We, at HUBII BR LTDA. ("Hubii"), value your privacy. The protection of personal data is part of our essence, our values, our mission, and our day-to-day operations. We have prepared this Privacy Policy so that you can understand, clearly and simply, what our practices are regarding your privacy and the protection of your personal data. We want you to get to know our services and become our client with peace of mind and security, knowing that your privacy is not at risk and that we are committed to being transparent.
If, after reading this Privacy Policy, you have any questions about the processing of your personal data, please contact us through the following channel: [email protected].
When browsing the website of HUBII BR LTDA. (https://www.hubii.com.br/) or any channels belonging to HUBII BR LTDA., as well as when contacting us via email or WhatsApp, some personal data may be processed. We are committed to the security of your personal data, and in this document we will help you, the user, understand our data protection practices, with a description of what information is collected, how it is used, and how it is shared. Whenever you provide personal information, we will process that information in accordance with this Policy. At all times, we strive to keep your data accurate and secure.
WE RECOMMEND THAT THIS DOCUMENT BE READ CAREFULLY. IT DESCRIBES HOW THE PERSONAL INFORMATION YOU PROVIDE TO ACCESS OUR WEBSITE, ALL OF OUR CHANNELS, AND TO USE OUR SERVICES IS HANDLED.
BY READING THE TEXT BELOW AND SHARING YOUR DATA WITH US, YOU AFFIRM THAT YOU KNOW AND UNDERSTAND THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, AGREEING TO THESE CONDITIONS FREELY AND VOLUNTARILY.
What Personal Data Do We Process?
When you request information about our solutions or contract our services, we collect your name, mobile phone number, email, job title/role, city, and state, in addition to the name of the institution and sector you represent. If you contract our services, we collect the personal data necessary to formalize the agreement, such as your CPF number (Brazilian taxpayer ID), address, payment details, and social media information.
When you interact with any other channel under our management, such as Delivery Apps, Marketplaces, E-commerce Platforms, WhatsApp, etc., with the intention of purchasing products from our partners, we collect your name, CPF, mobile phone number, email, delivery address, and the items/products you selected on any of the platforms mentioned.
What Type of Information Do We Collect?
We collect certain information when the user, as the data subject, accesses our website, contacts us via WhatsApp, uses the form in the CONTACT field, or interacts with the various channels under our management. This information is important to maintain an open communication channel, with prompt and accurate responses to the user, whether for commercial negotiations or for the purchase of products from our partners.
Collection takes place directly when the user themselves uses the:
- Form: when contacting us through the website, we collect some personal data, such as full name, email, and the name of the company represented, where applicable. By filling out the form, we may contact the user to collect additional information necessary to handle the request made.
- Delivery Apps, Marketplaces, E-commerce Platforms, WhatsApp, etc.: when interacting with the channels under our management, on the various platforms we integrate with, and when placing purchase orders on these platforms, we collect the necessary information — buyer data, delivery address, and items purchased — in order to process and deliver the orders. We may also use buyers' contact data to provide proper consumer support, so that the order is fulfilled and delivered with the best possible experience.
We keep your data for as long as necessary to provide our services. Your data remains stored on database servers that have protection systems (firewall) until the purpose for which it was collected is fulfilled.
Indirectly:
Hubii may also collect data automatically, through browsing cookies, third-party tools such as Google Analytics, Facebook Ads, and the like, or third-party plugins that operate from the user's own browser.
Cookies are addressed in a dedicated section of our Policy, and we hereby inform you that the user has the right to restrict access to cookies or to browse anonymously by configuring their browser on their own. However, we do not rule out that this option may cause some inconsistency in the website's functionality, resulting in an unsatisfactory browsing experience.
Automatic data collection occurs in various ways, depending on the criteria and technologies used by the third-party tools; some of these are: an anonymous user code, access IP, the type of device used for browsing, the date and time of browsing, country of origin, and other general information.
In addition, search engines (for example, Google) and social networks (for example, Facebook, Instagram, or similar) may provide plugin-style tools that connect to the website to generate information through cookies and display related ads. The fact that the user is shown ads relating to the same products or services does not mean identification.
How Is My Information Used?
The personal data we collect is used to communicate with you and to inform you about the services and solutions of HUBII BR LTDA, or to fulfill the orders you may place on any of the channels under our management. You may choose to have your data removed from our databases at any time — simply contact us by email at: [email protected]. We do not process data related to crimes or criminal organizations. Personal data submitted by individuals under 18 years of age is also not processed without the consent of a legal guardian. Any such data that happens to reach our database will be immediately deleted.
Information Sharing
Except with regard to cookies, the specific details of which you will find in the dedicated section, we do not share your data with third parties, except with our information storage partners (the server owners), with the companies that make up our economic group, or in the event of a legal requirement, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that, for purposes of national security, law enforcement, or other matters of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users. In addition, in the event of a reorganization, merger, or sale, we may transfer any and all personal information we have collected to relevant third parties.
Any change to this standard will always be transparent and for specific purposes communicated to you in advance.
Remember that when you use a link to go from our website to another website or to request a third-party service, our Policy no longer applies. Your browsing and interaction on any other website, or your dealings with any other third-party service provider, are subject to the rules and policies of that third-party service provider or website itself. Likewise, your interaction on the channels under our management (Delivery Apps, Marketplaces, E-commerce Platforms, WhatsApp, etc.) is subject to the rules and policies of the channel itself.
We do not monitor, control, or endorse the information collection or privacy practices of third parties. We encourage you to familiarize yourself with the privacy practices of all websites, channels, apps, etc. that you visit, or of the third-party service providers you deal with, and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to the data collected by us through our website and the channels under our management (Delivery Apps, Marketplaces, E-commerce Platforms, WhatsApp, etc.) and does not apply to third-party websites and outsourced service providers.
Data Subjects' Rights
Hubii is committed to the effectiveness of the rights granted to Personal Data Subjects by the LGPD and the GDPR. Therefore, it necessarily ensures the following rights:
| Data Subject's Right | Description |
|---|---|
| Right to Confirmation of the Existence of Processing | Assurance to Data Subjects of obtaining, at any time and upon request, confirmation of whether or not their data is being Processed. |
| Right of access | Assurance to Data Subjects of free and easy consultation regarding the form and duration of the Processing, as well as the integrity of their Personal Data. |
| Right to data quality | Assurance to Data Subjects of the accuracy, clarity, relevance, and updating of the data, in accordance with the need and for the fulfillment of the purpose of its Processing. |
| Right to anonymize, block, or delete personal data | Assurance to Data Subjects of the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD and the GDPR. |
| Right to portability | Assurance to Data Subjects of the portability of their data to another service or product provider, upon express request, in accordance with the regulations of the ANPD and the DPA, observing trade and industrial secrets. |
| Right to information | Assurance to data subjects of information, including about the public and private entities with which their data has been shared. |
| Right not to consent | Assurance to data subjects of being informed about the possibility of not giving their consent and about the consequences of refusal. Likewise, it includes the guarantee of withdrawing consent. |
| Right to Review of Automated Decisions | Assurance, for Data Subjects, of the review of decisions made solely on the basis of the automated Processing of Personal Data that affect their interests, including decisions intended to define their personal, professional, consumer, and credit profile, or aspects of their personality. |
Data Subjects' rights will be fulfilled through our DPO channel, by email: [email protected]. Hubii will proceed with positivity, cooperation, and assistance regarding the request, in order to resolve it satisfactorily without the need to resort to regulatory bodies or external courts. The data subject is therefore expected not to hesitate to present their request to Hubii. The response time is up to 15 (fifteen) days.
In the event of legal or regulatory obligations, protection against possible future lawsuits, or for the maintenance and continuation of the services offered, your personal data will not be deleted, and processing will be maintained in accordance with the legal bases set out above and for the purposes stated in this Privacy Policy and other supplementary documents.
Information Security
We are always concerned about the security of our clients and the users of our website. Our information is stored on the servers of companies equally concerned with security, with redundancy and cloud storage, featuring high technology and information protection.
Only authorized persons have access to the personal data processed by us, and such access is granted only after the execution of a confidentiality commitment, always ensuring the privacy of data subjects' data.
We apply information security tools always taking into account the nature of the personal data collected, the context and purpose of the processing, and the risks that any breaches could pose to the rights and freedoms of the subject of the data collected and processed.
Accordingly, we understand that no available technology will ever be enough to prevent 100% of attacks or unauthorized access. In the unlikely event of a leak or breach of the privacy of data subjects' data, we will communicate within a reasonable time which data was affected and all the measures we have taken to repair any damage.
Cookies and Similar Technologies
Our website uses cookies(*), either our own or third-party, provided by Google Analytics, Facebook Ads, Instagram, etc., to track interactions with the visitor, and may store information such as the time at which the current visit occurred, whether the visitor has been to the site before, or whether there was any referral leading to access to our site.
*Cookie: a file placed on your computer to track movements within the site, such as page visits and ads. Cookies do not store personal information unless you have provided it, and do not collect information stored on your computer. Browsers do not share your cookies across domains.
We also do not rule out the indirect creation of cookies due to third-party services made available through our website, for the automatic collection of general browsing information, in order to improve and add more value to the user's experience on our site.
You may choose not to provide cookies at any time by disabling the respective function in your browser, aware that by doing so, the services provided to the user may not present all of their functionalities.
Updates to the Privacy Policy
We may, at any time and periodically, if necessary, change this privacy policy to comply with legislative changes, requirements of regulatory bodies, or operational needs. If the change is significant, both versions (the previous and the updated one) will be available on the website for comparison.
Agreement
By providing your data, you agree to this Data Privacy Policy, which is in accordance with national legislation — Law No. 12.965/14 (Marco Civil da Internet – Brazilian Internet Act), Law No. 13.709/2018 (LGPD – General Data Protection Law), and Law No. 12.527/2011 (Access to Information Act) — and any dispute involving this Policy shall be subject to national jurisdiction.
Contact the DPO
In accordance with Article 41 of Law No. 13.709/2018, we inform you that Felipe Latif Mechailech has been appointed to act as the DATA PROTECTION OFFICER (DPO) of HUBII BR LTDA., and can be contacted through the following channel:
Email: [email protected]
Curitiba/PR, April 24, 2024.