Akero Group Privacy Notice
(Student Hut is part of Akero Group)
The Akero Group ("we") are committed to protecting and respecting your privacy.
The Akero Group comprises Net Natives Limited (registered in England and Wales under number 12357553 with registered address at 21 Dyke Road, Brighton, BN1 3FE, United Kingdom) along with all of its group undertakings as defined in s1161(5) of the UK Companies Act 2006.
For the purpose of the Data Protection Act 2018 and thereafter and the General Data Protection Regulation (Regulation (EU 2016/679) as amended or replaced from time to time (“Data Protection Law”), each operating undertaking in the Akero Group (that is to say, each subsidiary undertaking of Akero Group Limited (English company number 10855914), but not Akero Group Limited itself, which is a non-operating company) may be a joint data controller in respect of data processed by each other operating undertaking. References to “we” in this notice are therefore references to the relevant member of the Akero Group.
According to Data Protection Law an individual may exercise his or her rights against each or any joint data controllers. However, in the first instance, you should contact Luke Kirkpatrick, CTO, at the above address or by email at [email protected] in the event that you have any issues related to data protection or this notice.
Where we are processing data on behalf of a customer of ours, we will be doing so as a “processor” for the purposes of Data Protection Law, and the customer will be the “controller”.
1. Information we collect from you
We will collect and process the following data about you:
1.1. Information you give us
This is information about you that you give us by filling in forms on our websites, applications or other media ("our sites") or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our sites, enter a competition, promotion, panel activity or survey and when you report a problem with our sites or services. The information you give us may include your name, email address, as necessary for us to do what we need to do.
1.2. Information we collect about you
We use our sites and communications to facilitate the provision of information about us or our customers to you. With regard to each of your visits to our sites and any correspondence that may flow between us (including emails), we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information for using the site/application, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstreamed to, through and from the site/application (including date and time); page response times, download errors, timing of your responses, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
2. Cookies and Tracking
Types of cookies used on our sites:
2.1.1. Analytics & Tracking - We use these to understand how the site/application is being used in order to improve the user experience. User data is anonymous.
2.1.2. Remarketing - We use these cookies to show relevant adverts to users who have previously visited our site/application, as they browse other websites. We also use these cookies to generate profile information in order to allow us to market to people with similar profiles. Remarketing services we use include both Google and Meta. To opt-out from Google’s remarketing program, please edit your Google Ad Settings.
2.2. Web beacons, such as pixels, may be included in our emails and sites. Web beacons may be used to track users’ activity in relation to our emails and sites.
3. Purposes for which we may process the information
We use information held about you in the following ways:
3.1. Information you give to us.
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services, or those of our customers, that you request from us;
- helping to manage our sites;
- market research, where you have specifically opted in to join the Student Hut panel, we may contact you about opportunities to take part in research via email;
- to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about with us;
- to notify you about changes to our sites or services;
- to ensure that content from our sites is presented in the most effective manner for you and for your computer.
Please note that, where you are asked to provide information to us which is of a sort that is necessary to enable us to perform a contract or fulfil a request that you make (eg contact, delivery or payment information) it is a requirement for us to enter and perform such a contract or fulfil your request that you provide that information – if you do not do so, we may not be able to perform your contract or fulfil your request.
3.2. Information we collect about you
We will use this information:
- to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our sites or services, when you choose to do so;
- as part of our efforts to keep our sites safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our sites about goods or services that may interest you or them;
- to include non identifiable data in compiled data summaries and the published public reporting of aggregated data and statistical analysis of trends;
- to include non identifiable data in published market research and PR, examining student trends.
3.3. Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out in sections 3.1 and/or 3.2 above (depending on the types of information we receive).
4. Disclosure of your information
4.1. You agree that we have the right to share your personal information:
4.1.1. With any other member of the Akero Group, provided that:
- they are joint controllers for the purposes of Data Protection Law or are processing the data purely for administrative purposes; and
- they are either (i) within the European Economic Area, or (ii) are in a country that the European Union has decided has adequate data protection laws in place, or (iii) have provided appropriate data protection safeguards of the sort approved by the European Union and provide effective rights and remedies for you.
Other members of the Akero Group may process your personal data in accordance with this notice as the data controller, subject to all the requirements of Data Protection Law.
4.1.2. Selected third parties where reasonably necessary for the purpose of carrying out our business, including:
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisements on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
- analytics and search engine providers that assist us in the improvement and optimisation of our sites;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
5. Legal basis of processing
5.1. Data Protection law requires us to meet at least one “legal ground” for processing, currently set out in Article 6 of the General Data Protection Regulation. The grounds applicable to the personal data to which this notice relates are as follows.
5.1.1. Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract, including providing you with information at your request, that is the ground on which we are processing that data;
5.1.2. Where the processing is necessary for compliance with a legal obligation to which we are subject, that is the ground on which we are processing that data;
5.1.3. Where processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, that is the ground on which we are processing that data, provided that your fundamental rights and freedoms which require protection of your data override those legitimate interests (our legitimate interests comprise the management, marketing and promotion of our business and services);
5.1.4. If you have given your consent to our processing the data, that is the basis on which we are processing that data.
If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the one that is set out above. If one of the above grounds ceases to apply to the processing of data in question, but other grounds continue to apply, we will be entitled to continue processing pursuant to the next applicable ground.
6. Where we store your personal data
6.1. The data that we collect from you will be stored on our servers or those of our service providers. It will not be transferred to, and stored at, a destination outside the European Economic Area ("EEA") unless
6.1.1. To a member of the Akero Group to which section 4.1.1 applies;
6.1.2. To a processor acting on our behalf which is either (i) within the European Economic Area, or (ii) in a country that the European Union has decided has adequate data protection laws in place, or (iii) has provided appropriate data protection safeguards of the sort approved by the European Union and provide effective rights and remedies for you.
6.2. All information you provide to us is stored on our secure servers or those of our service providers. Any data transmission will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites or services, you are responsible for keeping this password confidential, and for all use made of your account with such password. We ask you not to share a password with anyone.
6.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites or servers; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Length of data storage
7.1. Our policy is to ensure that personal data is only stored for as long as is necessary for the purposes set out at section 3 above. This may vary according to the type of information and the specific applicable purpose(s). In general, however, we keep personal data for up to 24 months after its collection. In determining how long we retain your information for, we take into consideration various criteria, including our legal obligations, good industry practice, the guidance of relevant authorities and bodies such as HM Revenue and Customs, the Information Commissioner’s Office and the Office for Students, as well as tax, accounting, health and safety and employment rules where applicable.
8. Your rights
8.1. You have various rights under Data Protection Law. These include:
8.1.1. The right to ask us not to process your personal data for direct marketing purposes, even if you have given consent;
8.1.2. If our processing is based on your consent, the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;
8.1.3. The right to ask us for access to the data we hold about you (see section 8 below for further details);
8.1.4. The right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;
8.1.5. The right to ask us to delete your data in certain circumstances;
8.1.6. The right to ask us to restrict our processing of your data in certain circumstances;
8.1.7. The right to object to our processing of your data in certain circumstances, including in respect of certain of the activities mentioned in section 3.2 above;
8.1.8. In certain circumstances, the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.
8.2. You can exercise any of the rights set out above, free of charge, by using any applicable methods set out in our communications with you, or by contacting us at [email protected]. In respect of certain of the rights referred to above, your right may be qualified by the GDPR (which we will discuss with you following your request) or we may need more information from you, which we will ask you for following your request. We may ask you to provide further information in order to confirm your identity. Please also note that if you submit unfounded or excessive (for example repetitive) requests to exercise any of these rights, we reserve the right to make a reasonable charge for providing the requested information or taking the requested action, or to decline your request.
8.3. You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you are concerned that we are not respecting your rights under Data Protection Law. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of, and enforcing, Data Protection Law.
9. Accessing your data
To expand on the right to access your data referred to at section 8.1.3 above, you have the right to obtain from us:
9.1. Confirmation as to whether we are processing (including holding) personal data about you; and
9.2. If we are processing personal data about you, you are entitled to be provided with:
9.2.1. Information as to the purposes for which we process the data;
9.2.2. Information as to the categories of the data that we are processing;
9.2.3. Information as to the recipients or categories of recipients to whom the data has or will be disclosed;
9.2.4. Information as to the envisaged period for which we will store the data, or if the basis on which that period will be determined;
9.2.5. A copy of the data (further copies are available at a reasonable charge, which we will inform you of should you request further copies). Please note that this right is subject to the rights of others in relation to their own personal data, meaning that we may not be able to disclose data to you if it would involve disclosing data about someone else.
9.3. Please see section 8.2 above as to how to exercise your rights under this section 9. Section 8.2 applies in full to the exercise of these rights.
10. Other websites
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Last updated: 14th June 2022