1.1. Hub IQ, LLC, hereafter referred to as “Provider”, is committed to safeguarding the privacy of those who use the Provider’s Software as a Service (Saas) offerings, hereafter referred to as “Services”. This policy details how the Provider will treat the personal information of those who use the Services.
1.2. A person who registers for the Provider’s Services will hereafter be referred to as “User”.
2. COLLECTING PERSONAL INFORMATION
2.1. The Provider may collect, store and use the following kinds of personal information:
(a) information about the User’s computer and about the User’s use of the Services (including, but not limited to, the User’s IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Services navigation paths);
(b) information that the User submits to the Provider when registering for the Services (including, but not limited to, the User’s name, company, job title, physical address, email address, phone number, mobile phone number);
(c) information that the User submits to the Provider for the purpose of subscribing to the Provider’s email notifications, text message notifications, and/or newsletters (including, but not limited to, the User’s name, email address, and mobile phone number);
(d) information that the User submits to the Provider when using the Services, or that is generated in the course of the use of the Services (including the timing, frequency and pattern of Service use);
(e) information relating to any purchases the User makes of the Providers Services or any other transactions that the User enters into through the Services (including, but not limited to, the User’s name, address, telephone number, email address and credit card details);
(f) information that the User submits for publication on the internet while using the Services;
(g) information contained in or relating to any communication that the User sends to the Provider or sends through the Services (including the communication content and metadata associated with the communication); and
(h) any other personal information that the User chooses to send to the Provider.
2.2. Before the User discloses to the Provider the personal information of another person, the User must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. USING PERSONAL INFORMATION
3.1. Personal information submitted to the Provider through the Provider’s Services will be used for the purposes specified in this policy.
3.2. The Provider may use the User’s personal information to:
(a) administer the Provider’s Services and business;
(b) personalize the Provider’s Services for the User;
(c) enable the User’s access to, and use of, the Services;
(d) send statements, invoices and payment reminders to the User, and collect payments from the User;
(e) send the User non-marketing commercial communications;
(f) send the User email and/or text message notifications that the User has specifically requested;
(g) send the User the Provider’s email newsletter, if the User has requested it (the User can inform the Provider at any time if the User no longer requires the newsletter);
(h) send the User marketing communications relating to the Services which the Provider thinks may be of interest to the User, by mail, by email, by text message or similar technology (the User can inform the Provider at any time if the User no longer require marketing communications);
(i) provide third parties with statistical information about the Provider’s Users (but those third parties will not be able to identify any individual User from that information);
(j) deal with inquiries and complaints made by or about the User relating to our Services;
(k) keep the Services secure and prevent fraud; and
(l) verify compliance with the Terms & Conditions governing the use of the Provider’s Services (including monitoring messages sent through our Services).
3.4. The Provider will not, without the User’s express consent, supply the User’s personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. DISCLOSING PERSONAL INFORMATION
4.1. The Provider may disclose the User’s personal information to any of the Provider’s employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2. The Provider may disclose the User’s personal information to any member of the Provider’s group of companies (this means the Provider’s subsidiaries, the Provider’s ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3. The Provider may disclose the User’s personal information:
(a) to the extent that the Provider is required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend the Provider’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that the Provider is (or is contemplating) selling to; and
(e) to any person who the Provider reasonably believes may apply to a court or other competent authority for disclosure of that personal information where, in the Provider’s reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4. Except as provided in this policy, the Provider will not disclose the User’s personal information to third parties.
5. INTERNATIONAL DATA TRANSFERS
5.1. Information that the Provider collects may be stored and processed in, and transferred between, any of the countries in which the Provider operates in order to enable the Provider to use the information in accordance with this policy.
5.2. Information that the Provider collects may be transferred to countries/territories which do not have data protection laws in force.
5.3. Personal information that the User publishes on the Services, or submits for publication on the Services, may be available, via the internet, around the world. The Provider cannot prevent the use or misuse of such information by others.
5.4. The User expressly agrees to the transfers of personal information described in this Clause 5.
6. RETAINING PERSONAL INFORMATION
6.1. Personal information that the Provider processes for any purpose or purposes will be stored in the Provider’s database and will be stored for as long as needed to fulfill that purpose or those purposes.
6.2. The provider will retain information and documents (including electronic documents) containing personal data:
(a) to the extent that the Provider is required to do so by law;
(b) if the Provider believes that the information and/or documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. SECURITY OF PERSONAL INFORMATION
7.1. The Provider will take reasonable technical and organizational precautions to prevent the loss, theft, misuse or alteration of the User’s personal information.
7.2. The Provider will store all the personal information the User provides on the Provider’s secure (password- and firewall-protected) servers.
7.3. All electronic financial transactions entered into through the Provider’s Services will be protected by encryption technology.
7.4. The User acknowledges that the transmission of information over the internet is inherently insecure, and the Provider cannot guarantee the security of data sent over the internet.
7.5. The User is responsible for keeping the User’s password for accessing the Services confidential; the Provider will not ask the User for the User’s password (except when the User logs in to the Services).
8.1. The Provider may update this policy from time to time by publishing a new version on the Provider’s website.
8.2. The User should check the Provider’s website occasionally to ensure that the User is satisfied with any changes to this policy.
8.3. The Provider may notify the User of changes to this policy by email at the Provider’s sole discretion.
9. THE USER’S RIGHTS
9.1. The User may instruct the Provider to provide the User with any personal information the Provider holds about the User; provision of such information will be subject to:
(a) the payment of a fee; and
(b) the supply of appropriate evidence of the User’s identity, as determined and requested at the Provider’s sole discretion.
9.2. The Provider may withhold personal information that the User requests to the extent permitted by law.
9.3. The User may instruct the Provider at any time not to process the User’s personal information for marketing purposes.
9.4. In practice, the User will typically either expressly agree in advance to the Provider’s use of the User’s personal information for marketing purposes, or the Provider will provide the User with an opportunity to opt out of the use of the User’s personal information for marketing purposes.
10. THIRD PARTY SERVICES
10.1. The Provider’s Services includes hyperlinks to, and details of, third party Services.
10.2. The Provider has no control over, and is not responsible for, the privacy policies and practices of third parties.
11. UPDATING INFORMATION
11.1. The User should let the Provider know if the personal information that the Provider holds about the User needs to be corrected or updated. Some of the User’s information can also be updated in the “My Account” section of the customer dashboard after login.
12.2. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.3. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.4. Cookies do not typically contain any information that personally identifies a User, but personal information that the Provider stores about the User may be linked to the information stored in and obtained from cookies.
12.5. The Provider uses both session and persistent cookies in the Services.
12.6. Most browsers allow the User to refuse to accept cookies. However, blocking all cookies will have a negative impact upon the usability of many websites.
12.7. If the User blocks cookies, the User will not be able to use all the features in the Provider’s Services.
12.8. The User can delete cookies already stored on the User’s computer. However, deleting cookies will have a negative impact on the usability of many websites, including on our Services.
13.1. This document was created using a template from SEQ Legal (http://www.seqlegal.com).