1. Introduction

1.1. This privacy policy (“Policy“) sets out how The Hub Exchange Limited, whose registered offices are at 843 Finchley Road, London, NW11 8NA collect and process information about you when you visit our website (“Website“), our mobile application (“App”) and any websites, branded pages on third party platforms (such as LinkedIn or Twitter) and applications accessed or used through such websites or third party platforms (“the HUBX Sites”), which are operated by or on behalf of the Hub Exchange Limited, its subsidiaries and/or affiliated companies (hereinafter, “we“, “us“, “our“). By continuing to use the HUBX sites, you consent to your information being processed in accordance with this Policy.

1.2. Your right to privacy is important to us. This Policy sets out how we use and protect any information that you give us when you use the HUBX Sites. We are committed to ensuring that your privacy is protected. When we ask you to provide certain information by which you can be identified when using the HUBX sites, then you can be assured that it will only be used in accordance with this Policy.

1.3. We may amend this Privacy Policy by giving you notice via the Platform. By continuing to use the HUBX sites you confirm your acceptance of the relevant changes.

1.4. If you have any questions, concerns or complaints about this Policy or our handling of your personal information, please contact us by email on support@hubx.capital.

2. Information Collected

2.1. Information you give us. You may give us information, including information that can identify you (“Personal Information“), when you use the HUBX sites, correspond with us or fill in an online form. Where we request information from you, we will collect the information set out in the relevant forms or pages, for example your full name, title, organisation, email address, location and phone number. You may choose to provide additional information to us when you contact us or otherwise interact with us.

2.2. Information we collect automatically. When you visit the HUBX sites, we may automatically collect the following information: your IP address, log-in information, location information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from the HUBX sites, products you viewed or searched for, download errors, length of visits to certain pages and page interaction. We collect information automatically through the use of various technologies, including through “cookies”, and this is explained further below.

2.3. Information we receive from other sources. We may receive information about you if you use any of the other services we provide on the HUBX sites, or from our affiliates. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them (including information that is publicly available).

3. Use of Personal Information

3.1. We use the personal information that you provide to us via the HUBX sites, or that we collect automatically for the purposes of:

(a) enabling you to use the HUBX sites and make requests via the HUBX sites;

(b) providing and personalising our services including to build a matching suggestion based on objective inputs;

(c) dealing with your inquiries and requests;

(d) administering orders and accounts relating to our clients;

(e) maintaining information as a reference tool or general resource;

(f) providing you with information about products and services;

(g) administrative and internal operations, including troubleshooting purposes;

(h) sending you marketing materials (should you request to receive marketing materials from us);

(i) ensuring that content from the HUBX sites is presented in the most effective manner for you and your devices; and

(j) keeping the HUBX sites safe and secure.

3.2. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

4. How to opt in or opt out of direct marketing

4.1. We may use the information you give us on the HUBX sites for direct marketing purposes to provide updates; newsletters; events; or other communications that we think may interest you. Where required by law, your prior consent will be obtained before sending direct marketing. If you have provided your personal information to us and you wish to change your preferences, please inform us at the address provided above if you do not wish to receive information about:

(a) our products or services;

(b) products or services offered by other companies within our group; or

(c). products or services offered jointly with or on behalf of other organisations.

4.2. Alternatively, you may opt-out of receiving additional information from us or related third parties at any time by contacting us at our address above. In any event, we will offer you the option to unsubscribe in every communication sent.

5. Disclosures

5.1. We may share your information with our affiliates The Hub Exchange d.o.o., Maleska 34, Belgrade, Republic of Serbia, for the purposes outlined in this Policy and with the third parties listed in this Policy. We may also share your information with third parties when: (1) it is necessary to involve a third party service provider in order to facilitate or extend our services; (2) explicitly requested by you (e.g. with social media networks); (3) required by a court order or any legal or regulatory requirement; (4) in connection with the actual or intended sale or transfer of a business; (5) to enforce our user agreement with you; (6) to ensure the safety and security of our users and third parties; and (7) to protect our rights and property and the rights and property of third parties.

6. Other Websites

6.1. The HUBX sites may contain links to other websites which are outside of our control. Where we provide links to other websites, we do so for information purposes only. The other websites are outside our control and are not covered by this Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may be different to this Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

6.2. On some pages of the HUBX sites, third parties that provide content, applications or plug-ins through the HUBX sites may track your use of content, applications and plug-ins or customize content, applications and plug-ins for you. For example, when you click to access our page on social media site by clicking on the button (e.g., LinkedIn or Twitter), the social network that has created the button may record that you have done this. For more information on social media plug-ins on the HUBX sites, see the Cookie Policy.

7. Information security

7.1. We apply appropriate security measures to protect your personal information that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers.

8. Internet-based Transfers

8.1. Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of information on an international basis. While we generally store all of the personal information that we collect about you through the HUBX sites in your region (for example for European visitors, in the European Economic Area), it is possible that your personal information will be transmitted to parties outside your region (where data protection laws may be different). If such transfer happens, we ensure that it takes place in compliance with contractual or other measures to protect the information.

9. Subject Access Rights

9.1. You have a right to a copy of and details of the personal information we hold about you. If you wish to obtain a copy of personal information that we hold about you, please contact us at the email address above. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond within an appropriate timeframe and, in any event, within any timescales required by law. A charge of £10.00 will be made by us for providing this information.

9.2. For further Information about your rights and the Data Protection Act 1998, please see the Information Commissioner’s website at www.ico.gov.uk.

10. Use of Cookies

10.1. We collect information automatically through the use of “cookies”. Cookies are small text files containing small amounts of information that a website can send to your browser, which may then be stored on your computer as a tag that distinguishes your computer but does not name you. Some of the HUBX sites pages use cookies to better serve you when you return to the HUBX sites. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the HUBX sites.
For further information about the specific cookies used on the HUBX sites, please refer to our Cookies Policy. You can also find more information about cookies generally by visiting www.aboutcookies.org.

11. Data Retention

11.1. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. However, please be advised that we may retain some personal information that you have provided to us, for instance if doing so is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.