LAST MODIFIED: December 22, 2020
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact firstname.lastname@example.org.
The Information We Collect and Store
We may collect and store the following information when running the Hub Service:
Information You provide
When you register for an account, we collect some Personal Data, such as your name, phone number, email address, and home and/or business postal addresses. You may also ask us to import your contacts history by giving us access to your third-party services (for example, your customer relationship management account) or to use your social networking information if you give us access to your account on social network connection services. You may also have the option to import and update versions of your calendar, product information, and email history, and you can later choose to upload files to, or provide comments through, Hub. When you invite others to join Hub by using the Services, we send them an email for that invitation at the email addresses provided.
When we configure and customize deals, or manage and perform recurring billing, we may also ask you to provide information such as your bank account number; credit card number; national ID number, insurance number, social security number; taxpayer identification number, tax file number, passport number, and driver’s license number.
Collection and Use of 3rd Party Personal Data
You may also provide Personal Data about other people, such as their email address. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.
If you believe that one of your contacts has provided us with your Personal Data and you would like to request that it be removed from our database, please contact us at email@example.com.
Your Data and Other Information About You
User Data Supplementation
We may receive additional demographic information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us Personal Data about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Hub obtains this business contact and company information from third-party sources, such as business intelligence platforms. The information obtained by these third-party sources is from publicly available sources such as news articles. This information is used to support Hub’s marketing and sales efforts. The Hub sales team may contact you based on this information to gauge your company’s interest in Hub’s services and technology solutions. You may opt-out of these communications at any time by clicking the unsubscribe link provided in the email or by sending a request to the Hub Technical Support team by emailing firstname.lastname@example.org.
When you use the Service, we automatically collect certain information from your Device, its software, and your activity using the Services. This may include, for example (but without limitation), the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before or after you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata, and interactions with the Service, Internet service provider, referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. We may also collect information that your browser sends whenever you visit the Website or when you access the Services through a mobile device.
We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Social Media Widgets/Buttons
For purposes of the General Data Protection Regulation (“GDPR”), Personal Data means any information relating to you such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
Legal Basis for Processing Personal Data under GDPR
In the course of using the Services, we may process Personal Data under one or more of the following GDPR lawful bases:
- You have given consent to the processing of your Personal Data for one or more specific purposes
- Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract
- Processing is necessary for compliance with a legal obligation to which the Hub is subject
- Processing is necessary in order to protect your vital interests or the vital interests of another natural person
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Hub
- Processing is necessary for the purposes of the legitimate interests pursued by Hub
In any case, Hub will gladly help to clarify the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights Under the GDPR
Hub undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.
- Request access to Your Personal Data. The right to access, update or delete the information Hub has on You. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Hub to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that Hub holds about You. You have the right to have any incomplete or inaccurate information Hub holds about you corrected.
- Object to processing of Your Personal Data. This right exists where Hub is relying on a legitimate interest as the legal basis for its processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where Hub is processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask Hub to delete or remove Personal Data when there is no good reason for Hub to continue processing it.
- Request the transfer of your Personal Data. Hub will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Hub to use or where Hub used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, Hub may not be able to provide you with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting Hub. Please note that Hub may ask you to verify your identity before responding to such requests. If you make a request, Hub will try its best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about Hub’s collection and use of your Personal Data. For more information, if you are in the European Economic Area (“EEA”), please contact your local data protection authority in the EEA.
For purposes of the California Consumer Privacy Act (“CCPA”), Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
Your Rights under the CCPA
The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits you to request and obtain from Hub information regarding the disclosure of your Personal Data that has been collected in the past 12 months by Hub or its subsidiaries to a third-party for the third party’s direct marketing purposes.
The right to say no to the sale of Personal Data. You also have the right to ask Hub not to sell your Personal Data to third parties. Hub does not sell your Personal Data to third parties so you have no need to request this restriction.
The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom we share Personal Data
- The specific pieces of Personal Data we collected about you
The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of you consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email or call us.
Hub will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Personal Data is or may be used for the following purposes:
- To provide and improve our Service.
- To administer your use of the Service
- To recommend follow-up reminders, assign tasks, or personalize the service,
- To provide or offer software updates and product announcements.
- To ensure our legal compliance obligations.
If you no longer wish to receive communications from us that are not required for the Services, please follow the “unsubscribe” instructions provided in any of those communications or update your account settings information.
Information Sharing and Disclosure by Us (Do Not Sell My Information)
We do not sell Personal Data to third parties.
If you are a California resident our default cookie settings may constitute a sale of Personal Data.
Service Providers, Business Partners and Others
Compliance with Laws and Law Enforcement Requests; Protection of Hub’s Rights
Changing or Deleting Your Information
- Upon request Hub will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. If you are a registered user, you may review, update, correct, or delete certain Personal Data provided in your registration or account profile by changing your account settings. If your Personal Data changes, or if you no longer desire our Services, you may update or delete it by making the change in your account settings, although (in some cases) we may retain copies of your information if required by law, to protect our rights, or if it is not technically reasonably feasible to remove it. You may at any time withdraw any consent that you have provided to us to process your information, or exercise any of the following rights by contacting us as provided below. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
For questions about your Personal Data on our Services, please contact email@example.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your inquiry within 30 days.
Hub will retain Personal Data we process on your behalf and on behalf of your customer data for as long as needed to provide the Services to you. Our intention is to retain your information for as long as your account is active or as needed to provide you with the Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, you may delete your account. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, that Hub may retain your Personal Data for longer where there is a legal obligation, contractual, or legitimate interest, unless these interests are overridden by the individual’s fundamental rights; in those cases, Personal Data will be removed once it is no longer needed for those purposes. In addition, we do not provide access, transfer, change, or delete information from our servers’ files where that right adversely affects the rights of others.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at firstname.lastname@example.org.
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Data from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your Personal Data. If this is the case, we will let you know and indicate why.
Hub stresses its privacy and security standards. Although no one can guarantee absolute security, we regularly re-evaluate our privacy and security policies in order to adapt to new challenges. We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Services do not respond to Do Not Track (“DNT”) signals. Some third party websites do keep track of your browsing activities, however. If you are visiting such third-party websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. If you are a California resident and you would like to request removal of such data, you can contact us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Children’s Online Privacy Protection Act (COPPA)
Our Services are not directed to persons under 13. We do not knowingly collect Personal Data from children under 13 as is consistent with the Children’s Online Privacy Protection Act (“COPPA”). If you, as a parent or guardian, become aware that your child has provided us with Personal Data without your consent, you should contact us at firstname.lastname@example.org and we will remove your child’s information from our database. Additionally, if we become aware that a child under 13 has provided us with Personal Data, we will take steps to delete such information from our files.
If you are a European Union data subject, you have the right to lodge a complaint with a supervisory authority concerning Hub’s data processing activities. If you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Information Related to Data Collected through the Hub Platform
Hub collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes.
Hub acknowledges that you have the right to access your Personal Data. We collect information for our clients. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.
Service Provider, Sub-Processors/Onward Transfer
Hub may transfer Personal Data to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice, as well as the service agreements with our Clients. A list of Sub-Processors can be made available upon request.
Access to Data Controlled by our Clients
Hub has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the Hub’s Client (the data controller). If the Client requests Hub to remove the data, we will respond to the request within 30 business days.