HubWorx Ltd (referred to as "HubWorx", "we", "us" or "our") develops and operates an Employee Hub (the "Services") designed to improve how organisations communicate with their people. By bringing together company updates, documents, systems and key information into a single, structured environment, the Services enable teams to find what they need, when they need it, and reduce reliance on fragmented communication channels.
This Privacy Policy describes our practices regarding the collection, storage, use and disclosure of information relating to identified or identifiable individuals ("Personal Data" or "Personal Information") and such individuals ("Data Subjects") who:
- visit or otherwise interact with our website, www.hubworx.ai (the "Website"); or
- interact with any webpage, email, text message or online advertisement under our control
(collectively, "Visitors").
This Privacy Policy does notcover our practices relating to individuals who use our Services at a customer's direction, including a customer's employees, staff or contractors ("End Users"). If you are an End User, please refer to the relevant customer's privacy notice and the HubWorx Privacy Policy for End Users for information about how your Personal Data is handled.
Personal Data processed through the HubWorx platform is governed by a separate product privacy notice and, where applicable, a data processing agreement.
HubWorx Ltd is the data controller responsible for Personal Data collected through the Website. If you have any questions about this Privacy Policy or how we handle your Personal Data, please contact us using the details set out in section 11 below.
This Privacy Policy describes our practices regarding:
- Data Types
- Data Collection
- Data Uses and Legal Bases
- Data Disclosures
- Cookies and Tracking Technologies
- Communications
- Data Security
- Data Retention
- Your Privacy Rights
- Roles and Responsibilities
- Additional Notices and Contact Details
Definitions
In this Privacy Policy:
- "Website" means www.hubworx.ai.
- "Services" means the HubWorx Employee Hub and related services, as described on our Website.
- "Personal Data" has the meaning given to it under applicable data protection laws.
Please read this Privacy Policy carefully to ensure that you understand how we process your Personal Data.
1. Data Types
Personal Data means any information relating to an identified or identifiable individual.
We may collect, use, store and transfer the following categories of Personal Data:
- Identity Data: such as your name or job title where you choose to provide it.
- Contact Data: such as your email address or other contact details.
- Technical Data: including IP address, browser type and version, time zone setting, operating system, device information and other technology on the devices you use to access the Website.
- Usage Data: information about how you use the Website.
- Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share aggregated data, such as statistical or usage data, for analytical purposes. Aggregated data does not directly or indirectly reveal your identity and is not Personal Data.
2. Data Collection
We collect Personal Data through the following methods:
2.1 Direct interactions
You may provide Identity Data and Contact Data by completing forms on the Website (including the "Let's chat" enquiry form), subscribing to updates, requesting information about our Services, or corresponding with us by email or otherwise.
2.2 Automated technologies or interactions
As you interact with the Website, we may automatically collect Technical Data and Usage Data through cookies, server logs and similar technologies. This includes data collected via analytics providers such as Google Analytics, which help us understand how Visitors use the Website and improve its performance and usability.
Further information about our use of cookies and analytics technologies is set out in our Cookie Policy.
2.3 Publicly available sources
In limited circumstances, we may collect Identity Data and Contact Data from publicly available sources, such as Companies House, where this is relevant to our relationship with you (for example, where you contact us on behalf of an organisation).
3. Data Uses and Legal Bases
We process Personal Data only where permitted by applicable data protection laws. Under the UK GDPR and EU GDPR, Personal Data must be processed on the basis of one or more lawful grounds set out in Article 6(1).
3.1 Lawful bases (Article 6(1))
Personal Data may be processed on the following legal bases:
- Consent (Article 6(1)(a))
- Contract (Article 6(1)(b))
- Legal obligation (Article 6(1)(c))
- Vital interests (Article 6(1)(d))
- Public task (Article 6(1)(e))
- Legitimate interests (Article 6(1)(f))
3.2 Legal bases relied on by HubWorx
In relation to the Website, we typically rely on:
- Legitimate interests (Article 6(1)(f)) to operate, secure and improve the Website, respond to enquiries, and manage our business communications, provided these interests are not overridden by your rights and freedoms;
- Consent (Article 6(1)(a)), where required, including for certain cookies, analytics technologies and marketing communications;
- Contractual necessity (Article 6(1)(b)), where processing is necessary to take steps at your request prior to entering into a contract; and
- Legal obligation (Article 6(1)(c)), where processing is required by law.
We do not generally rely on vital interests or public task for routine Website processing; these legal bases are included for completeness.
3.3 Legitimate interests
Where we rely on legitimate interests, these include:
- responding to enquiries and communicating with prospective customers;
- operating, maintaining and improving the Website;
- understanding how Visitors use the Website to improve user experience;
- ensuring system security and preventing misuse; and
- managing and developing our business.
We consider and balance any potential impact on you before processing Personal Data on this basis.
4. Data Disclosures
We may share Personal Data with trusted third-party service providers that support our Website and business operations, including providers of hosting, analytics, IT services and communications tools.
All such providers are required to implement appropriate security measures and to process Personal Data only in accordance with our instructions. They are not permitted to use Personal Data for their own purposes.
We do not sell Personal Data.
We may also disclose Personal Data where required to comply with a legal obligation, or in connection with a sale, transfer or reorganisation of all or part of our business.
Some service providers may be located outside the UK. Where Personal Data is transferred internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.
5. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to operate, maintain and improve the Website and to understand how Visitors interact with it.
Further details about the cookies we use, the purposes for which they are used, and how you can manage your preferences are set out in our Cookie Policy.
6. Communications
6.1 Service and administrative communications
We may contact you for administrative or operational purposes, such as responding to enquiries, providing requested information, or notifying you of changes to the Website or Services. These communications are not promotional.
6.2 Marketing communications
Where permitted by law, we may send marketing communications about HubWorx or our Services.
We will only send marketing communications where:
- you have provided your consent; or
- applicable law otherwise permits us to do so.
You may opt out at any time using the unsubscribe link in our communications or by contacting us directly. Opting out of marketing will not affect service-related communications.
7. Data Security
We implement appropriate technical and organisational measures to protect Personal Data against accidental loss, unauthorised access, use, alteration or disclosure.
Access to Personal Data is limited to personnel and third parties with a legitimate business need and who are subject to confidentiality obligations.
We maintain procedures to manage suspected data breaches and will notify affected individuals and regulators where legally required.
8. Data Retention
We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting or reporting requirements.
Retention periods are determined based on the nature and sensitivity of the data, the purposes of processing, and applicable legal obligations.
In some cases, we may anonymise Personal Data so that it can no longer be associated with an individual, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your Privacy Rights
Under applicable data protection laws, you have the right to:
- request access to your Personal Data;
- request correction of inaccurate Personal Data;
- request erasure of Personal Data in certain circumstances;
- object to processing Personal Data based on legitimate interests (note that, in some cases, we may demonstrate compelling legitimate grounds which override your right to object);
- request restriction of processing Personal Data;
- request data portability of Personal Data; and
- withdraw consent where we rely on consent to process your Personal Data.
Requests can be made using the contact details below.
10. Roles and Responsibilities
10.1 HubWorx as data controller
HubWorx Ltd acts as the data controller for Personal Data collected through the Website and determines the purposes and means of processing in accordance with applicable data protection laws.
10.2 Customers and End Users
This Privacy Policy does not apply to Personal Data processed on behalf of customers through the HubWorx platform. In those cases:
- customers act as data controllers; and
- HubWorx acts as a data processor under applicable data processing agreements.
End Users should refer to the relevant customer privacy notice and the HubWorx Privacy Policy for End Users.
10.3 Responsibilities
HubWorx is responsible for lawful, fair and transparent processing of Personal Data and for implementing appropriate safeguards.
Where applicable, you are responsible for ensuring that Personal Data you provide is accurate, up to date and lawfully shared.
11. Additional Notices and Contact Details
11.1 Updates and amendments
We may update this Privacy Policy from time to time. Material changes will be communicated where appropriate. Continued use of the Website after updates constitutes acceptance of the revised policy.
11.2 External links
The Website may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.
11.3 Children
The Website is not intended for children, and we do not knowingly collect Personal Data relating to children.
11.4 Contact and complaints
If you have questions, concerns or complaints about this Privacy Policy, please contact our Data Privacy Officer at dpo@hubworx.ai or write to:
HubWorx Ltd, 72–74 Dean Street, London, England W1D 3SG
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.
