This policy is effective as of 1 November 2019
Your privacy is important to us. It is INHUBBER UG (haftungsbeschränkt)’s policy to respect your privacy regarding any information we may collect from you across our website, app.inhubber.com, and other sites we own and operate.
We use the following terms in this data protection declaration:
A. Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person shall be considered identifiable if he can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
B. Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing” means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.
D. Limitation of processing
Limitation of processing is the marking of stored personal data with the aim of limiting their future processing.
Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.
Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
G. Controller or data controller
The controller or data controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or controllers may be designated in accordance with Union law or with the law of the Member States on the basis of specific criteria.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the course of a specific investigation task under Union law or the law of the Member States shall not be considered as recipients.
J. Third parties
Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor.
Consent shall mean any voluntary, informed and unequivocal expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, stating his or her intention to give his or her consent to a particular case.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
When you register for an account, we may ask you for your contact information, including information such as name, e-mail address. If you choose to invite a business partner to our services, you will need to enter your business partner’s email address and we will need to collect it so that we can send them an invitation to register for our services.
Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data, and other metrics, as well as other types of information, created or generated, as users interact with our services.
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
we need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
E.g. After deactivation of your account, we keep users Name, email address, blockchain address (generated by our system) and the hash of the password to ensure it’s functionality and fulfill our contractual obligations to the user in question and users he collaborated with on the platform.
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
We may disclose personal information to:
third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, error loggers, maintenance or problem-solving providers,, professional advisors and payment systems operators; and our employees, contractors and/or related entities.
The personal information we collect is stored and processed where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties. We are doing our best to ensure that all personal Information we acquire does stay on the servers within the the European Economic Area border.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.
Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you.
Where possible, we will provide this information in CSV format or another easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details above. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details above and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details above or opt-out using the opt-out facilities provided in the communication.
The provision of signing with Inhubber is subject to the Customer acknowledging and agreeing to the following:
a) The term Document includes all contract types and formats that are signed electronically with Inhubber.
b) Inhubber permits the creation and signing of documents. Nothing in this service shall be construed to make Inhubber a party to any document processed by Inhubber and Inhubber makes no warranties or representations as to the transactions to be effected by any document.
c) In the context between Inhubber and the Customer, the Customer has sole responsibility for controlling the content, quality and format of all Documents. All documents, together, stored by Inhubber on the system are stored in encrypted form, Inhubber has no control over or access to the content.
d) Some types of documents may be exempt from the laws governing electronic signatures (e.g. wills and family law agreements). Inhubber is not responsible or liable for making any determination as to whether a document or agreement falls within any exemption to applicable electronic signature laws; or whether it can be validly signed by electronic signatures;
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may continue to use your personal information according to this policy.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
The materials appearing on the website could include technical, typographical, or photographic errors. INHUBBER UG (haftungsbeschränkt) does not warrant that any of the materials on its website are accurate, complete or current. INHUBBER UG (haftungsbeschränkt) may make changes to the materials contained on its website at any time without notice. However, INHUBBER UG (haftungsbeschränkt) does not make any commitment to update the materials.