Privacy Policy

We want you to know how we collect, use, share, disclose, and protect information about you. When you access this website, interact with us, and/or hire our Services, it is important that you understand how we process your Personal Data, as described in this Privacy Policy.

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Buyer/Member: An individual or legal entity that purchases any Infoproduct on the Hubla Platform, offered by an Infoproducer. Processing agents: the controller and the processor.

Anonymization: the use of reasonable technical means available at the time of Processing, through which data loses the possibility of direct or indirect association with an individual.

Controller: an individual or legal entity, under public or private law, who is responsible for decisions regarding the processing of personal data.

Personal Data: any and all information related to an identified natural person or information that allows their identification, such as name, address, CPF, RG, general identity documents, telephone number, photo, among others.

Sensitive Personal Data: personal data concerning racial or ethnic origin, religious conviction, political opinion, affiliation with a trade union or a religious, philosophical, or political organization, data concerning health or sexual life, genetic or biometric data, when linked to a natural person.

Processor: an individual or legal entity, under public or private law, that carries out the processing of personal data on behalf of the controller.

Data Subject: the natural person to whom the Personal Data undergoing processing refers. These are, for example, our clients, potential clients, employees, and potential employees.

Processing: any operation carried out with Personal Data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.

Who is the controller of my personal data?

HUBLA TECNOLOGIA LIMITADA, CNPJ/MF No. 36.062.381/0001-80 ("HUBLA"), is the CONTROLLER of your Personal Data collected and processed when accessing our website, interacting with us, and/or contracting our Services.

What data is collected and what is the source of this collection?

All the data that you actively provide to us or that we collect is considered confidential. We are committed to adopting all technical and administrative measures capable of protecting your Personal Data, complying with, for example, the guidelines on security standards established in current legislation.

When you access our website and/or use our Services, different information is collected, falling, basically, into three categories:

1. Data provided by the Data Subject. This is the information provided by you when interacting with us, whether to learn about our services, hire them, conduct tests, ask questions, receive newsletters, participate in our recruitment processes, among other forms of interaction. Such information, depending on the purpose of its collection, includes: name, email, CPF, telephone, address, identity document, corporate name, CNPJ, financial data, photo, among others.

You will be solely and exclusively responsible for the accuracy of the Personal Data provided to HUBLA, as well as for any damages resulting from the inaccuracy and/or obsolescence of such information.

You are responsible for any third-party Personal Data obtained, published, or shared through our Services and confirm that you have the authorization of third parties to provide such data to HUBLA.

2. Automatically collected data. This is information collected when you browse our website and/or use our Services, such as: the Internet Protocol (IP) address used to connect your computer to the internet, login, email address, password, the location of your device or computer; metrics of devices in use, application usage, connectivity data, and any errors or failure events; HUBLA service metrics (for example, technical error occurrences, your interactions with service features and content, your settings preferences, and backup information), your interactions with our emails, our text messages, and our messages sent through communication channels; details about your interactions with our support, such as date, time, and reason for contact, chat communication transcripts, data collected through the use of cookies, web beacons, and other technologies, including ad data (such as data on the availability and distribution of ads, the website URL, as well as the date and time).

3. Data from other sources. This is information collected by HUBLA from third-party partner companies, suppliers, and service providers, protected in accordance with the practices set forth in this Privacy Policy and the restrictions imposed by the data source. Such sources include: (i) service providers that help us determine a location based on your IP address to customize our Services and for other purposes consistent with this Privacy Policy; (ii) security service providers that supply us with data to protect our systems, prevent fraud, and help us safeguard the security of registrations and transactions; (iii) payment service providers that provide us with payment data or updates to such data based on their relationship with you; (iv) online and offline data providers, from whom we obtain aggregated demographic data, interest-based data, and data related to online advertisements; (v) publicly available sources, such as public posts on social media platforms and through public databases that associate IP addresses with Internet Service Providers (ISPs).

Sensitive personal data

HUBLA does not process Sensitive Personal Data when collecting data from potential clients and clients. In certain recruitment processes, the collection of sensitive personal data may occur. In these cases, we will inform and request the Data Subject's consent to process sensitive personal data.

Children and/or adolescents

You must be at least 18 years old to use our Services. Minors may only use our Services with the involvement, supervision, and approval of a parent or legal guardian.

Purposes of processing

We process the collected Personal Data in strict compliance with the terms of the General Data Protection Law (Law No. 13,709/18) and for legitimate and specific purposes, including:

Provide and administer our Services;
Enable the use of our Services;
Process your registration and transactions;
Respond to your requests, questions, and complaints;
Notify you about any changes in the provision and operation of our Services;
Improve and develop our Services;
Support and promote our Services;
Enable your participation in our recruitment processes;
Personalize and adapt your experience on our website;
Detect, prevent, and respond to fraud, abuse, security risks, and technical issues that may harm HUBLA, our customers, or others;
Conduct satisfaction surveys;
Analyze data to improve usability, experience, and interactivity in the use of our Services and/or our website;
Make offers and/or provide recommendations more tailored to your needs or interests, including through marketing campaigns or simulations performed;
Conduct communication and relationship marketing research to improve our Services;
Comply with legal obligations;
Exercise the right of defense in judicial, administrative, or arbitral proceedings;
Comply with decisions from administrative or judicial authorities.

Most of the time, the Processing of your Personal Data will be related to you contracting our Services (or otherwise in your customer relationship with us) or based on your consent, when requested.

Your consent will be requested by us to process Personal Data for a specific purpose that we will communicate to you. When you agree to the processing of your Personal Data for a specific purpose, you may revoke your consent at any time.

If you would like to know more details about how your Personal Data will be processed by HUBLA based on the purposes described in this item, please contact us through our Privacy Channel (privacidade@hub.la).

Data Transfer/Sharing

Any sharing of information is done strictly to the extent necessary and following strict security and confidentiality standards, in compliance with privacy protection laws and regulations, always respecting and ensuring that third parties respect the confidentiality of your information and this Privacy Policy.

We may share your information with third-party service providers and/or partners, such as:

Suppliers, subcontractors, and/or business partners for the proper execution of our Services. For example, professional consultants, accountants, lawyers, data analytics providers, IT consultants performing testing and development work on our commercial technology systems;
Companies responsible for detecting, preventing, or addressing illegal or suspicious activities, technical or security issues, as required or permitted by law;
Advertising and marketing partner companies, to select and serve relevant ads to you, as authorized.

We do not authorize such companies to use or disclose your Personal Data, except for the specific purpose of providing the services contracted by HUBLA (which include the maintenance and improvement of our Services).

We may also occasionally share your Personal Data with tax, judicial, or administrative authorities to comply with applicable laws and/or orders/determinations issued by them.

In the event of any reorganization, restructuring, merger, sale, or transfer of assets, the transfer of data by HUBLA will be necessary for the continuity of the Services offered, such that the receiving party will commit to respecting your Personal Data in accordance with this Privacy Policy.

Purposes of processing

We process the collected Personal Data in strict compliance with the terms of the General Data Protection Law (Law No. 13,709/18) and for legitimate and specific purposes, including:

Provide and administer our Services;
Enable the use of our Services;
Process your registration and transactions;
Respond to your requests, questions, and complaints;
Notify you about any changes in the provision and operation of our Services;
Improve and develop our Services;
Support and promote our Services;
Enable your participation in our recruitment processes;
Personalize and adapt your experience on our website;
Detect, prevent, and respond to fraud, abuse, security risks, and technical issues that may harm HUBLA, our customers, or others;
Conduct satisfaction surveys;
Analyze data to improve usability, experience, and interactivity in the use of our Services and/or our website;
Make offers and/or provide recommendations more tailored to your needs or interests, including through marketing campaigns or simulations performed;
Conduct communication and relationship marketing research to improve our Services;
Comply with legal obligations;
Exercise the right of defense in judicial, administrative, or arbitral proceedings;
Comply with decisions from administrative or judicial authorities.

Most of the time, the Processing of your Personal Data will be related to you contracting our Services (or otherwise in your customer relationship with us) or based on your consent, when requested.

International transfer of personal data outside Brazil

We use international tools to enable the seamless provision of our Services. Therefore, your Personal Data will be transferred outside Brazil when we use, for example, the following tools: MixPanel, Mux, Firebase, Google Cloud, Google Forms.

Regardless of where your information is processed, we will ensure that data is transferred in accordance with this Privacy Policy, as permitted by applicable data protection legislation, and that appropriate contractual, technical, and organizational measures are observed, ensuring greater security for your Personal Data.

Information Security

Once we collect your information, we will use strict procedures and the best security and technology features to attempt to protect your Personal Data against loss, theft, and unauthorized access, use, and alteration, such as data encryption, data access control, and the use of firewalls. However, despite our continuous efforts, you should be aware that it is impossible to guarantee 100% of such protection. The use of our Services under these conditions is a personal decision.

It is important that you protect yourself against unauthorized access to your password and to your computers, devices, and applications. Be sure to log out whenever you finish using a shared computer. If we detect a dangerous security threat worthy of notification, you will be notified and guided through the necessary steps to stay safe.

How long are my personal data kept?

Your Personal Data will be retained by HUBLA, in accordance with applicable legislation, for the period necessary to fulfill the purposes for which it was collected, as described in this Policy, or to comply with applicable legal requirements.

From the moment the purpose for which the Personal Data was collected is achieved or in the event that the Personal Data is no longer necessary to achieve that purpose, it will be deleted within the scope and technical limits of the activities, with retention authorized in the situations provided for by applicable law. Your Personal Data will also be deleted pursuant to a decision by a competent authority.

We reserve the right to anonymize the Personal Data collected and to use such data for analytical purposes. We will use data outside the scope of this Privacy Policy only after its proper Anonymization.

You can obtain more details about the retention of your Personal Data through the communication channels detailed in this Policy, including requesting its deletion at any time.

What are my rights as a personal data subject?

You can contact us at any time to:

Provide and manage our Services;
Confirmation of the existence of processing of your Personal Data;
Obtain information on how to access your Personal Data;
Perform/request the correction of incomplete, inaccurate, or outdated data (in the same way you provided your data to HUBLA, you may correct or update it);
Obtain information about the Anonymization, blocking, or deletion of unnecessary, excessive data, or data processed in non-compliance with the LGPD;
Obtain information about the portability of your Personal Data to another service provider, upon express request;
Request the deletion of data processed with your consent, except in cases of legal custody and others provided by Law;
Obtain information about public or private entities with which HUBLA has shared your data;
Obtain information about the possibility of not providing your consent, as well as being informed about the consequences in case of refusal;
Revoke consent for the Processing of your Personal Data, except in cases provided for by applicable legislation;
Other rights of the Personal Data subject, in accordance with applicable legislation.

To exercise any of your rights set forth above, as well as to determine your preferences in the Processing and use of some of your Personal Data by HUBLA, you can access our Privacy Channel via email at privacidade@hub.la.

For security reasons, we will only be able to fulfill your request if we are sure of your identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the requester.

Cookie Policy

Cookies are mechanisms through which websites store information in your browser while you use the internet, which helps and personalizes your access.

To improve your experience, offer and enhance our Services aiming for greater security during browsing, usability, and interactivity, our website uses the following cookies:

Necessary Cookies: These cookies are essential for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms. If you wish, you can set your browser to block or alert you about these cookies, but some parts of the site may not work properly;
Analytical Cookies: Provide information about how our website is being used so that we can improve the user experience. The data collected is aggregated and anonymized;
Marketing Cookies: Provide information about user interaction with our website content, helping us better understand the effectiveness of our email and website content.

To disable cookies in your browser, follow the instructions typically found in your browser's "Help", "Tools", or "Edit" menus. Please note, however, that some features or services on our website may become compromised and limited as a result.

When will this privacy policy not apply?

HUBLA's website may contain links or connections to websites or services of other companies and organizations. This Privacy Policy will not apply, under any circumstances, to any other solution and/or service other than those made available by us.

Stay alert and read the privacy policies of each third-party website or service you visit or use. HUBLA is not responsible for any violation of the privacy rights of Data Subjects that may be committed by said websites.

What are my marketing choices?

You may consent to have your Personal Data used by HUBLA to promote our Services through checkboxes located on the registration forms.

If you decide that you no longer wish to receive such communications, you may unsubscribe from receiving marketing-related communications at any time by following the instructions provided in such communications.

To unsubscribe from marketing communications sent by any medium, including third-party social networks, you may opt out at any time by unsubscribing through the links available in our communications.

Please note that, even if you unsubscribe from our marketing communications, you will continue to receive important administrative communications from HUBLA related to your activities on our website.

Questions about your privacy at Hubla?

Any questions regarding this Privacy Policy can be addressed through our Privacy Channel via email at privacidade@hub.la. We will be available on business days from 10:00 AM to 6:00 PM and will respond as soon as possible.

HUBLA will make every effort to address all questions you may have about how we process your Personal Data. However, if you still have unresolved concerns, you have the right to lodge a complaint with the National Data Protection Authority.

Changes to this privacy policy

This Policy may be modified at any time, and using our Services after a modification constitutes, to the extent permitted by law, consent to the modified Policy.

Therefore, we recommend that you periodically review our Privacy Policy to stay up to date with the latest information. However, in the event of significant changes, you will be notified in advance through our website or registered email.