Huble Data Privacy Statement

1. This Privacy Notice (“Notice”) describes how Huble collects, uses and discloses Personal Data. The Notice is intended to help you gain a quick understanding about what Huble does and how you can opt out of our database and the potential outcomes of remaining in our database.
   
   
2. Huble, in its capacity as Responsible Party and/or Operator, shall strive to observe and comply with its obligations  under applicable privacy laws. 

1. Huble collects Personal Data in connection with the services we offer and provide. This includes information collected directly from you as a Data Subject, as well as information we collect indirectly through our Direct Marketing campaigns and online through our websites (www.hubledigital.com), branded pages on Third Party platforms and applications accessed or used through such websites or Third Party platforms which are operated by or on behalf of Huble.
   
   
2. This Notice does not apply to Personal Data collected by any other means or in a different context, such as Personal Data of our employees, job applicants, contractors, or officers, nor to the information practices or Third Party companies who we may engage with in relation to our business operations (including, without limitation, their websites, platforms and/or applications) which we do not own or control. These Third Party sites may have their own privacy policy and terms & conditions, and we encourage you to read them before using them.
   
   
3. This Notice also does not apply to information we maintain in a manner that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, with a particular individual, and such information is not considered Personal Data. 

1. Within the scope of this Notice, Huble acts as a data controller for the Personal Data we process. This means that we decide how and why your Personal Data is collected and processed. 
   
   
2. On the other hand, we generally act as a data processor in connection with the Personal Data we process on behalf of our clients to provide our Services. If you are a Data Subject of a Huble client, our client’s privacy notice, rather than this Notice, will apply to the processing of your Personal Data. 
   
   
3. Huble will always collect Personal Data in a fair, lawful and reasonable manner to ensure that it protects the Data Subject’s privacy. Furthermore, we will also ensure that processing of Personal Data is based on legitimate grounds in a manner that does not adversely affect the Data Subject in question.

1. We may process your Personal Data on the basis of:
   
   1. Data Subject consent;
   2. in order to reply to your request submitted;
   3. processing is necessary to carry out actions for conclusion of a contract to which a Data Subject is involved;
   4. processing is necessary for pursuing the legitimate interests, such as our interest in marketing and selling our Services, or of a third party to whom information is supplied;
   5. our obligation to comply with applicable law; or
   6. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Huble. 
      
      
2. Where we process your Personal Data based on your consent, you may withdraw your consent at any time. However, this will not affect the lawfulness of our processing before your withdrawal of consent. It will also not affect our processing performed on any other lawful ground. 
   
   
3. If we receive your Personal Data as part of providing our Services to you based on a contract, we require certain Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the Services to you. 
   
   
4. Where Huble obtains your Personal Data from Third Parties, Huble will ensure that it obtains the consent of the Data Subject to ensure legitimate grounds for processing, or Huble will only process the Personal Data without explicit consent where Huble is lawfully permitted to so so in terms of clause 4.1 above.
   
   

1. We may collect or otherwise receive your Personal Data when:
   
   1. you visit and interact with our Website;
   2. you provide it to us directly as a client or prospective client, including by way of contacting us via telephone, email, mail, or a contact form, or live chat service on our Website;
   3. you click on one of our advertisements, social media posts, or open one of our emails;
   4. you register and attend one of our live events;
   5. we receive it from other affiliates; or
   6. we obtain it from publicly available sources.

1. We may process the following types of Personal Data about Website visitors:
   
   1. basic identifying information, such as your name and surname;
   2. contact information, such as your email address;
   3. professional information, such as your place of work; and
   4. identifiers and device information, such as your IP address and associated location, device ID, operating system, and website navigational information, such as information about your interaction with the Website, including cookies for targeted advertising.
      
      
2. We may process the following types of Personal Data in connection with our Services:
   
   1. basic identifying information, such as your name and surname;
   2. contact information, such as your email address, postal address, and phone number;
   3. professional information, such as your job title, position, and information about your organization; and
   4. billing information, such as your bank account number.

1. Huble understands its obligation to make Data Subjects aware of the fact that it is processing their Personal Data and to inform them of the purpose of processing said Personal Data. Huble will generally use Personal Data for purposes required to operate and manage its normal business operations and these purposes include one or more of the following non-exhaustive purposes:
   
   1. providing you with access to our Website;
   2. managing our relationship with you;
   3. selling and supporting our Services to you;
   4. responding to your requests and questions;
   5. sending you marketing communications about our business that you have expressed interest in, or which we think may interest you;
   6. collecting payment for our Services;
   7. conducting “Know your Customer” reviews as and when required by the Financial Intelligence Centre Act 38 of 2001 and similar relevant laws;
   8. conduct due diligence processes as and when required;
   9. measuring and improving our Website, Services, and marketing initiatives, and for the purpose of performing general information technology-related functions for all business functions within Huble;
   10. enforcing our legal obligations and complying with applicable laws and regulations; and
   11. for such other purposes to which the Data Subject may consent from time to time.
       
       
2. For more information about our processing of personal data, please read our Huble Data Processing Addendum.
   
   

1. We will aim to keep the Personal Data we collect as accurate, complete, and up to date as is necessary for the purposes in this Notice.  
   
   
2. We will only retain Personal Data for a period of five (5) years from the date of receipt or as long as it is necessary to fulfil the purpose for which it was collected and for as long as that purpose continues unless otherwise required by law, after which it is deleted.
   
   
3. For more information about our retention of personal data, please read our Huble Data Processing Addendum.

1. We will keep your Personal Data confidential and only share it with service providers and/or our partners and/or other associated institutions who perform certain services on our behalf. 
   
   
2. We share your Personal Data solely for the service providers, partners, and/or associated institutions to perform services for us. All these service providers, partners, and/or associated institutions have a contractual obligation to secure your Personal Data and to use it only in a way that we permit. 
   
   
3. These service providers, partners, and/or associated institutions include, but are not limited to, those who provide:
   1. hosting services;
   2. payment processing services;
   3. accounting services;
   4. e-signature software; and
   5. customer relationship management services.
      
      
4. Some of these service providers, partners, and/or associated institutions may be located outside of your country of residence (“Third Countries”). In some cases, the authorities in your country responsible for data protection may not have determined that the data protection laws in the countries where our service providers, partners, and/or associated institutions are located provide a level of protection equivalent to the laws in your country. 
   
   
5. Where Personal Data is transferred to such Third Country recipients, we make sure that appropriate safeguards are in place to provide for adequate protection of your Personal Data. For example, if you are a resident in the European Union, and the European Commission has not determined that the Third Country provides an adequate level of protection for your Personal Data, we will ensure that appropriate safeguards are in place with the service provider, partners, and/or associated institutions, such as the European Commission’s approved standard contractual clauses. 
   
   
6. Please note that we may also disclose your Personal Data:
   
   
   1. to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by government and/or law enforcement officials, or private parties, including but not limited to a response to subpoenas, search warrants, or court orders;
   2. if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change;
   3. to our subsidiaries or affiliates, only if necessary for business and operation purposes; or
   4. to partners and/or associated institutions for the purposes of co-selling and to facilitate referral partnerships, this is limited to the purpose of offering you valuable products and/or services.
      
      
7. If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by government and/or law enforcement, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy and security of your Personal Data.
   
   
8. We do not sell or trade your Personal Data.  

1. Huble Digital has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction. More information about our Security and Technical Measures applied can be accessed on our Huble Trust Portal.
   
   
2. Huble will continue to take reasonable steps to ensure that all Personal Data is kept as accurate, complete and up to date as reasonably possible, depending on the purpose for which the Personal Data is collected or further processed.
3. Huble may not always expressly request the Data Subject to verify and update his/her/irs Personal Data, unless this process is specifically necessary. Huble, however, requests that the Data Subject will notify Huble from time to time in writing of any updates required in respect of his/her/its Personal Data.
4. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your Personal Data, kindly notify our Information Officer by sending an email to privacy@hubledigital.com.

1. We sometimes use “cookies”, which are files with a small amount of data, which may include anonymous unique identifiers. Cookies are sent to your browser from our Website and stored on your computer’s hard drive.
   
   
2. We may use cookies to provide Website functionality, improve interactivity with our Website, allow for authentication (session management), obtain analytical information, and remember your settings.
   
   
3. We use sessional and persistent cookies. Sessional cookies are deleted when you close your browser. Persistent cookies may remain on your device even after you close your browser, but will always have an expiration date.
   
   
4. Some of the cookies placed on your device are first-party cookies since they are placed directly by us. However, please note that other third parties may also set their own (third-party) cookies through our Website. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you. We do not have access to or control over third-party cookies, and therefore cannot take responsibility for them.
   
   
5. If you would prefer not to accept cookies, you can change the settings of your browser to reject some or all cookies. Please note that, if you reject certain cookies, you may not be able to use all of the functionalities of our Website and in some cases, may experience technical difficulties when navigating our Website.
   
   
6. You may set your browser to send a Do Not Track (“DNT") signal. For more information about DNT signals, please visit https://allaboutdnt.com. Please note that our Website does not have the capability to respond to DNT signals.
   
   
7. For more information about our use of cookies, please read our Cookie Notice.

1. Our Website may connect to various social media sites or apps, including Facebook,  LinkedIn, and Instagram. If you choose to use our Website for social media integration, including creating user profiles and login functionality, we will share your information with the relevant social media sites or apps. This may include your name, email address, profile picture, and other information you choose to share. Please note that these social media platforms have their own privacy policies, and we encourage you to review them carefully. By integrating your social media accounts with our Website, you acknowledge and agree to the data sharing practices described here and in the respective social media platform's privacy policies.
   
   
   
2. This Website may include links to other affiliated and unaffiliated sites such as Twitter, Instagram, and LinkedIn. Those websites will have their own privacy policies that you may wish to review. We have no responsibility for unaffiliated linked websites or any use of those sites and their privacy practices. This Website may also contain links to our presence on various social media platforms. As we do not operate or control such platforms, this Notice does not apply to your use of such platforms.

1. If you are a Data Subject about whom we store Personal Data, you have certain data protection rights under applicable privacy laws.
   
   
2. Please note that you can only exercise these rights with respect to Personal Data that we process about you when we act as a data controller. To exercise your rights with respect to Personal Data processed by us on behalf of one of our clients, please read the privacy notice(s) of our clients.
   
   
3. We may need to confirm your identity in order to process your request. A request can also be made on behalf of a child or ward (who is under the age of 16).
   
   
4. Your privacy rights include:
   
   1. The right to be informed – You have the right to obtain from us all information regarding our data processing activities that concerns you, such as how we collect and use your Personal Data, how long we keep it, and whom it will be shared with, among other things. We are informing you of how we process your Personal Data with this Notice.
   2. The right to access - You can ask us to confirm whether or not we process Personal Data concerning you, and, where that is the case, obtain copies of your Personal Data.
   3. The right to correction - You can ask us to correct or update inaccurate Personal Data concerning you.
   4. The right to deletion - You can ask us to erase your Personal Data in certain circumstances. We will always strive to fulfil your request. However, in certain circumstances, we may not be able to delete your Personal Data due to our obligation to maintain your Personal Data pursuant to a legal obligation. If that is the case, we will consider if there are means to limit how we use your Personal Data.
   5. The right to withdraw consent - You can also withdraw your consent, where consent is the legal basis for processing your Personal Data.
   6. The right to data portability – You can ask us to transfer your Personal Data, which we obtained from you, to another organization or to you.
   7. The right to object to processing – You have the right to object to the processing of your Personal Data in circumstances where we rely on our legitimate interest to process your Personal Data. You also have the right to object, at any time, to the processing of your Personal Data for direct marketing purposes.
   8. The right to restrict processing – You can ask us to only use or store your Personal Data for certain purposes. You have this right on certain occasions, such as when you believe the Personal Data is inaccurate or the processing activity is unlawful. This right enables you to ask us to suspend the usage of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
   9. The right to complain to a supervisory authority - You can complain about our processing of your Personal Data to the relevant supervisory authority.
      
      
5. These rights are subject to certain limitations and exceptions.
   
   
6. To exercise any of the rights described above, please contact us using the contact details set out below in this Notice. Huble will respond to each written request of a Data Subject not later than 30 (thirty) days after receipt of such requests. Under certain circumstances, Huble may, however, extend the original period of 30 (thirty) days once for a further period of not more than 30 (thirty) days.
   
   
7. You can obtain more information about your participation rights as a Data Subject under South African law and how to exercise them by reading our POPIA and Data Subject Participation Manual which can be found here.

1. This Notice covers Huble Digital Group Limited and the following affiliate entities:
   
   1. Huble Digital Limited;
   2. Huble Digital (Pty) Ltd;
   3. Huble Digital PTE.;
   4. Huble Digital Inc.;
   5. Huble Digital Corp.; 
   6. Huble Digital GmBH; and
   7. Huble Digital SRL. 

If you have any questions or concerns about our data privacy practices or the contents of this Notice, or if you would like to exercise your privacy rights, please write to us at privacy@hubledigital.com.

We have appointed PROLIANCE GmbH as Huble Digital GmBH’s data protection officer in terms of Article 37 of the GDPR (the “DPO”). If you are a data subject of Huble Digital GmbH, you may contact the DPO using the following contact details:

DPO: PROLIANCE GmbH
Physical Address: Leopoldstr. 21, 80802, Munich, Germany
Website: www.datenschutzexperte.de
Email: datenschutzbeauftragter@datenschutzexperte.de

When contacting our DPO, please state that your enquiry relates to Huble Digital. Please refrain from enclosing any sensitive information along with your request, such as a copy of your ID card.

We have appointed an information officer relevant to the rest of the Huble Group entities. If you would like to exercise your privacy rights under the POPIA or GDPR or any other relevant Data Privacy Law or Regulation, you can contact our Information Officer using the following contact details.

Contact Person: Michael Norton (Group Finance Director)
Physical Address: 123 Buckingham Palace Road, London, SW1W 9SH

Telephone Number: +44 (0)20 7183 0288
Email: privacy@hubledigital.com

1. European Union: We have appointed Huble Digital GmBH as Huble’s representative in the European Union for Personal Data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. Whilst you contact our Information Officer, you can also contact Huble Digital GmBH using the following contact details: 
   
   Physical Address: Schwanthalerstraße 13 / Hinterhof Aufgang II, 80336 München
   Telephone Number: +49 (0)89 9589903
   Email: privacy@hubledigital.com
   
   
2. United Kingdom: We have appointed Huble Digital Group Limited as Huble’s representative in the United Kingdom for Personal Data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. Whilst you contact our Information Officer, you can also contact Huble Digital Group Limited using the following contact details.  
   Physical Address: 123 Buckingham Palace Road, London, SW1W 9SH
   Telephone Number: +44 (0)20 7183 0288
   Email: privacy@hubledigital.com

1. Huble reserves the right to make amendments to this Notice from time to time and will use reasonable efforts to notify Data Subjects. If we make any material changes to this Notice, we will post the revised Notice to this Website. We will also update the “effective date” accordingly.
   
   
2. The current version of this Notice will govern the respective rights and obligations between you and Huble each time that you access and use our website.