Privacy and Cookie Policy

This policy was last updated in September 2021
ICO Registration Number: ZA780685

Who we are is owned and operated by Hugo Finley as a sole trader. We help clients in the capacity of charity consulting, start-up support, Course Creation and Delivery, GDPR Consulting and project managing website builds.

Where is processing your information, including in relation to our administration and website, for the purposes of data protection legislation, it is a controller of your personal information.


In plain English: You don’t have to share data, but without sharing it, we cannot provide you with services.

Providing us with personal data is purely consensual. You are not obligated under any laws to provide us with any personal data, but without providing such personal data, we cannot provide you with Services.

This privacy notice applies to the personal information we collect about you when you interact with HugeHug (for example when you use our Website or Services). It sets out:

  • what information we collect, and from whom;
  • how we use that information;
  • how long we keep your information;
  • whom we share your information with;
  • how your information is protected;
  • your rights in relation to the information we hold about you.

We keep this privacy policy under regular review, and we encourage you to periodically review this page for the latest information on our privacy practices. Any material changes will be notified to you by updating them on our websites, together with any such other methods as may be appropriate.

This Privacy Policy also extends to data that may be provided to us by clients and other parties who may provide us with data, or access to data, from time to time, in the course of dealing with that party.

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, or because you have consented to our use of your personal data, or because it is in our legitimate interests. Specifically, we may use and you consent to us using your data for the following purposes:

  • Providing and managing your access to my website;
  • Personalising and tailoring your experience on our website;
  • Providing you with cost guidance about our Services and/or goods;
  • Providing you with other information about our Services and/or goods;
  • Supplying our services and/or goods to you, which may include:
    • Access to the member’s section of this website;
    • Consulting with you;
    • IT support for your use of websites I have project managed for you.
  • Communicating online, through social media, by post, email or telephone or by any other means, with you;
  • Providing you with newsletters and other material, which may include marketing material, relevant to my services and/or goods, email or other means (provided that you may unsubscribe or opt-out at any time, and where practicable, we will include a link to facilitate that);
  • Analysing your use of our website & services to enable us to improve this website & services and your user experience.

1. What information does HugeHug collect?

Information you provide to me voluntarily
You may give us your personal information when you:

  • opt-in to receive email, or telephone communications from HugeHug by interacting with us in day to day correspondence;
  • use, or provide a comment on the HugeHug websites;
  • correspond with or contact us;
  • interact with us on social media platforms;
  • sign up to one of our newsletters or other communications;
  • otherwise interact with us or provide information to a third party to be referred to us.

Where we request information from you, HugeHug will collect the information set out in the relevant forms or pages, or as explained to you. You may choose to provide additional information to us when you contact us or otherwise interact with us or provide information to a third party to be referred to us.

Information we collect automatically
We, or the companies which work on our behalf, collect data related to visitors to our websites automatically, including what pages you have viewed, for how long and your website journey.

Information is also collected about how you arrived at our websites in the first place, including what links or adverts of HugeHug you have viewed or clicked on to reach this website or any search terms you have used. Where you see an advert for HugeHug outside of this website, for example on social media, we will place a cookie on your browser so that, when you access this website, we recognise that you have seen an advert for HugeHug elsewhere. Information collected automatically using cookies or other tracking technologies includes your IP address.

Information that is available publicly
Your personal information may be available to us from external publicly available sources: for example, geo-demographic information and information from public registers such as listed directorships, information from the electoral roll and press reports. In addition, depending on your privacy settings for social media services, we may access information from those accounts or services.

2. What types of information does HugeHug process?

We collect, store and use the following types of information:

  • your name, email address, postal address, phone number and social media identity;
  • correspondence you have had with HugeHug;
  • comments you have left on this websites;
  • your contribution to any research you take part in;
  • information about your computer/mobile device and your visits to and use of the HugeHug website, including for example your IP address;
  • details about you that are stored in documents in different formats, or copies of them; and
  • any other information shared with HugeHug as described in [section 1] above.

3. How does HugeHug use my information, and on what legal basis?

The following sections describe in more detail how HugeHug may use your information, and in particular the legal grounds on which we rely in doing so.

What we use your personal information for:
We use the information collected for a number of purposes, including:

  • to verify and manage your account;
  • to make and manage/receive payments;
  • to manage our relationship and communicate with you;
  • to respond to complaints and seek to resolve them;
  • to enhance your online experience;
  • to conduct research and surveys;
  • to better understand our clients and supporters in general;
  • to respond to individual experiences shared with us and for editorial content;
  • to understand your website journey, including what pages you have viewed and for how long;
  • to improve the effectiveness HugeHug’s advertising campaigns;
  • to administer and keep safe and secure HugeHug’s websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to train HugeHug’s contractors and measure the quality of the service we give you; and
  • to obey laws and regulations that apply to us.


The legal grounds we rely on to process your information

The legal grounds on which we rely are:

  • to fulfil our contractual obligations (for example in order to provide services requested by HugeHug’s clients and to contact you if a problem arises with them);
  • to pursue our legitimate interests (for example to facilitate your use of our websites, or for marketing);
  • your consent; and / or
  • to fulfil a legal duty.

Legitimate interests

When we rely on our legitimate interests, these are as follows:

  • keeping our records up to date;
  • charging for client accounts and services;
  • marketing our products and services;
  • administering our websites and keeping them safe and secure;
  • ensuring that content is presented in the most effective manner for you and your devices;
  • facilitating your use of my websites;
  • measuring the use of my websites and improving their content and accessibility;
  • measuring and understanding the effectiveness of advertising, and delivering relevant advertising to you;
  • tailoring content and my communications so that they are most relevant to you;
  • complying with legal and/or regulatory requirements;
  • identifying trends in customer/client behaviour;
  • informing and generating content (for my campaigns and policy work).

4. Who does HugeHug share my information with?

We, or one of the companies who work on our behalf, share your personal information with the following third parties:

Data processors

To help us fulfil contracts and to pursue our legitimate interests, we share your personal information with third parties who provide services to HugeHug or who act on our behalf, for instance, vendors, IT and other suppliers, research agencies, payment processors, financial institutions. We do not authorise these companies to use or disclose your personal information except for the purpose of providing the service we request of them. HugeHug is based in the UK, but some third-party data processors will be based outside of the European Economic Area (EEA).


We use SurveyMonkey for carrying out surveys of our customers to help improve our campaigns. You can read their privacy policy here.

We use as our website provider. You can read their privacy policy here.

Google Drive

We use Google Drive for our internal file storage. You can read their privacy policy here.


Gravatar allows users to use one Avatar on multiple websites and platforms. It is produced by Automattic. You can read their privacy policy here.

Google Analytics and Drive

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.

  • Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States

We use Google Analytics to measure traffic on our website. I also use Google Drive/Suite for all my admin tasks. Google has their own Privacy Policy which you can review here.

Note: If you’d like to opt-out of tracking by Google Analytics, visit the Google Analytics opt-out page


Other circumstances in which we will disclose your information

We will disclose your information to local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators when we have a legal obligation to do so or when we believe our compliance with the request to be fair, reasonable and lawful, eg to detect, prevent or investigate security breaches, fraud or other crimes.

We will also disclose your information to establish, exercise or defend legal claims, for example: (i) to enforce my Terms and Conditions; (ii) to ensure the safety and security of my users, consumers and third parties; and (iii) to protect our rights and property and the rights and property of my website visitors, consumers and third parties.

Location of third parties

Some potential recipients of your information might be located outside the European Economic Area (“EEA”), in jurisdictions that do not have the same data protection laws as those in the EEA. If we do transfer your information outside the EEA we will take appropriate steps to protect that information, which include:

  • transferring to third parties in jurisdictions that the European Commission has determined offers adequate protection for your information and information relating to adequacy decisions made by the European Commission are available here; and
  • entering into an agreement with the recipient, which includes clauses that the European Commission has determined offers adequate protection for your information (a template copy of which is available here).

5. How long is my information retained?

Whenever HugeHug collects or processes your personal data, we will only keep information about you for as long as I need to fulfil the purposes for which we are processing your information or for an appropriate retention period thereafter. At the end of that retention period, your data will either be deleted or anonymised. Examples of our retention periods are:

  • Where you are a client/customer, we would normally keep your information for the duration of your contract and then a period of up to seven years after you cease being a client/customer.
  • Where we need to keep your information for financial reporting obligations, we would normally keep it for seven years from the date of the last payment.
  • Where we need to keep your information relating to complaints you have made, we would normally keep it for seven years from the end of that matter.
  • All data pertaining to personal abuse, stalking, and harassment is kept until the legal authorities no longer require it to be kept.

6. What are my data protection rights?

You have the following rights in relation to your personal data:

  • Access: The right to request access to and a copy of your personal information (which can be done by emailing;
  • Restriction: You can ask us to pause processing your information in certain circumstances (eg you are disputing its accuracy);
  • Rectification: You can have any inaccuracies in your personal information corrected;
  • Deletion/right to be forgotten: You can ask us to delete all your personal information in certain circumstances (eg if the information is no longer necessary for the purposes for which it was collected);
  • Objection: You can object to us processing your personal information in certain circumstances;
  • Objection to marketing: Please see SECTION 7 (Marketing and advertising) below, for information about how to opt-out of direct marketing communications;
  • Portability: You can ask us to transfer your information electronically to you or another organisation in certain circumstances;
  • Withdrawal of consent: Where we rely on your consent to process your information, you can withdraw consent at any time, although this will not affect our uses of your personal information prior to the withdrawal of your consent; and
  • To lodge a complaint with the Information Commissioner’s Office (“ICO”) or other relevant supervisory authority: You can complain to the ICO at or other relevant supervisory authority about any aspect of our handling of your information.

More information about the right to complain can be found at If you have any questions about these rights, or you would like to exercise them, please contact us using the details within section 10 (How can I contact HugeHug about its privacy notice?) below.

Please be aware that you are under no obligation to provide us with your personal information. However, failure to do so may, in some circumstances, will prevent us from being able to provide you with services, or otherwise interact with you.

When exercising your data protection rights we may ask you to verify your identity in order to help us respond efficiently to your request.

If you would like to exercise any of the above rights, please email or write to us using the details outlined in section 10 (How can I contact HugeHug about its privacy notice?) below.

All of these rights are free to exercise and we will do our best to respond to you as quickly as possible and in any event, within 72 hours of receipt of your written request. We will inform you within 72 hours of receipt of such a request if we will need longer to respond, for example, due to the complexity of the request.

I want to make sure that your personal information is accurate and up to date. Please always let me know if you think that it is not and needs updating. Details of how to get in touch are in section 10 below.

7. Marketing and advertising

We may use the information you provide to send you communications about HugeHug’s Services or news. This might be by email with your consent marketing in furtherance of our legitimate interests.

You can change your marketing preferences at any time by clicking on the “[unsubscribe]” link in the footer of our emails, or by writing to us or emailing us at All details can be found in [section 10](How can I contact HugeHug about its privacy notice?) below. You can also unsubscribe from receiving any further marketing communications.

8. Third-Party Websites and social media

Where we provide links to other websites, we do so for information purposes unless otherwise indicated. The other websites are outside our control and are not covered by this privacy notice. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice, which may differ from ours.

On some pages of the HugeHug website, third parties that provide content, applications or plug-ins through these websites may track your use of content, applications and plug-ins or customise the content, applications and plug-ins for you. For example, when you share an article using a social media sharing button on our websites (e.g., Facebook or Twitter), the social network that has created the button will record that you have done this.


HugeHug and Hugo Finley have a Twitter page, managed by us at:

  1. HugeHug:
  2. Hugo Finley:

Twitter stores all its information and data on a remote secure server. This is a link to Twitter’s Privacy Policy.


Hugo Finley has his own profile on LinkedIn and HugeHug has a page too, they are as follows:

  1. Hugo Finley:
  2. Hugehug:

LinkedIn stores all its information and data on a remote secure server. This is a link to LinkedIn’s Privacy Policy.

9. Use of our websites by minors

In plain English: We don’t knowingly collect information about children.

I will not knowingly contact or engage with children under the age of 18. If you have reason to believe that a child under the age of 18 has provided me with their personal data, please contact me, and I will act in accordance with the applicable law.

10. How can I contact HugeHug about its privacy notice?

You can contact us by email as follows:


To find out more about HugeHug and who I am, please look at the About Section of

11. Changes to this Privacy Notice

HugeHug may need to update this Privacy Notice from time to time. You can see when the Privacy Notice was last updated by checking the date at the top of the page. A summary of changes can be found in this section, along with the date they were made.

If we make any updates, such as materially changing how we use your personal data, we will alert you as required by applicable privacy laws.

The privacy policy is reviewed annually in line with our risk assessment and Data Protection Impact Assessments.

September 2021 New privacy policy adopted.

September 2022 Privacy policy to be reviewed.

12. What can you do if you are unhappy with the way we have processed your personal data?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane

0303 123 1113 (local rate)

13. Cookies

A new cookies section is currently being edited. Please note that any pop up that lets you opt-out of cookies will add a cookie to say you have opted out of them, so we are looking at what to do about that.

We use cookies for the following purposes:

  • Necessary cookies – These cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
  • Functionality cookies – These cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and email in comment forms so you don’t have to re-enter this information next time when commenting.
  • Analytics cookies – These cookies are used to track the use and performance of our website and services.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as!/ or For more information about cookies, visit

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site. You can remove cookies stored in your computer via your browser settings. In addition, you may opt out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool or For more information about cookies, visit

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:

Apple Safari
Google Chrome
Microsoft Edge
Microsoft Internet Explorer
Mozilla Firefox
Android (Chrome)
iPhone or Ipad (Chrome)
iPhone or Ipad (Safari)

Hugehug.Net cannot provide legal advice and nothing on this website should be interpreted as such.

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