We invite you to read this document carefully (hereinafter, the “Privacy
Policy”). If you have any questions about this document and, more
generally, about the collection and processing of your personal information by
HUBUR company (hereinafter “HUBUR”), please contact us at the following e-mail address
[email protected].
Summary
Personal data means any information relating to an identified or identifiable natural person; An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to him or her. To determine whether a person is identifiable, it is necessary to consider all the means to enable his or her identification that are available or to which the Data Controller or any other person may have access
Services : refers to all the services provided by HUBUR to the Client as specified in the Quotation or which may be the subject of a franchise offer, as detailed in any Franchise agreement.
Orders : refers to the subscription process carried out on the Site involving a delivery, namely in particular, the rental of vehicles.
Purpose : refers to the objective pursued by the Processing as part of the performance of the Subcontractor’s services.
Personal Data Regulation : This personal data protection policy complies with the following obligations:
Processing : means an operation, or set of operations, relating to personal data, regardless of the process used.
Agreement : means this Privacy Policy, the General Terms and Conditions of Sale, and its Appendix, as well as any applicable Quote signed between the Client and HUBUR.
Client : refers to the natural person, individual or professional who subscribes to the Services via the Site.
Users : refers to all users of the HUBUR Website, whether they are Customers, professionals or members.
HUBUR is committed to maintaining the confidentiality of your personal information and we attach great importance to protecting the privacy of Users of our Services.
The purpose of the Privacy Policy is to define the rules applicable to the collection and Processing of your Personal Data via our Site as well as through subscription to the Services.
Our Privacy Policy details the Personal Data we collect and process through our Site, the reasons for processing your Personal Data, how we use it and the features offered to allow you to access and update your Personal Data.
It applies to Users of the Site as defined in section “1. Definitions”.
Our Privacy Policy does not apply to services offered by third-party companies, operating websites and tools of our delivery providers or other partners or tools accessible from our Site. We are not responsible for how these sites use your Personal Data.
Acceptance of Our Terms. When subscribing to our Services, you are required to accept this Privacy Policy. You thus confirm that you have read it and accept it without restrictions or reservations. If you disagree with any of its terms, you are free not to use our services.
Update. We may modify the terms of this Privacy Policy, in particular in the event of the implementation of a new Processing of Personal Data. You will be notified of such changes either by a special notice on our Sites or by an email notification.
The data controller is HubUR, represented by, Philippe Cussonier, having its registered office at THE BLACK CHURCH, SAINT MARY’S PLACE NORTH, DUBLIN D07 P4AX
Registration number: 717691
A data controller is an entity that determines the Purposes and means of your Personal Data Processing and is responsible to you for compliance with the Personal Data Regulations.
If you have any questions about the processing of your Personal Data, you can contact us by e-mail at : [insérer email contact]
We are the data controller for all Processing carried out on our HUBUR Website. We are also responsible for the Processing of Personal Data collected in connection with the subscription to our Services, in accordance with the legal provisions in effect.
To access the details of the Purposes and Processing of Personal Data carried out on our Site, please refer to section 4 of this Privacy Policy.
Details of the data collected:
-IP address
-Cookies
-Logs
Persons concerned:
– Site User
Details of the data collected:
– Civil status
– First name, last name
– Email address
– Phone number
– Mailing address
– Professional context (function, organization)
Persons concerned:
-Customers
Details of the data collected:
– Civil status
– First name, last name
– Email address
– Phone number
– Mailing address
– Professional context (function, organization)
Persons concerned:
– Customers
Details of the data collected:
– Civil status
– First name, last name
– Professional context (function, organization)
– Financial aspects: income and tax situation
-IP address
-Logs
Persons concerned:
– Business customers
Details of the data collected:
– Registered legal name
– Copy of the identity document of the legal representative and shareholders holding at least 25% of the company’s shares (CNI, Passport or Driving License for the EU)
– Business email address
– Registered legal address
– Proof of registration – one of the following, not older than 3 months:
SIRET number/Registration number
Details of the data collected:
– Civil status
– First name, last name
– Professional context (function, organization)
– Financial aspects: income and tax situation
-IP address
-Logs
Persons concerned:
-Customers
The Personal Data that is essential for HUBUR to achieve the purposes of the Processing are indicated by an asterisk in the collection forms.
If you do not fill in these required fields, we will not be able to provide you with our Services.
Personal Data not marked with an asterisk is optional; they allow us to know you better and improve our Services.
Regarding the Personal Data collected when you browse the HUBUR Website, please refer directly to the Cookie management banner.
Processing purposes:
– General administration of the website to ensure its proper functioning and security
– Deposit of cookies in accordance with the choices made via the cookie banner
– Creation of statistics, monitoring of activity, analysis of traffic and pages viewed;
Legal basis:
-Consent
Processing purposes:
– Establishment of contracts: subscription to Services, placing and delivery of orders
– Tracking, history and management of Services and Orders
– Processing requests for information and assistance in connection with your orders and the use of our services
– Invoicing, follow-up, management of unpaid invoices and litigation
– Keeping accounting records and legal supporting documents
Legal basis:
– Execution of contractual measures
-Consent
Processing purposes:
– Establishment of contracts: subscription to Services, placing and delivery of orders
– Tracking, history and management of Services and Orders
– Processing requests for information and assistance in connection with your orders and the use of our services
– Invoicing, follow-up, management of unpaid invoices and litigation
– Keeping accounting records and legal supporting documents
Legal basis:
– Execution of contractual measures
-Consent
Purpose of processing:
– Establishment of a Smart Contract
Legal basis:
-Consent
Purpose of processing:
– Fight against fraud and money laundering
Legal basis:
– Legal obligation
Purpose of processing:
– Fight against fraud and money laundering
Legal basis:
– Legal obligation
Your Personal Data is only kept for a strictly necessary period of time.
Management and use of the HUBUR Site. Cookies are kept for a maximum of thirteen (13) months after they are first placed on the User’s terminal, as is the period of validity of the User’s consent to the use of these Cookies.
The lifespan of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.
Customers (BtoC). Your data is kept for the duration of our contract. Personal data is deleted 10 years after the end of our contractual relationship to comply with legal retention requirements.
Before the expiry of these periods, we may contact you again to find out whether you wish to set up an additional retention period, in which case the periods indicated above will start running again.
At the end of these periods and the effective closure of your account, your Personal Data will be anonymized. They will then be used exclusively for statistical purposes.
Sharing to third parties. The Personal Data that you transmit to us when using the Site and subscribing to our Services, may be communicated to:
Transfer outside the EU. When HUBUR uses service providers located outside the EU, transfers protection and security guarantees are taken. Thus, either these recipients are located in a country benefiting from an adequacy decision, or standard contractual clauses approved by the European Commission have been signed.
Definition of the Adequacy Principle
The principle of adequacy, as defined by the General Data Protection Regulation (GDPR), states that transfers of personal data to third countries or international organisations may be only authorised if the level of data protection in these third countries is considered adequate by the European Commission.
As a data sender, we undertake to comply with the following obligations to ensure the adequacy of the transfer of data to countries recognised by the European Union as being in line with the GDPR:
– Adequacy assessment: Prior to any transfer of data to these countries, we will cary out a thorough assessment to ensure that the legal framework and data protection mechanisms provide a level of protection equivalent to that required by the GDPR.
We will ensure that all data transfers to these countries are secure and encrypted in accordance with the information security standards recognized by the GDPR. This will ensure that our customers’ & users’ personal data remains protected while in transit to these countries and is not at risk of infringement or unauthorized disclosure.
By respecting the principle of adequacy and taking the necessary measures to ensure an adequate level of protection of personal data during its transfer, we ensure that the fundamental data protection rights of our customers and users are respected.
Definition of standard contractual clauses (or GDPR clauses)
Standard contractual clauses are clauses pre-established by the European Commission that can be used by companies to ensure an adequate level of protection when transferring personal data to third countries outside the European Union, where the level of data protection may be different. These clauses are designed to ensure that the rights of data subjects remain protected and that GDPR obligations are met, even outside the EU. They contain contractual guarantees to ensure the confidentiality, security and respect of the rights of individuals with regard to the processing of their personal data. The parties concerned must incorporate these clauses into their contracts to ensure that data transfers are done in compliance with European data protection regulations
As a data controller, HubUR takes all necessary measures to preserve the security and confidentiality of the data and in particular, to prevent it from being damaged or accessed by unauthorized third parties.
To this end, HubUR implements all technical and organisational measures to ensure an adequate and risk-appropriate level of security with regard to the processing of your personal data.
You have a right of access to the Data concerning you, the right to request its rectification, deletion or portability, as well as the right to request the limitation of the processing of your Data, to withdraw your consent and to define guidelines on the fate of your Data after your death.
You also have the possibility to object, at any time:
These rights can be exercised at any time by contacting our customer service team by email at [email protected]. You also have the option to delete your account (and therefore your Personal Data) directly within your Member Account.
After contacting us, if you feel that your rights have not been respected, you also have the right to lodge a complaint with a supervisory authority.
The Irish supervisory authority is the Data Protection Commission (DPC) located at The Data Protection Commission (c/o Data Protection Officer), 21 Fitzwilliam Square South, Dublin 2, D02 RD28 Ireland.
Your rights regarding your personal data
Your rights in relation to your personal data are as follows:
You also have the right to define general and/or specific guidelines relating to the fate of your personal data and the way you wish your rights to be exercised after your death.
To ensure that the information HubUR has about you is always accurate, we recommend that you update your personal data regularly.
You can make any request to exercise your rights in relation to your personal data by contacting HubUR by email: [email protected]
In the event of dissatisfaction, you have the right to submit a complaint to the competent authoritý:
This policy is intended to evolve and is therefore subject to change. In the event of minor changes, the new policy will be posted on the website in the dedicated section. In the event of substantial changes concerning, for example, the purposes or the exercise of your rights, you will be informed via the email we have at our disposal.
