRESS, CITY AND POST CODE COUNTRY and our registered company number is .
   2. We also have a group company (Orion Hub Limited) which we share data with in collection with our activities. This privacy notice also applies to the activities of Orion Hub Limited.
   3. If you have any questions, our contact details are set out on our Contact page on our website, or using the contact details set out in our app and you may also write to us at our registered office address above or email contact@orion-hub.com .

2. Account information and other correspondence

   1. When you create an account with us (or someone does so on your behalf) there will be personal information about you relating to that account such as your name, contact details, profile details, and potentially correspondence with us about your account.
   2. We need certain information to set up your account and you must provide this in order to have an account with us, if you do not, you will not be able to create or maintain an account. Mandatory information fields are generally set out when you are setting up an account, but these will normally include the following information:
      1. Your name.
      2. Your phone number with country code.
      3. Your date of birth.
      4. The gender you identify as.
      5. Your height.
      6. At least two photos of you.
      7. At least three (3) areas of interest selected from a list of options we provide.
      8. Your payment details.
   3. When you create an account with us you may add extra information or preferences to your profile.
   4. Some of the information that you choose to provide us as set out in the paragraphs above may be considered “special”, “special category” or “sensitive” in certain jurisdictions, for example your ethnicity, sexual orientation or religious beliefs. By choosing to provide this information, you consent to our processing of that information. You may withdraw this consent by removing this information from your account at any time or by closing your account. Please ensure you do not provide any information of this type which you do not want to be visible on your profile.
   5. Other optional profile information. You can also upload more information about yourself, such as your profession, star sign, whether you have children, education level, university attended, information about events you have attended, and answers to profile questions. We also have free text fields for your profile and information you provide in them will be displayed in your profile. If you do choose to add this information to your account, you consent to our processing of that information. You may withdraw this consent by removing this information from your account at any time.
   6. Account recovery. If you provide your email address, we will use this for account recovery purposes.
   7. Chatting and interactions through your account. Please ensure that when you use any chat or other communication features that you do not share any personal information you do not want to be seen by recipients of that chat or interaction. We hold your chat history in order to provide the chat functionality of our service, and to resolve any issues or disputes in relation to user interactions. We also keep records of blocking and reporting (along with the reasons given) in order to action those requests and enforce our terms and conditions.
   8. We use this information to help us improve the service we can give you. For example, by letting us know the gender you are interested in meeting, we can show you relevant matches. If you do not include this information, you will appear in future (or no) searches and you may have fewer (or no) search results. This kind of data also helps our matching logic prepare as curated experience for you as possible.
   9. Other correspondence or interaction (for example by email, telephone, post, SMS or via our website or app) between you and us, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you.
   10. Social media. If we engage with you on social media, we may use information you share with us (including your social media handle or profile) or which is available from your account to inform our correspondence with you.
   11. Information we receive from others. As well as information that you give us directly, we may also collect information about you from others. For instance, this might happen if another user contact us about you.
   12. Call information. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
   13. Why we use this information. We will keep and use that information to administer your account (if applicable), to comply with any legal requirements for us to maintain certain records or carry out certain verifications, and/or for our legitimate interests in preventing fraud, dealing with a complaint or enquiry and administering services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
   14. Where your information relates to an account, it is kept for a period of up to seven (7) years after your account is closed to enable us to deal with any enquiries or claims and as required for tax purposes.
   15. Payment information is collected by our payment card processing provider and is retained by them in accordance with their policies. For more information, please see their information available during the payment process.
   16. If your information is on social media, it will be retained in accordance with the relevant social media platform’s policies. Any other information set out above such as initial enquiries or correspondence which doesn't relate to a customer is kept for seven (7) years from the last point of contact with them.

3. Why else do we use your information

   1. Common uses of your information. We will only use your personal information when the law allows us to do so. We use optional information you upload to your account (and in limited other circumstances) because you have consented to it. We use your other information in the ways set out in this notice because:
      1. we need to administer your account and provide our services to you.
      2. we need to comply with a legal obligation.
      3. it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
      4. we need to protect your interests (or someone else's interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
   2. Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4. Marketing

   1. We may collect your name and contact details (such as your email address) in order to send you information about our products and services which you might be interested in.
   2. You always have the right to "opt out" of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you "opt-out" of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don't include direct marketing.
   3. For individuals. We will only send you marketing emails or texts with your consent.
   4. For businesses. If you are a company or LLP (or are acting in a professional capacity as part of one) we use your contact details as necessary for our legitimate interests in marketing to you (by various channels) and maintaining a list of potential customers.
   5. We never share your name or contact details with third parties for marketing purposes. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
   6. We retain your details on our marketing list until you "opt-out" at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don't accidentally send you any more marketing.
   7. When we send marketing emails to you, we use "web beacons" to collect information about when you open the email, your IP address and browser or email client type, and other similar information. We do this as necessary for our legitimate interests in reviewing and improving our direct marketing activities. We keep this information for six (6) months.

5. Website and app information

   1. We may collect information about you and your use of our website and app via technical means such as cookies, webpage counters and other analytics tools. This may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, device type, operating system and platform and other technology on the devices you use to access a website or app as well as the date and time of your access, what you interact with on our website or app, and (if applicable) the website from which access is made. We use this as necessary for our legitimate interests in administering and improving our website and app and content, to ensure they operate effectively and securely, to develop our business and inform our marketing strategy, and for other administrative purposes. We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors or app users) which is not personal information about you.
   2. Social Media integrations. We have Facebook, Google and Apple login enabled. If you use this to login to your account, or are logged in when visiting our site, or if you click a “share” or “like” or equivalent social media button, the relevant social media platform may be a joint controller with us in relation to information that is sent to them about you regarding your clicking of that button or your use of that login functionality (which may include the types of information which we collect about you as part of your visit to our website or use of our app described above). Any information sent to a Google or a social media platform is used by them according to their privacy policies, and they will be solely responsible for that use and primarily responsible for providing you with information about any joint processing and enabling you to exercise your rights under data protection law. For more information on the responsibilities of Google or social media platforms and us in relation to this functionality, please see their privacy notices:
      1. Facebook: facebook.com/policy
      2. Google: policies.google.com/privacy
      3. Apple: www.apple.com/legal/privacy
   3. For detailed information on the cookies on our site and app and the purposes which they are used for see our Cookie Notice.
   4. We keep this information about you for up to six (6) months from when it is collected or the relevant cookie expires.
   5. Third party websites. Our website or app may, from time to time, contain links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy notice of every website you visit or app you use.

6. Photos, content and promotional material

   1. This is information about you which you provide to us (whether through our website, app or otherwise), or images or recordings of you which you allow us (or someone on our behalf) to use or take (including at our premises or events), for publication or display. This may include reviews, comments, testimonials, photographs (including stock photos and advertising material) and videos.
   2. We may display and publish this content (and, if relevant, attribute it to you) on our platforms as necessary for our legitimate interests in providing content and for promotional purposes (or, in some circumstances, because you have specifically consented to us doing this). This information is kept and published or displayed by us for as long as we consider it relevant for those purposes. You can ask us to remove or delete your content at any time (subject to any agreements about our right to use it) by contacting us. If we are displaying or publishing the information based on your consent, you have the right to withdraw that consent at any time.

7. Professional information

   1. If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
   2. We keep this information for up to seven (7) years after the end of our relationship with your organisation.

8. Application, referees and emergency contacts

   1. We will collect and hold information on job applicants (including applications for work experience or internships), including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide. We may also collect information about your professional history which you make available on LinkedIn, or which are on your employer's website.
   2. We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights. Where you voluntarily provide us with special categories of data, such as information about your race, health or sexuality, we will store this as part of your application on the basis that you have decided to make it public to us for this purpose, and to ensure that our record of your application is accurate so we can comply with (and demonstrate our compliance with) our obligations under employment law.
   3. If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice. If you currently work for us, or used to work for us, you can request a copy of this from us If you are not successful in your application, your information may be held after the process has completed for up to six (6) months, or (if you consent for us to contact you directly about future opportunities) for up to seven (7) years.
   4. You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
   5. If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant's information.
   6. If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that member of staff. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that member of staff, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that member of staff, or we no longer need to contact them after they have stopped working for us.

9. Legal Claims

   Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.

10. Automated decision making

    We use an automated matching logic to match you with the kind of people you should see, and the kind of people that should see you. This is done to create a personalised experience for you and give you the best chance of finding a good match. This will have no impact on you or your information other than determining whose profile is displayed to you, and who your profile is displayed to.

11. Information we receive from third parties

    1. We may also receive information about you from our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out in this privacy notice.

12. Sharing your information

    1. We never sell your data to third parties. But we may need to share your information with third parties, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law.
    2. Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    3. Which third-party service providers process your personal information? We may need to share your personal information with third-party service providers (including contractors and designated agents) so that they can carry out their services. We may use third-party service providers in relation to the following types of activity: legal advice, administration, IT services, payment processing.
    4. When might we share your personal information with other entities in the group? We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
    5. How secure is your information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as "data processors" they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
    6. What about other third parties? We may share your personal information with other third parties, for example with potential buyers and professional advisers in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.

13. Where do we store your information

    1. Our offices are based in England and our main data centre is located in the EU. We do not currently process any data outside of the UK and EEA.
    2. If in the future we do process any data outside of the UK and EEA, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.

14. Data security

    1. As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
    2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.

15. How long will we keep your information for?

    1. We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    2. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
    3. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

16. Your rights

    1. Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from your local data protection authority. Under certain circumstances, by law you have the right to:
       1. Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
       2. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
       3. 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.
       4. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
       5. Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
       6. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
       7. Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
       8. Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
       9. Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority and you may also email complaints@orion-hub.com .

       If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

    2. No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
    3. What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified.
    4. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.

17. Changes to this privacy notice

    Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.