Privacy Policy


At HuBB – Humans Before Borders we take the use of your data seriously. We aim to be clear and transparent about how we collect, what we collect and how we use your data. We also want to give you control of your data and a choice of how this data is used.
This privacy policy gives you information about:

  1. Where we collect information about you
  2. What information we collect about you
  3. How we use your data
  4. Marketing and consent
  5. Whether we share your data
  6. Your data protection rights
  7. Data security
  8. For how long we store your data
  9. What to do if you want to raise a concern or complaint

Where we collect information about you?

HuBB may collect information from you in the following circumstances:

a. When you give it to us DIRECTLY
You may give us your information when you:
– Sign up to one of our events
– Make a donation
– Purchase one of our products
– Apply for a volunteer vacancy
– Contact us with a query
– Subscribe to one of our on-line events
– Fill in a HuBB survey

b. When you give it to us INDIRECTLY
Your information may be shared with us by independent course organisers, for example when you
take part in an event that is not organised by HuBB, but HuBB is an integral part of the event.
We will always ask those working on our behalf and our partners to ask for your consent to receive HuBB news and marketing emails.

c. When you use HuBB’s SOCIAL MEDIA
When using our social media services such as Facebook, Twitter and Instagram the settings you have in place may give us permission to access information about you from these accounts. These cookies enable in-depth campaign reporting and the tracking of social network users when they visit our websites by using a tagging mechanism provided by those social networks.

If you want to change what information is shared with us you can refer to the following privacy notices to see how you can change your privacy settings:

d. When the information is publicly available

We might obtain personal data about individuals from places such as public institutions or information published in the media.

e. When we collect information via our WEBSITE


Cookies are small data files that are served by our platform and stored on your device. The HuBB website is hosted by PTISP/ WordPress and it makes use of cookies for technical reasons and to enable a personalised experience for visitors and registered users.

Newsletter subscription

This site offers newsletter or email subscription services, and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/ unsubscribed users. We use external programmes to send and manage marketing emails and newsletters.

Google Services

In our website we use several google services, like, Google Analytics and Google Tags, your information is stored and collected as cookies. These cookies are used to collect analytical information about how visitors use the website. All web traffic and usage information is collected in an aggregate form.

For more information about Google Analytics cookies, see the official Google Analytics page, or how google uses information from sites or apps that uses their services.

Donation in the website and debit/credit card security

The HuBB website offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.

The HuBB website uses third party platforms (paypal and stripe) to process e-commerce transactions. This site uses the industry standard protocol which encrypts your information as it is transmitted over the internet.

If you visit our website, HuBB may collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device). We can tell what website directed you to our website by looking at information from our browser.

The HuBB website contains links to external sites not owned or managed by us. We cannot be held responsible for the content or for the privacy of any external sites.

What information do we collect about you?

Personal data
The following list is the personal data we may collect about you:

  • First name and surname
  • Email address
  • Postal address
  • Date of birth
  • Country of residence
  • Bank details
  • IP addresses

Sensitive personal data
We only collect sensitive personal data where there is a clear reason for doing so and this is limited.
Examples of when we may collect this data is if we need to provide services to you and we need to
make adjustments based on your physical health needs, or if we need to support you to be able to take
part in an event.

What lawful basis do we use to process data?

There are six lawful bases for processing an individual’s data, however, only three apply to our

Information is processed to fulfil a contractual relationship.
Legitimate interests
Information is processed because it is within Gaia Education’s legitimate interest to do so. Where we
have used legitimate interests, we will always balance this with your rights and ensure that it has a
minimal privacy impact.
Information is only processed based on your explicit consent.

How do we use your data?

For marketing and fundraising
Please see section 5

When you sign up to one of our face-to-face events

  • To process your payment
  • To be able to contact you with details of the event
  • To ensure that our events can be tailored to individual needs
  • So that we can cater to any mental/physical health needs and dietary requirements
  • So that we can book and organise accommodation
  • To ensure that we are adhering to the health and safety regulations of the course venue

When you sign up to one of our online events

  • To process your payment
  • So that we can register you on the online platform
  • To generate individual login details if needed
  • To fulfil contractual obligations
  • Including:
    • When you have bought a product or register for an event from us we will need to process your payment in order to provide you with the product
    • To confirm receipt of payment
    • To process your details in order to send you the product this is very similar to the first point
    • In case we need to contact you about a transaction you have made


We use profiling to segment our information so that we can effectively analyse it. This allows us to
develop our marketing strategy to specifically target what information we send out and ensures that
the information we send to you is relevant. It ensures that you only receive information that is
appropriate, based on your engagement with us, and that we think you will find interesting. We will
only send you information when you have given us your express consent to do so.
We may build your profile based on geographic or demographic information as well as how you have
engaged with us before, what courses you have taken, and what products you have purchased from us.

Administration and Governance

  • Maintaining ‘do not contact’ lists
  • Asking you to take part in surveys about the event you have been on or the product you have bought, to help HuBB improve their work
  • For reporting purposes
  • Monitoring staff, board members, volunteers and employees for recruitment or compliance purposes
  • Administration of payroll and staff benefits such as pensions
  • If you contact us and we need the information you have provided in order to correspond with you

Sharing your story
With the consent of the individual we may use quotations from feedback we receive on our website.
We also publish reports on our website from some of our courses.

Marketing & Consent

From 25 May 2018 we only contact you for marketing purposes or to share our news with you where we have your express consent to do so. We will not send you marketing emails if you have asked us
not to.
We make it easy for you to let us know if you want us to communicate to you or not. Our forms have
a clear opt in to marketing and news tick box – if you do not tick it, we will not send you marketing
When you do give consent you can opt out at any time by clicking ‘Unsubscribe’ at the bottom of our
emails, or by emailing
The maximum marketing that we carry out includes quarterly newsletters as well as weekly emails
regarding upcoming courses. We only send information we think you will be interested in.

Do we share your information with anyone else?

We will never sell your information to anyone else for the purposes of marketing and we only share it
with necessary people.
Where we run an event or promotion in partnership with another organisation your details may need to
be shared to fulfil our contract with you or for legitimate reasons. An example of this would be an
organisation which is running an event for us – we need to send them your information in order
to book you into appropriate accommodation and to deliver services tailored to your needs (for example dietary).
We may share information with third parties who are performing a service for us. An example of this
is secure database provider that is PTISP a Portuguese company.

Your data protection rights under GDPR

  1. The right to be informed
    Under GDPR, we will be as transparent as possible on how we use your data. This information will be given in our Privacy Policy where we will be as clear and concise as possible.
  2. The right of access
    You can write to us to ask us, free of payment, what information we hold about you at We will respond to you within 30 days after you have confirmed your identity.
  3. The right to rectification
    You have the right to ask us, free of payment, to change your details if they are not correct or up to
  4. The right to erasure
    You can ask us, free of payment, to delete your data and in most cases we will be able to do this.
    There may be some circumstances in which we have to keep your data.
  5. The right to restrict processing
    You can ask for us to stop processing your data for certain activities or for us to suppress your
  6. The right to data portability
    Individuals have the right to request their information and transport it to another service. This is
    unlikely to be relevant to HuBB.
  7. The right to object
    In terms of marketing, you have the right to object and for these activities to be stopped.
  8. Rights in relation to automated decision making and profiling.
    This allows an individual access to information about the reasoning behind any decisions taken by
    automated means.

Data Security – how do we keep your data safe?

We ensure that we have the relevant controls in place to make sure that your data is safe. Most of our
data is stored electronically and we ensure that our network is password protected. We make every
reasonable effort to ensure that the data you send to us is safe.
Your data is only accessible by the board and trusted volunteers.

How long do we store your information?

We will only keep your information for as long as we require it for the purposes set out in this
document or for operational purpose or until you stop giving us your express consent.

How do you contact us if you have a concern or want to complain?

If you have any concerns, we would be happy to address them and work towards resolving them.
You can contact us by:

N.B. If you are contacting us, please provide a way for us to reply to you