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Privacy policy

The Hubfinance website (the "Site " or "hubfinance.com " ) offers features that allow you, as a user, to access a directory of wealth management specialists, to create a profile for your employer/client in this directory and to communicate with the other specialists listed there. All these functionalities are described in greater detail in Appendix A "Description of Services" in the General Terms and Conditions of Use of the Site (hereinafter the "Services").

This policy ("Policy") informs you of the processing of your personal data resulting from your browsing of the Site and use of the Services.
To find out more about cookies, please consult the Cookies Policy.

SUMMARY

1) What are the roles and responsibilities concerning the processing of your data via the Site?
2) What categories of personal data are processed via the Site?
3) Why does the Company collect your personal data?
4) Who are the recipients of your personal data collected via the Site?
5) Why and how are your personal data transferred outside the EEA?
6) What are your rights regarding your personal data?
7) How long is your data stored?
8) How is the security of your personal data ensured?
9) How can you contact us if you have any questions?

1) What are the roles and responsibilities concerning the processing of your data on the Site?

DATAPUNK, a public limited company incorporated under Luxembourg law, having its registered office at 5 rue de l'industrie, 1811, Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B247671 (hereinafter the " Company ") , is responsible for managing the Site and for processing your personal data via the Site.

The Company is committed to respecting your privacy and protecting your personal data.

2) What categories of personal data are processed via the Site?

The Company collects the following personal data directly from you:

- your identification details: surname, first name, job title, login, password,

- your contact details: e-mail address and telephone number (necessary to respond to your requests and contact you if necessary);

Personal data whose collection is essential to the use of the Services are identified by an asterisk.

If you do not provide this data in the mandatory fields, it will not be possible to provide you with the Services and/or respond to your requests. All other data is simply optional and enables the Company to get to know you better, in order to improve the Site and Services.

Other personal data is collected automatically when you access the Site or use the Services. This includes connection and browsing data (terminal used, your IP address, browser type and browsing information). This data is collected to ensure the proper operation and security of the Site, but also to measure the audience, or to offer functionalities linked to social networks, depending on the choices made for the deposit of cookies, under the conditions defined in the Cookies Policy.

3) Why does the Company collect your personal data?

The Company collects and processes your personal data on the following legal bases:

A/ On the basis of the performance of contractual or pre-contractual measures (as part of your browsing on the Site), for the purposes of:

  • Allow you to create a User account;
  • Allow you to use the Services, in accordance with the Terms of Use.

B/ On the basis of your consent, for the purposes of :

  • Customize the Site's interface according to your preferences
  • Generate statistics to measure the Site's audience and statistics relating to the
  • Consultation of User Profiles, in accordance with the purposes listed in the Cookies Policy.

C/ To pursue the Company's legitimate interests in offering an operational e-commerce site, for the purposes of :

  • Ensure the proper functioning of the Site;
  • Ensuring the security of the Site.

D/ For the pursuit of the Company's legitimate interests in managing its relationship with the users of its Site:

  • To manage the relationship between you and the Company, by virtue of your status as a user of the Site offered by the Company, by maintaining an up-to-date centralized database of users of the Site and Services;
  • To enable the Company to contact you in response to any complaint or request relating to the Site or Services, and to provide you with any necessary assistance;
  • To manage any disputes that may arise.

‍4) Who are the recipients of your personal data collected via the Site?

Your personal data is communicated to third parties for the purposes described below.

✔ Management of the Site and of the relationship with you as a user of the Site and the Services offered by the Company.

The Company's authorized personnel have access to the personal data collected from you, in order to enable the proper functioning of the Site and to correct any technical incidents and to manage the relationship with you as a user of the Site and Services.

✔ Third-party service providers or suppliers
Your personal data is also communicated by the Company to:

● subcontractors or service providers, who intervene on a purely technical or logistical basis: providers of Site hosting and maintenance services.

✔ Protection and defense of rights:

Your personal data may be communicated to third parties where such communication is required by law, regulatory provision or judicial decision, or where such communication is necessary in the event of litigation.

5) What are your rights regarding your personal data?

Access and rectification

You have the right to access your personal data and to request the rectification of any data found to be inaccurate. If you wish, you can directly access and rectify/delete the data contained in your online user account. You can delete your user account by clicking on "Delete my account".

Other rights
Deletion. You may also request the deletion of your personal data, provided that it is no longer necessary for the Company to retain it.

Objection and restriction of processing. You may also object to the processing of your personal data or request a restriction of such processing, unless it is necessary for the management of the Services you request.

Withdrawal of consent. Where the processing of your personal data is based on your consent, you may withdraw it at any time. Withdrawal of consent will not affect the lawfulness of any processing already carried out.

Portability. You may exercise your right to portability, i.e. to obtain, in a structured and machine-readable form, the personal data you have provided, directly on the basis of your consent or on the basis of the General Terms of Use, provided that this processing is automated.

Instructions. You may also give your instructions concerning the retention, deletion and disclosure of your personal data after your death, and change your instructions at any time.

You may make a complaint to the CNPD and/or the CNIL, following the process described on their respective websites https://cnpd.public.lu/fr.html and https://www.cnil.fr or to any competent data protection authority.

These rights may be exercised at any time by sending an e-mail to rgpd@datapunk.ai or by sending a letter to the Data Protection Department of DATAPUNK, a société anonyme incorporated under Luxembourg law, having its registered office at 5 rue de l'industrie, 1811, Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B247671. You may be asked to provide proof of your identity.

6) How long is your data stored?

Your personal data is kept for the time necessary to achieve the purposes described in this Policy, in accordance with the applicable regulations and legislation on the protection of personal data. These periods are detailed below.

For the purposes of this article, it should be noted that :

  • Active retention refers to the period of time required to achieve the objective (purpose of processing) that justified the collection/recording of the data. In practice, this means that the data will be easily accessible in the immediate working environment for the Company's operational departments in charge of processing.
  • Intermediate storage refers to the period during which personal data is no longer used to achieve its intended purpose ("closed files"), but is still of administrative interest to the Company, or must be retained to meet a legal obligation. The data may then be consulted on an ad hoc basis by specifically authorized persons.

Account data

  • Your account on the Site will remain active as long as you have not decided to close it and as long as you continue to use the Services after logging in to your User account. In the absence of any activity on your part, your account data will be kept in an intermediate archive for three (3) years. In the event of prolonged inactivity on your part for a period of 3 years, this account will be deactivated and your related data will be deleted.
  • In all cases, you may close your account at any time by clicking on "Delete my account" on the Site.

Claims

  • Your personal data and general information about your requests are collected and processed as part of your dealings with the Company's staff. This data is kept for the time it takes to respond to your request in the active database, and then for 3 years from the last contact with you in the intermediate archive.

Cookies

Your personal data collected via cookies will be stored under the conditions set out in the Cookies Policy.

Your personal data will be deleted at the end of the periods mentioned in this article.

7) How is the security of your personal data ensured?

The Company has implemented appropriate organizational, technical and administrative measures to protect your personal data from destruction, loss, alteration or unauthorized disclosure.
The Company makes every effort to protect your personal data, taking into account the sensitivity of the information in question and the potential risks associated with data leakage. The Company takes all appropriate measures to guarantee the confidentiality, integrity, availability and resilience of your personal data; it stores such data in information systems offering an appropriate level of security, access to which is protected, restricted and recorded; it enters into strict confidentiality agreements with all persons involved in processing such personal data on its behalf.

8) How can I contact you if I have any questions?

You can contact us at any time by sending an e-mail to rgpd@datapunk.ai or by sending a letter addressed to the Data Protection Department of DATAPUNK, a société anonyme incorporated under Luxembourg law, having its registered office at 5 rue de l'industrie, 1811, Luxembourg, and registered with the Luxembourg RCS under number B247671.

9) How can this Policy be modified?

The Privacy Policy may be amended and updated to reflect changes in the Company's practices, or to ensure compliance with regulations in the event of a change in the latter.

In this case, the revised Privacy Policy will be posted on the Site, along with the last update date, and you will be notified by a banner on the Site inviting you to consult the updated Privacy Policy.