This End User Privacy Policy explains how HubWorx Ltd ("HubWorx", "we", "us" or "our") processes personal data in connection with the use of the Services, including the HubWorx Employee Hub, by individuals who access the Services at the direction of one of our customers ("End Users").
This policy applies to End Users who access HubWorx via our web application and iOS and Android mobile applications (collectively, the "Platform").
This End User Privacy Policy should be read alongside the privacy notice provided by the organisation that has granted you access to HubWorx (your employer or contracting organisation, referred to as the "Customer").
Definitions
For the purposes of this End User Privacy Policy:
- "Services" means the HubWorx Employee Hub and related services provided to Customers, including the functionality, features and capabilities made available through HubWorx from time to time.
- "Platform" means the HubWorx software applications and interfaces (including iOS and Android mobile applications, the web application and the Admin Hub) through which End Users access and use the Services.
- "Customer" means the organisation (such as your employer or contracting organisation) that has entered into an agreement with HubWorx to use the Services.
- "End User" means an individual authorised by a Customer to access and use the Platform, including employees, contractors, frontline workers and managers.
- "Personal Data" means any information relating to an identified or identifiable individual, as defined under applicable data protection laws.
The Services are designed to support internal communication and access to information within an organisation and may include features such as content sharing, messaging, document access, notifications, integrations and administrative tools, as configured by the Customer.
1. Our role in processing your personal data
For the purposes of data protection laws, including the UK GDPR and EU GDPR:
- the Customer acts as the data controller, determining the purposes and means of processing your personal data; and
- HubWorx acts as a data processor, processing personal data only on the Customer's documented instructions and in accordance with applicable data processing agreements.
In limited circumstances, HubWorx and a Customer may each act as independent data controllers in respect of different categories of data they separately determine. This does not change the way End User data is processed within the Platform, which is performed on Customer instructions.
If you have questions about why or how your personal data is used within HubWorx, you should contact your Customer in the first instance.
2. Personal data we process about End Users
The categories of personal data processed about End Users depend on how the Customer configures and uses the Platform. These may include:
- Identity Data (such as your name and role)
- Contact Data (such as your work email address)
- Employment or organisational information (such as department, team or employee identifier)
- Profile information (such as a profile photo or avatar, where enabled)
- Login and access data (such as IP address, device information, login timestamps and authentication details)
- User-generated content (including messages, comments, acknowledgements, documents or other content created within the Platform)
- Usage data (information about how you interact with Platform features)
- Support-related data (where you interact with support services through the Platform)
HubWorx does not process special category personal data, payment data, or private communications outside the Platform.
3. How personal data is collected
Personal data is collected when:
- a Customer creates or manages your account;
- you access and use the Platform;
- you upload content, send messages, or interact with Platform features; or
- the Platform generates technical or usage data as part of its normal operation.
HubWorx does not independently collect End User personal data for its own purposes.
4. How personal data is used
HubWorx processes End User personal data solely to provide, operate, secure and support the Platform on behalf of the Customer. This includes:
- enabling access to the Platform and its features;
- delivering communications and notifications configured by the Customer;
- facilitating collaboration, messaging and content sharing;
- operating search, audit logs and administrative controls;
- maintaining system security and integrity; and
- providing technical support and troubleshooting.
HubWorx does not use End User personal data for advertising purposes and does not monitor End Users beyond what is necessary to operate the Platform as configured by the Customer.
5. Product analytics and service improvement
HubWorx uses product analytics tools to understand how the Platform performs and to improve reliability, functionality and user experience.
All product analytics are aggregated and anonymised and are not used to identify individual End Users. Analytics data is used solely for service improvement and operational purposes and is processed in accordance with applicable data protection laws.
6. Data sharing and sub-processing
HubWorx may engage trusted sub-processors to support delivery of the Platform, such as infrastructure, hosting and security providers.
All sub-processors are subject to contractual obligations that ensure appropriate data protection and security measures. HubWorx does not permit sub-processors to use End User personal data for their own purposes.
A list of sub-processors may be made available to Customers in accordance with applicable agreements.
7. International data transfers
The Platform is primarily hosted in the United Kingdom.
End User personal data is not transferred outside the UK or European Economic Area unless appropriate safeguards are in place in accordance with applicable data protection laws.
8. Data security and access controls
HubWorx implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or disclosure.
Access to End User personal data is restricted to authorised HubWorx personnel who require access to perform their role, using role-based access controls and subject to confidentiality obligations.
9. Data retention
Personal data is retained for the period determined by the Customer, in accordance with their configuration of the Platform and applicable legal requirements.
HubWorx retains personal data only for as long as necessary to provide the Services or as otherwise instructed by the Customer.
10. Your data protection rights
As an End User, your rights in relation to your personal data are determined by the Customer as data controller.
To exercise your rights (such as access, correction or deletion), you should contact your employer or contracting organisation directly. HubWorx will support Customers in responding to such requests where required by applicable data protection laws.
11. Changes to this policy
We may update this End User Privacy Policy from time to time to reflect changes in the Platform or applicable legal requirements. Updates will be made available through appropriate channels.
12. Contact information
If you have questions about this End User Privacy Policy or how HubWorx processes personal data on behalf of Customers, you may contact us at:
Email: dpo@hubworx.ai
Address: HubWorx Ltd, 72–74 Dean Street, London, England W1D 3SG
