Privacy Policy

At Hubflo, the protection of your personal data is a priority. 

When you use the https://www.hubflo.com/ and https://www.app.hubflo.com website (here after the "website"), we may collect personal data about you.

The purpose of this policy is to inform you about the ways in which we process this data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

1. Who is the data controller?

The data controller is Hubflo, SAS, registered in the Paris Trade and Companies Register under number 909 078 263 and whose registered office is located at 49 rue de Ponthieu 75008 PARIS (hereinafter "We"), when you browse our Site or in the context of managing our contractual relations.

On the other hand, when our customers use our services, we collect and process personal data on their behalf and for their account. Our customers are therefore data controllers in accordance with Article 4 of the GDPR. We act as a processor, as a service provider. 

2. What data do we collect? 

Personal data is data that identifies an individual directly or by cross-referencing with other data. 

We collect data that falls into the following categories:

- Identification data (last name, first name, email address, phone number);

- Data relating to your company (company name, SIRET number, position held)

- Browsing data (e.g. IP address, pages viewed, date and time of connection, browser used, operating system, user ID, IFA);

- Economic and financial data (data relating to your bank cards, data necessary for invoicing);

- Any information that you wish to send us as part of your contact request.

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Mandatory data are indicated when you provide us with your data. They are indicated by an asterisk and are necessary to provide you with our services.

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3. On what legal grounds, for what purposes and for how long do we keep your personal data?

Carrying out operations relating to the management of our customers concerning contracts, orders, invoices and follow-up of the contractual relationship with our customers

Execution of the contract that you or your company have signed with us

Personal data are kept for the duration of the contractual relationship.

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Additional Limitations on the Use of Your Gmail User Data

if you provide Hubflo access to your Google data, Hubfo's use of that data will be subject to these additional restrictions:

• Hubflo will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• Hubflo will not use this Gmail data for serving advertisements.
• Hubflo will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for hubflo's internal operations and even then only when the data have been aggregated and anonymized.
• Hubflo use of information received, and the hubflo's transfer of information to any other app, from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

4. Who are the recipients of your data? 

Will have access to your personal data:

• Our company staff;
• Our subcontractors: hosting provider, newsletter provider, audience measurement and analysis provider, personalized advertising provider, email provider, secure payment provider, accounting provider, data consolidation provider, integration management provider, electronic signature provider, document management provider, customer service provider; 
• Where applicable: public and private bodies, exclusively to meet our legal obligations.

5. Is your data likely to be transferred outside the European Union? 

Your data is kept and stored for the duration of the processing on Heroku and AWS servers located in Europe.

In the context of the tools we use (see article on the recipients concerning our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured by means of the following tools:

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• either the data is transferred to a country that has been the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the RGPD: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the RGPD;

• or the data is transferred to a country whose level of data protection has not been recognized as adequate to the RGPD: in this case these transfers are based on appropriate safeguards indicated in Article 46 of the RGPD, adapted to each provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism

• or the data is transferred on the basis of one of the appropriate safeguards described in Chapter V of the GDPR.

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6. What are your rights to your data?

You have the following rights with respect to your personal data:

• Right to information: this is precisely the reason why we have drafted this policy. This right is provided for in Articles 13 and 14 of the GDPR. 

• Right of access: you have the right to access all your personal data at any time, in accordance with Article 15 of the GDPR.

• Right of rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time pursuant to Article 16 of the GDPR

• Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the GDPR

• Right to erasure: you have the right to demand that your personal data be erased, and to prohibit any future collection of your personal data on the grounds set out in Article 17 of the GDPR

• Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable texts. (Article 77 of the GDPR)

• Right to define directives regarding the retention, deletion and communication of your personal data after your death. 

• Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
  

• Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to require its transfer to the recipient of your choice.

• Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Please note, however, that we may continue to process your personal data despite this objection, for legitimate reasons or to defend legal rights.

You can exercise these rights by writing to us at the address below. We may ask you to provide us with additional information or documents to prove your identity. 

7. What cookies do we use?

To learn more about how we manage cookies, please see our Cookie Policy.

Contact point for personal data 

Contact email : data@hubflo.com 

Contact address : 49 rue de Ponthieu 75008 PARIS

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8. Changes

We may modify this policy at any time, in particular to comply with any regulatory, legal, editorial or technical developments. 

These modifications will apply on the date the modified version comes into force. You are therefore invited to regularly consult the latest version of this policy. 

Nevertheless, we will keep you informed of any significant changes to this Privacy Policy.

Effective date: 07/14/2022

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