Last Updated: June 2023
HUBX respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our website at HUBX.CAPITAL (“Website”). For personal information that we collect when you use or interact with our services, please send a request and it can be made available. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
What does HUBX do?
HUBX is a Platform as a Service technology solution for the Private Capital Markets headquartered in the United Kingdom but with group companies all around the world. Our platforms enable private companies, professional firms and accredited investors to organise and execute private capital markets transactions in complete privacy.
What personal information does HUBX collect and why?
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including the United Kingdom and countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources (including; Third parties that provide services to us, such as system hosting, management, and support; data analysis; facilitation of advertisements; data backup; and data security and storage services; Competent governmental and public authorities, in each case to comply with legal or regulatory obligations or requests; and Other third parties as we believe necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce our terms and conditions; (d) to protect our operations and those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit damages that we may sustain), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we collect from third parties include: your Internet Protocol (IP) address; information about the browser or type of device you are using; data collected through cookies, pixel tags, and other similar technologies; the date and time of your visit; and the web page you visited immediately prior to visiting this Site. We also collect data about videos or other content you view on this Site, like the type and name of the content and the time viewed.
Who does HUBX share my personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies and service providers can be made available upon request.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to any other person with your consent to the disclosure.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us on SUPPORT@HUBX.CAPITAL.
Cookies and similar tracking technology
How does HUBX keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. [Specific measures we use include Authentication measures for access to all networks and devices, including where appropriate two factor authentication; Use of encryption or other suitable measures for access to network and devices; Differentiated and complex access rights including role- based access restrictions and ability to edit, download or copy; Access only granted on a "need-to-know" basis with minimum access right requirement; Regular review of the access controls in place; Approval process for access rights and process for removing access; Appropriate level of encryption for data in storage and transit in live production environment; Data is segregated for different processing purposes. Production data is always securely processed.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Specifically, our Website servers are located in Eastern Europe and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us on firstname.lastname@example.org.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us on email@example.com.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us on SUPPORT@HUBX.CAPITAL.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, United Kingdom, Switzerland and certain non-European countries - including the US and Canada - are available HERE.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: firstname.lastname@example.org. The data controller of your personal information is The Hub Exchange Limited, with ICO registration number ZA107192