Privacy Policy

Dated: 24 May 2018

PLEASE READ THIS POLICY CAREFULLY

 

Protecting your personal information is very important to HubOne Pty Ltd (“HubOne” “our”, “us” or “we”).

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This policy sets out the basis on which any personal data about you will be processed and applies to the processing of personal data in connection with our software-as-a-service document management software known as ‘OnePractice’ (“Apps”). 

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Our Apps may contain links to third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

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Identity and contact information of the Data Controller

For the purposes of data protection legislation in the European Union, the data controller (i.e. the person that determines the purposes and manner in which your personal data are processed) is:

• HubOne Pty Ltd, in connection with: (i) Identity Data; (ii) Contact Data; (iii) Transaction Data; (iv) Technical Data; (v) Profile Data; and (vi) Usage Data. HubOne Pty Ltd is a company incorporated and registered in Australia (company number 129 333 795) with its registered office at 9 Claremont Drive, Robina, QLD.

• The Apps account holder, in connection with Content Data. HubOne Pty Ltd is the data processor and merely processes personal data in accordance with the instructions given to us by the account holder.

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to support@hubone.com.

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Personal information we may process about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data, which includes your first name, last name, social media profile, user ID, company name, job position and company department.

• Contact Data, which includes your email address and postal address.

• Content Data, any personal data which is contained within the documents or emails you ask us to store or generate.

• Transaction Data, which includes details about payments to and from you and other details of services you have purchased from us.

• Technical Data, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location you use to access the Apps.

• Profile Data, which includes your password, subscriptions purchased by you, your preferences, feedback and survey responses.

• Usage Data, which includes information about how you use our Apps.

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A breakdown of the personal data we may process is set out in the section below. Please note that third parties may collect personal data from you directly. For example, payment processors such as Stripe Inc. collect financial data (such as your payment card details) when you make payment to us on the Apps.

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Why is personal data processed?

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1. Registering you as a new customer

   1. Why is personal data being processed: To Register you as a new customer.

   2. What Data: Identity Data, Contact Data and Profile Data.

   3. Legal basis for Processing: Performance of a contract with you.

   4. Period of Data Storage: Until 7 years after you have deleted your account and uninstalled the Apps.

   5. Will your personal data be shared: We share this data with Microsoft, who operates your Office 365 environment. The data cannot be shared unless you have entered into a separate contract with Microsoft for Office 365. To ensure this transfer is lawful, we rely on the fact that you have a contract in place with Microsoft which is approved by the European Commission and gives personal data the same protection as in Europe.

2. Processing your access to the Apps

   1. Why is personal data being processed: To process users’ access to the Apps, including ensuring secure access to the Apps

   2. What Data: Identity Data, Contact Data and Profile Data.

   3. Legal basis for Processing: Performance of a contract with you. Necessary to comply with a legal obligation.

   4. Period of Data Storage: Until 7 years after you have deleted your account and uninstalled the Apps.

   5. Will your personal data be shared: We share this data with organisations such as Microsoft, Inc., to ensure secure access to the Apps. Microsoft Inc. stores some data in the USA. To ensure this transfer is lawful, we rely on the fact that Microsoft, Inc. is certified as complying with the EU-US Privacy Shield regime.

3. Financial Transactions

   1. Why is personal data being processed: To manage payments, fees / charges and to collect / recover money owed to us.

   2. What Data: Identity Data, Contact Data and Transaction Data.

   3. Legal basis for processing: Performance of a contract with you. Processing is necessary for our legitimate interests (i.e. to recover debts due to us).

   4. Period of Data Storage: We will keep records until 7 years after you have ceased payment, have debts outstanding deleted your account and uninstalled the Apps.

   5. Will your personal data be shared: We use Chargify to collect payments for our Apps. Chargify will request information from you on an order form. You must provide contact information (such as name and email). This information is used for billing purposes and to fulfill customer’s orders. If Chargify has trouble processing an order, the information is used to contact you. We will also share your email address with Stripe Inc. so that payment receipts can be sent to you by email. Stripe Inc. stores this data in the USA. To ensure this transfer is lawful, we rely on the fact that Stripe Inc. is certified as complying with the EU-US Privacy Shield regime.

4. Registering you as a parnter​

   1. Why is personal data being processed: To register you as a new partner and grant you access to the partner portal. ​

   2. What Data: Identity Data and Contact Data.

   3. Legal basis for Processing: Performance of a contract with you. Necessary to comply with a legal obligation.

   4. Period of Data Storage: We will keep records until 7 years after our partnership has ended.

   5. Will your personal data be shared: We share this data with organisations such as Microsoft, Inc., to ensure secure access to the Apps. Microsoft Inc. stores some data in the USA. To ensure this transfer is lawful, we rely on the fact that Microsoft, Inc. is certified as complying with the EU-US Privacy Shield regime. In addition, partner portal credentials are stored by Wix and their authorized affiliates and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law. Wix.com Ltd. is based in Israel, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data). Nor do we collect any information about criminal convictions and offences. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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How we use your data for marketing

• Customers - we will contact you regarding App features and updates, as well as admin and account notifications that may impact you. You can also opt in to other marketing content via our website, emails, social media, webforms, events and other marketing forums.

• Partners - we will contact you regarding updates to our Apps, as well as admin and account notifications that may impact you and/or your customers using our Apps. 

• Other - we will only contact you with marketing content if you have opted in via website, emails, social media, webforms, events and other marketing forums.

 

How personal data are collected

We may obtain personal data about you in two main ways:

• Direct interactions. You may, for example, provide us with your personal data by filling in forms on our Website. This included personal data provided to us when an account is created, or you subscribe to use our Apps.

• Automated technologies. Personal data may be collected automatically (such as the automatic recognition of your IP address or placement of cookies on your device - please see our cookies policy).

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Apps). In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

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Where we store your personal information

The personal data that we collect from you will be transferred to and stored at a destination outside of the European Economic Area (“EEA”). This data may also be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. Further information is provided in the above. Please contact us at support@hubone.com if you would like further details on the specific safeguards applied to the export of your personal data outside the EEA.

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Disclosure of your information

We may also disclose your personal information to third parties in the following circumstances:

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• If you request we do so - You have provided your consent

• If HubOne Pty Ltd or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets. Legitimate interests (i.e. to dispose of our business).

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of HubOne Pty Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection. - Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.

• We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where we are compelled or believe it is reasonable to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.

 

Alternatively, legitimate interests (i.e. to cooperate with law enforcement and regulatory authorities).

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Your rights

Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at support@hubone.com.

You have the following rights in relation to your personal data:

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• Rights of Access - You have the right to obtain from us confirmation as to whether your personal data are being processed, and, where that is the case, access to such personal data.

• Right to Rectification - We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.

• Right to erasure / ‘Right to be forgotten’ - Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing).

• Right to restriction of processing - You have the right to ask us to stop processing your personal data at any time.

• Right to data portability - You have the right to request that we provide you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.

• Right to complain - You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints.

 

We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

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Where you request us to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example to comply with its legal obligations.

 

Children under the age of 16

The Apps are not aimed at children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, please do not use our services or provide any information to us through the Apps. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@hubone.com.

 

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, we will notify you, by email, or by means of a notice on our home page. Your continued use of the Apps will be deemed acceptance by you of the privacy policy. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.