At HUBUC we take your privacy very seriously. By visiting our site and using our services, you are accepting our guidelines, so please take a few minutes to read it over carefully.
3. What is Personal Data?
Personal data is widely defined by European Data Privacy law and includes all types of information that directly or indirectly can identify a natural person. This means that name, address, phone number are considered personal data, but that log data, encrypted data or other types of electronic ID such as an IP-Address can also be classified as personal data, if they can be connected to a natural person.
4. What is Processing of Personal Data?
Processing is similarly defined very widely by European law and includes almost every action taken in relation to personal data - for example collection, registration, organization, structuring, storage, adaption, transfer or deletion.
This policy does not cover personal data that we process on behalf of our customers - the legal agreements which relate to this processing can be found at Hubuc.com/legal - namely our Terms and Conditions, in conjunction with our Data Processing Addendum which we strongly encourage our customers to sign and return to us.
6. Who’s Data Does Hubuc Control?
6.1 Representatives of Customers and Hubuc users: Hubuc is also the data controller in relation to both account Administrators as well as in regard to the personal data provided by Hubuc users when accepting an Administrators’ invitation and activating their Hubuc profile.
6.2 Executive Directors, LLP Members or Designated Members, Board Members, Beneficial Owners and other individuals within the scope of Hubuc’s Know-Your-Customer (KYC) policy: Hubuc is the data controller for personal data obtained when our customers register for our services and during the registration process provide information regarding their corporate structure and permit us to pull applicable data from public registries.
6.3 Leads: Hubuc is also the data controller for representatives of potential customers who are either website visitors who submit personal data through any of the forms on our websites or otherwise contact us through our customer support or people who might be interested in our services and/or products whose information we have received from other sources e.g. Facebook, LinkedIn or similar.
6.4 Prospects: In some situations you may have been contacted by a Hubuc Business Development Representative who has determined that you may be interested in a demonstration and/or trial of the Hubuc service. In this case some limited personal information may be controlled and processed by Hubuc to offer this demonstration and answer any questions you may have about our product.
6.5 Website visitors and individuals interacting via webchat, emailing or telephoning our support: Hubuc controls some personal data of individuals visiting our website, particularly behavioural and tracking details: e.g. location data, behavioural patterns, personal preferences, IP-number, cookie identifiers, unique identifier of devices you use to access and use the services and our websites. Further, Hubuc controls personal data regarding individuals who interact with our team either via webchat, email or telephoning our support.
6.6 Candidates: Hubuc is the data controller for candidate’s personal data obtained in the recruiting process.
7. Types of data, purposes of processing and lawful basis for processing
7.1 Representatives of customers and HUBUC users
Categories of personal data we may process
For existing customers:
7.2 Executive Directors, LLP Members or Designated Members, Board Members, Beneficial Owners and other individuals within the scope of Hubuc’s Know-Your-Customer (KYC) policy
Categories of personal data we process
7.3 Leads, website visitors, individuals interacting via webchat, emailing or telephoning our support
Categories of personal data we may process
For existing customers visiting our website:
7.4 Prospects and referrals
Categories of personal data we may process
Categories of personal data we may process
8. What personal data does Hubuc collect from third parties?
We process personal data obtained from selected third parties such as fraud detection agencies, other financial institutions and other information providers, and from publicly available sources including population registers, company registration offices, enforcement authorities, as well as services such as LinkedIn. Further, in connection with payment processing we collect information from third parties such as banks and payment service providers.
Other external resources from which we may collect information are sanctions lists, registers held by credit-rating agencies and other commercial information providers providing information on e.g. beneficial owners and politically exposed persons.
9. Ways we will never use personal data
We will not share personal data with third parties for them to use for their own marketing purposes without ensuring that there is a lawful ground to do so.
We do not sell your personal data to third parties.
10. Automated decision making
Currently, HUBUC does not carry out any such processing that is defined as solely automated decision making, including profiling, under the General Data Protection Regulation (“GDPR”) that has ”legal effects” or has otherwise significant effects.
11. Policy regarding sharing of data with third parties
Third party service providers Where necessary to provide our services we may disclose personal data about you to identify you and perform an assignment or agreement with companies that we cooperate with in order to perform our services. These services include, but are not limited to, secure identification solutions and between parties in the financial system such as banks.
Our designated banks and relevant card networks may also come to process your personal data for their own fraud prevention and risk management.
Third parties that are data processors Some of the third parties that we share personal data with are data processors. A data processor is a party that processes personal data on our instructions and on our behalf.
We collaborate with carefully vetted suppliers, which include processing of personal data on behalf of us. Examples include suppliers of IT development, maintenance, hosting and support but also suppliers supporting us with marketing and customer support.
When we share your personal data with data processors we only share them for purposes compatible with the purposes for which we have collected the data (such as performance of a contract). We always control all data processors and ensure that they can provide adequate guarantees as regards security and confidentiality of personal data. We have written agreements in place with all data processors through which they guarantee the security and confidentiality of personal data that they process on our behalf and limitations as regards third country transfers.
Third parties that are data controllers Some of the third parties that we share personal data with are independent data controllers. This means that we are not the ones that dictate how the data that we provide shall be processed. Examples are authorities, acquirers and other financial institutions. When your data is shared with independent data controllers their data policies and personal data processing principles apply.
Authorities We also disclose personal data to authorities to the extent we are under a statutory obligation to do so. Such authorities include tax authorities, police authorities, enforcement authorities and supervisory authorities in relevant countries. We may also be required to provide competent authorities information about your use of our services, e.g. revenue or tax authorities, as required by law, which may include personal data such as your name, address and information regarding card transactions processed by us on your behalf through your use of our services.
12. Third country transfers?
If we transfer your personal data to a third country, i.e. a country outside of the European Economic Area (“EEA”) we will comply with all applicable laws in respect of such transfer, including making sure that your personal data is kept secure, and ensure that appropriate safeguards are in place to ensure there is adequate protection.
Our preferred basis for transfer is the use of Standard Contractual Clauses. You can access a copy of the relevant EU model-clauses used by us for transfers by browsing to www.eur-lex.europa.eu and searching for 32010D0087.
If we transfer your personal data to a third country, i.e. a country outside of the European Economic Area (“EEA”) we will comply with all applicable laws (including Article 46 of the GDPR) in respect of such transfer, including making sure that your personal data is kept secure, and ensure that appropriate safeguards are in place to ensure there is adequate protection.
13. Security and integrity
We take security seriously.
We always process personal data in accordance with applicable laws and regulations, and we have implemented appropriate technical and organizational security measures to prevent that your personal data is used for non-legitimate purposes or disclosed to unauthorized third parties and otherwise protected from misuse, loss, alteration or destruction.
The technical and organizational measures that we have implemented are designed to ensure a level of security appropriate to the risks that are associated with our data processing activities, in particular accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data including access control to premises, facilities, systems and data, disclosure control, input control, job control, availability control and segregation control.
14. Storage of personal data
If we keep your data for other purposes than those of the performance of a contract, such as anti- money laundering purposes, bookkeeping and regulatory capital adequacy requirements, we keep the data only if necessary and/or mandated by laws and regulations for the respective purpose.
The data retention obligations will differ within the Hubuc Group subject to applicable local laws.
See below for examples of the retention periods that we apply:
The above is only for explanatory purposes and the retention times may differ from country to country.
15. Your rights
While HUBUC is in control of some of your personal data it’s important that you know that you have a range of important rights under EU law.
Please note that there are exceptions to these rights, so access may be denied e.g. where we are legally prevented from making a disclosure.
Your rights in connection to your personal data
Please note that we may ask you to provide further information about yourself in order for us to be able to identify you and handle the request in an efficient and secure way. This will sometimes oblige you to send in a signed copy of a valid ID.
Please note that due the fact that we provide financial services we are in many cases obliged to retain personal data on you during your customer relationship, and even after that, e.g. to comply with a statutory obligation or where processing is carried out to manage legal claims. This means that we will keep any KYC data that we have about you during such a time period as we are required according to applicable anti-money laundering regulations.
Where our lawful basis for processing your data is our legitimate interests, you have the right to object to the processing of your data if:
This means that we will cease such processing unless we:
If you have received marketing from us, you may at any time object to the marketing by contacting us at [email protected] or opt out by following the instructions in the marketing material.
We will send a copy of your data in a commonly used and machine-readable format to you or a person/organization appointed by you, where technically feasible and where the exercise by you of this right does not adversely affect the rights and freedoms of others.
16. How to exercise your rights
Send us an email at [email protected] and we’ll do our best to help.
You can also always contact us by sending a letter to B2B Fintech Solutions SL, Att: Privacy Function, Cl Prat De La Riba 11 B, 2-1, 08150, (Parets Del Valles) Barcelona, Spain.
If you are unhappy with our processing of your personal data you may lodge a complaint with or contact the Spanish Data Protection Authority (AEPD), at C/ Jorge Juan, 6, 28001-Madrid, phone no. +34 901 233 144. You may also seek a remedy through local courts if you believe your rights have been breached.
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18. Third-party websites and services
Last updated: October 01, 2021
This Cookies Policy explains what Cookies are and how We use them. You should read this policy so You can understand what type of cookies We use, or the information We collect using Cookies and how that information is used.
We do not store sensitive personal information, such as mailing addresses, account passwords, etc. in the Cookies We use.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
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The use of the Cookies
Type of Cookies We Use
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