Hub Controls Privacy Notice.

Effective date: 25th May 2018

Hub Controls Ltd recognizes that privacy is a fundamental human right and further recognizes the importance of privacy, security and data protection to our customers and partners. This Privacy Notice informs you of our privacy practices and of the choices you can make and rights you can exercise in relation to your personal data, including information that may be collected from your online activity, use of devices, and interactions you have with Hub Controls Ltd offline, such as when you engage with our customer support representatives. Unless otherwise stated, this Privacy Notice applies to all Hub Controls Ltd websites, domains, services, applications, subscriptions and products. For the purposes of the GDPR, Data Protection Acts 1988 and 2003, the data controller is Hub Controls Ltd.

This Privacy Notice does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide for your convenience and information. Accessing those links will cause you to leave the Hub Controls Ltd website and may result in the collection or sharing of information about you by a third-party. We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.

Please read this Notice carefully (together with any other documents referred to on it) as they set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Hub Controls Privacy Notice.

Effective date: 25th May 2018

Hub Controls Ltd recognizes that privacy is a fundamental human right and further recognizes the importance of privacy, security and data protection to our customers and partners. This Privacy Notice informs you of our privacy practices and of the choices you can make and rights you can exercise in relation to your personal data, including information that may be collected from your online activity, use of devices, and interactions you have with Hub Controls Ltd offline, such as when you engage with our customer support representatives. Unless otherwise stated, this Privacy Notice applies to all Hub Controls Ltd websites, domains, services, applications, subscriptions and products. For the purposes of the GDPR, Data Protection Acts 1988 and 2003, the data controller is Hub Controls Ltd.

This Privacy Notice does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide for your convenience and information. Accessing those links will cause you to leave the Hub Controls Ltd website and may result in the collection or sharing of information about you by a third-party. We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.

Please read this Notice carefully (together with any other documents referred to on it) as they set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We do not consider personal data to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

The provision of all other personal data is voluntary, but may be necessary in order to buy and use our products. We may also collect personal data from other sources, as described in the table below.
 

Data you provide directly

Contact details Full name Standard business activity

Advertising
Yes Yes Installation partner Consent

Legitimate interests

Compliance with law
Address Yes Yes
Email address Yes Yes
Phone/mobile number Yes Yes
Payment data Credit/debit card numbers, security code numbers and other related billing information Transaction support Never Yes, only for payment Never
 

Automatically collected data

Environmental data Temperature, humidity, battery voltage and wifi signal strength Normal product operation, support and improvement

Data analytics and statistical research
Yes Yes Anonymous and aggregated data Legitimate interests

Consent
Product usage data Energy usage, adjustments to thermostat settings, schedules and programs, heating system performance measurement and monitoring, and other information that affects energy usage. Normal product operation, support and improvement

Data analytics and statistical research
Yes Yes Anonymous and aggregated data
Device data First start date, model and serial number, software version, IP address and technical information such as battery charge level. Normal product operation, support and improvement Yes Yes No
Application data App version, user agent information (hardware model, application type, operating system) Normal product operation, support and improvement

Data analytics and statistical research
Yes Yes No
Website We collect information about your visits to and your activity on our website. To learn more, read our Cookie policy. Data analytics and statistical research Yes Yes No Consent

Information from third-party sources

Data brokers, social media networks and advertising networks Commercially-available data, e.g. personal data may be collected when you access our applications through social media logins (i.e., logging in to our applications using your Facebook or other social media account). The basic details we receive may depend on your social network account privacy settings. Direct marketing Yes Yes No Consent

We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs. This privacy notice tells you how we, Hub Controls Ltd, will collect and use your personal data. We collect and use personal data to manage your relationship with Hub Controls Ltd and better serve you when you are using our product(s) by personalizing and improving your experience. Examples of how we use data include:

Standard business activity

  1. Transaction support - Assisting you in completing transactions and orders of our products or services, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
  2. Customer experience - Providing you with a seamless customer experience by maintaining accurate contact data, delivering comprehensive customer support, offering products, services, subscriptions and features that may interest you and enabling you to participate in contests and surveys. We also use your data to deliver a tailored experience, personalize the communications you receive and create recommendations based on your use of our product(s).
  3. Normal product operation, support and improvement - Ensuring normal device operation enabling additional features e.g. mobile apps. Improving the performance and operation of our products, solutions, services and support, including warranty support and timely firmware and software updates and alerts to ensure the continued operation of the device or service.
  4. Administrative communication - Communicating with you about our services. Examples of administrative communications may include responses to your inquiries or requests, warranty-related communications, or communications required by law.
  5. Security - Maintaining the integrity and security of our websites, products, features and services and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your information. When you interact with us, we will also take reasonable steps to verify your identity, such as requiring device ID, before granting access to your personal data.
  6. Business operations - Conducting ordinary business operations, verifying your identity, conducting business research and analytics, corporate reporting and management, staff training and quality assurance purposes (which may include monitoring or recording calls to our customer support).

Data analytics and statistical research

  1. Features normal function and improvements – some of the Hub Controller features (e.g. budget control feature) require automatic data analysis to ensure normal operation.
  2. Research and innovation - Innovating new products, features and services using research and development tools and incorporating data analysis activities.

Advertising

  1. Website – We may also collect details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data), and the resources that you access. When you access our website, your computer’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data on the use of our website. This information may be used to help us to improve our site and the services we offer. See our Cookie Policy.
  2. Direct marketing – We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at privacy@hubcontrols.com.

Compliance with law

  1. Compliance with applicable laws, regulations, court orders, government and law enforcement requests, to operate our services and products properly and to protect ourselves, our users and our customers and to solve any customer disputes.

In order for us to provide you our services we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes we would contact you for additional consent.

We may pass your personal data on to third-party service providers contracted to Hub Controls Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide you on our behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with Hub Controls Ltd’s procedures. If we wish to pass your personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. We will not pass on your details to any third parties for marketing purposes.

We may use technologies considered automated decision making. We will not make automated-decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to use such technology. Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  1. Right of access – you have the right to request a copy of the information that we hold about you.
  2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  4. Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  5. Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  6. Right to object – you have the right to object to certain types of processing such as direct marketing.
  7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  8. Right to judicial review – in the event that Hub Controls Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

Hub Controls Ltd at your request, can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information:

  1. Identity and the contact details of the person or organisation that has determined how and why to process your data.
  2. Contact details of the data protection representative, where applicable.
  3. The purpose of the processing as well as the legal basis for processing.
  4. If the processing is based on the legitimate interests of Hub Controls Ltd or a third party, information about those interests.
  5. The categories of personal data collected, stored and processed.
  6. Recipient(s) or categories of recipients that the data is/will be disclosed to.
  7. If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  8. How long the data will be stored.
  9. Details of your rights to correct, erase, restrict or object to such processing.
  10. Information about your right to withdraw consent at any time.
  11. How to lodge a complaint with the supervisory authority.
  12. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  13. The source of personal data if it wasn’t collected directly from you.
  14. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

What forms of ID will you need to provide in order to access your data?

We accept the following forms of ID when information on your personal data is requested:

  1. Government issued photo ID such as a current driving license or passport
  2. Birth certificate

Please take a moment to read through our Privacy and Data Protection policies below.
Hub Controls’ Privacy Notice >
Subject Access Request Form >
Data Subject Consent Withdrawal Form >

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We do not consider personal data to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

The provision of all other personal data is voluntary, but may be necessary in order to buy and use our products. We may also collect personal data from other sources, as described in the table below.
 

Data you provide directly

Contact details Full name Standard business activity

Advertising
Address
Email address
Phone/mobile number
Payment data Credit/debit card numbers, security code numbers and other related billing information Transaction support
 

Automatically collected data

Environmental data Temperature, humidity, battery voltage and wifi signal strength Normal product operation, support and improvement

Data analytics and statistical research
Product usage data Energy usage, adjustments to thermostat settings, schedules and programs, heating system performance measurement and monitoring, and other information that affects energy usage. Normal product operation, support and improvement

Data analytics and statistical research
Device data First start date, model and serial number, software version, IP address and technical information such as battery charge level. Normal product operation, support and improvement
Application data App version, user agent information (hardware model, application type, operating system) Normal product operation, support and improvement

Data analytics and statistical research
Website We collect information about your visits to and your activity on our website. To learn more, read our Cookie policy. Data analytics and statistical research

Information from third-party sources

Data brokers, social media networks and advertising networks Commercially-available data, e.g. personal data may be collected when you access our applications through social media logins (i.e., logging in to our applications using your Facebook or other social media account). The basic details we receive may depend on your social network account privacy settings. Direct marketing

We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs. This privacy notice tells you how we, Hub Controls Ltd, will collect and use your personal data. We collect and use personal data to manage your relationship with Hub Controls Ltd and better serve you when you are using our product(s) by personalizing and improving your experience. Examples of how we use data include:

Standard business activity

  1. Transaction support - Assisting you in completing transactions and orders of our products or services, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
  2. Customer experience - Providing you with a seamless customer experience by maintaining accurate contact data, delivering comprehensive customer support, offering products, services, subscriptions and features that may interest you and enabling you to participate in contests and surveys. We also use your data to deliver a tailored experience, personalize the communications you receive and create recommendations based on your use of our product(s).
  3. Normal product operation, support and improvement - Ensuring normal device operation enabling additional features e.g. mobile apps. Improving the performance and operation of our products, solutions, services and support, including warranty support and timely firmware and software updates and alerts to ensure the continued operation of the device or service.
  4. Administrative communication - Communicating with you about our services. Examples of administrative communications may include responses to your inquiries or requests, warranty-related communications, or communications required by law.
  5. Security - Maintaining the integrity and security of our websites, products, features and services and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your information. When you interact with us, we will also take reasonable steps to verify your identity, such as requiring device ID, before granting access to your personal data.
  6. Business operations - Conducting ordinary business operations, verifying your identity, conducting business research and analytics, corporate reporting and management, staff training and quality assurance purposes (which may include monitoring or recording calls to our customer support).

Data analytics and statistical research

  1. Features normal function and improvements – some of the Hub Controller features (e.g. budget control feature) require automatic data analysis to ensure normal operation.
  2. Research and innovation - Innovating new products, features and services using research and development tools and incorporating data analysis activities.

Advertising

  1. Website – We may also collect details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data), and the resources that you access. When you access our website, your computer’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data on the use of our website. This information may be used to help us to improve our site and the services we offer. See our Cookie Policy.
  2. Direct marketing – We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at privacy@hubcontrols.com.

Compliance with law

  1. Compliance with applicable laws, regulations, court orders, government and law enforcement requests, to operate our services and products properly and to protect ourselves, our users and our customers and to solve any customer disputes.

In order for us to provide you our services we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes we would contact you for additional consent.

We may pass your personal data on to third-party service providers contracted to Hub Controls Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide you on our behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with Hub Controls Ltd’s procedures. If we wish to pass your personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. We will not pass on your details to any third parties for marketing purposes.

We may use technologies considered automated decision making. We will not make automated-decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to use such technology. Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  1. Right of access – you have the right to request a copy of the information that we hold about you.
  2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  4. Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  5. Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  6. Right to object – you have the right to object to certain types of processing such as direct marketing.
  7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  8. Right to judicial review – in the event that Hub Controls Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

Hub Controls Ltd at your request, can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information:

  1. Identity and the contact details of the person or organisation that has determined how and why to process your data.
  2. Contact details of the data protection representative, where applicable.
  3. The purpose of the processing as well as the legal basis for processing.
  4. If the processing is based on the legitimate interests of Hub Controls Ltd or a third party, information about those interests.
  5. The categories of personal data collected, stored and processed.
  6. Recipient(s) or categories of recipients that the data is/will be disclosed to.
  7. If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  8. How long the data will be stored.
  9. Details of your rights to correct, erase, restrict or object to such processing.
  10. Information about your right to withdraw consent at any time.
  11. How to lodge a complaint with the supervisory authority.
  12. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  13. The source of personal data if it wasn’t collected directly from you.
  14. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

What forms of ID will you need to provide in order to access your data?

We accept the following forms of ID when information on your personal data is requested:

  1. Government issued photo ID such as a current driving license or passport
  2. Birth certificate

Please take a moment to read through our Privacy and Data Protection policies below.
Hub Controls’ Privacy Notice >
Subject Access Request Form >
Data Subject Consent Withdrawal Form >