LAST MODIFIED: December 22, 2020

This Privacy Policy applies to “www.hub.inc” (the “Website”) and the technical sales engagement platform service at app.hub.inc (the “Services”), which are owned and operated by Hub Technical Sales Inc. (“Hub”). At Hub, we are committed to maintaining the confidentiality and security of any Personal Data about our users. “Personal Data” is any information that relates to an identified or identifiable individual. Your privacy is always at the top of our priorities, and we are focused on protecting it from unauthorized access.

This Privacy Policy supplements our Terms of Service and spells out how we collect, use, and disclose information from or about you through our Website and the Services. You can access the Services via our website www.hub.inc, accounts.hub.inc, applications on Devices, APIs, and third parties. A “Device” is any device used to access the Services, including without limitation a computer, mobile phone, tablet, or other electronic device. By using our Services, you are consenting to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. The use of information collected through our Services shall be limited to the purpose of providing the service for which you have engaged Hub.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact [email protected].

The Information We Collect and Store

Hub employees and consultants are prohibited from viewing the content of the data you import into your Hub account, except as provided in this Privacy Policy. Of course, in the case that you request our help to resolve your support issues relating to that data, and only after receiving your permission, Hub employees and consultants may access the relevant data.

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.

If you provide such information and Personal Data, during registration and otherwise, you are giving Hub permission to use, share, and store it in a manner consistent with this Privacy Policy.

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 protected].

Your Data and Other Information About You

With your permission (which you grant when you sign up for or begin using our Services), Hub collects and stores information you provide or that we collect in order to administer our Services and/or as otherwise described in this Privacy Policy or our Terms of Service. If you or another user uploads a file to Hub that has been previously uploaded by you or another user, we may associate all or a portion of the previous file with the applicable accounts rather than storing duplicates.

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 [email protected].

Log Data

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.

Cookies

Hub and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website or Services.

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

Our website includes social media features, such as the Facebook Like button and widgets, such as the “Share This” button for Twitter and LinkedIn. These features may collect your IP address and the page you are visiting on our site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

GDPR Privacy

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.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • 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.

CCPA Privacy

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

Under this Privacy Policy, and by law if you are a resident of California, you have the following rights:

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

We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services’ features). These third parties may have access to your information for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. As of the date this policy went into effect, we use Amazon’s S3 storage service to store some of your information (for example, your files). You can find more information on Amazon’s data security from the S3 site.

Third-Party Applications

Our website includes links to other websites whose privacy practices may differ from those of Hub. As of the date this policy went into effect, Hub has never and will not share your information with a third-party application. If you submit Personal Data to any of those websites, your information is governed by their privacy policies. In the future, with your consent, we may share your information with a third-party application (for example when you choose to access our Services through such an application). We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy that is acceptable to you. We strongly advise you to review the privacy policy of every site you visit.

Compliance with Laws and Law Enforcement Requests; Protection of Hub’s Rights

We may disclose to third parties data stored in your Hub account and information about you that we collect only in the ways that are described in this Privacy Policy and when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request, such as to comply with a subpoena; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of Hub or its users; or (d) to protect Hub’s rights. If we provide any data stored in your Hub account to a law enforcement agency, we will remove Hub’s encryption from the information before providing it to law enforcement. However, Hub will not be able to decrypt anything that you encrypted prior to uploading it to Hub.

Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email, sign in notification, and/or a prominent notice on our website) if that happens or if your information otherwise becomes subject to a different privacy policy in lieu of this one. We will also notify you of choices you may have regarding the information.

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 protected] or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your inquiry within 30 days.

Data Retention

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.

Choice/Opt-Out

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 [email protected].

Blogs

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 protected]. 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.

Security

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 [email protected] 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.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected], or at Hub Technical Sales Inc., 3527 Mt. Diablo Blvd. Suite 285, Lafayette, CA 94549. Or by calling at 1(888) 499-6799.

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.

Changes to our Privacy Policy

If we make a change to this privacy policy, we will provide you with notice (for example, by email, a sign-in notification, or some other means) prior to the change becoming effective. By continuing to use the Services after those changes become effective, you are agreeing to be bound by the revised Privacy Policy; if you do not agree to the change, simply don’t use the Services after the change is effective, in which case the change will not apply to you.

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.

Choice

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.