Last updated: March 2026 HUDL CIC (“HUDL”, “we”, “us”, “our”) is the data controller responsible for your personal data. This Privacy Policy explains how we collect, use, store and protect your personal data when you interact with us, including through our website, programmes, and communications. 1. Our approach to your data At HUDL, safeguarding and ethical practice extend to how we handle data. We are committed to: Being transparent about how we use your data Only collecting what we need Keeping your information secure Respecting your rights at all times 2. The types of people we collect data from We may collect and process personal data from: Potential clients and partners Clients and collaborators Programme participants (including young people, associates and parents) Website users Community members (e.g. newsletter, opportunities, book club, WhatsApp channel) 3. How your personal data is collected We collect data in the following ways: Direct interactions You may provide data when you: Fill in forms (e.g. applications, enquiries, sign-ups) Contact us by email, phone or social media Take part in programmes, events or research Subscribe to updates or newsletters Provide feedback Automated technologies When you use our website, we may collect: IP address Browser type and device information Pages visited and usage patterns This is typically collected via cookies or analytics tools. Third parties We may receive data from: Partner organisations (e.g. funders, delivery partners) Event or programme referrals Publicly available sources (where relevant to our work) 4. The data we collect We may collect the following types of personal data: Identity Data: name, date of birth, gender (where relevant) Contact Data: email, phone number, address Professional Data: organisation, role, experience Programme Data: participation, feedback, contributions Technical Data: IP address, browser, usage data Marketing Preferences: communication preferences Special category data In some cases (particularly in youth programmes), we may collect sensitive data such as: Health or access needs Ethnicity or background (to support inclusion and equity) We only collect this where necessary and with appropriate safeguards. 5. How we use your data (lawful basis) Under UK GDPR, we must have a lawful basis for processing your data. We use: Contract – to deliver programmes or services Legitimate interests – to run and improve our work Legal obligation – to comply with safeguarding, financial or regulatory requirements Consent – for marketing communications and certain data collection We may use your data to: Deliver programmes, workshops and consultancy Manage relationships with clients and partners Communicate opportunities, updates and relevant work Improve our services and website Ensure safeguarding and duty of care Meet legal and reporting requirements 6. Marketing and communications We may send you updates, opportunities or newsletters if: You have opted in, or You have an existing relationship with us, and it is relevant You can opt out at any time by: Clicking “unsubscribe” Contacting us directly 7. Sharing your data We do not sell your data. We may share your data with: Trusted associates and facilitators delivering HUDL work Service providers (e.g. IT systems, payment providers) Delivery partners and funders (where relevant to a programme) All third parties are required to: Keep your data secure Only use it for agreed purposes 8. International transfers Where data is transferred outside the UK, we ensure appropriate safeguards are in place, such as: UK-approved standard contractual clauses Adequacy regulations 9. Data security We have appropriate technical and organisational measures in place to protect your data, including: Restricted access to data Secure systems and storage Internal policies and training We also have procedures in place to respond to any data breaches. 10. Data retention We only keep personal data for as long as necessary, including: Programme delivery and reporting requirements Legal and financial obligations Safeguarding responsibilities Where possible, we anonymise data for learning and research. 11. Your rights Under UK GDPR, you have the right to: Access your personal data Correct inaccurate data Request the deletion of your data Restrict or object to processing Request transfer of your data Withdraw consent at any time To exercise your rights, contact us at: hello@hudl.org.uk 12. Complaints You have the right to lodge a complaint with the Information Commissioner's Office (ICO). We encourage you to contact us first so we can resolve your concern. 13. Third-party links Our website may contain links to external sites. We are not responsible for their privacy practices. 14. Updates to this policy We may update this Privacy Policy from time to time. The latest version will always be available on our website.