LAST UPDATED: January 12 2018

Introduction

We are an online platform for students, recent graduates and professionals to connect with potential employers. People use our services to discover (recruitment) events, calendars and companies. Companies use our services to promote their (recruitment) events and connect with potential employees. Our Privacy Policy applies to any (Business) Users or Visitor to the covered Services. Our registered users are divided in two categories, being the individual users (“Users”) and the companies looking for talent (“Business Users”). The Users can add their professional identities, discover events and calendars as well as internships and job opportunities, accept invitations to events, apply for private events when invited and follow companies. The Business Users can post their (recruitment) events as well as internships and job opportunities, purchase a subscription that allows them to invite potential talent to their events and open positions as well as view user profiles under the terms and conditions expressed in the user agreement. The content on some of our services is available to non-members (“Visitors”), such as the preview of events, internships and job opportunities on our platform.

Data Controllers
You are entering into the User Agreement with Hubler BVBA in Belgium, who will be responsible for your personal data provided to, or collected by or for, our Services.

Services
This Privacy Policy applies to Hubler.io and other Hubler-related sites, apps, communications and services (“Services”).

Consent
If you use our Services, you will be asked to give consent to the collection, use and sharing of your personal data under this Privacy Policy and agree to the User Agreement. We provide you choices that allow you to opt-out or control how we use and share your data.

Change
We may modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review and give consent to the changes before they become effective. If you object to any changes, you may close your account. If you don't give your consent to the changes, we cannot guarantee continued use of our services. In that case, we will clearly inform you about the reasoning.

1. Information We Collect

1.1 Information You Provide To Us

Registration
To create an account you provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, we ask you for payment (e.g., credit card) and billing information.

Profile
You have choices about the information on your profile, such as your education, work/volunteering experience, skills, photo, city or area, interests and industries. Profile information helps you to get more from our Services, including helping hiring companies find you. It’s your choice whether to include sensitive information on your profile. We do not require members to include sensitive data (e.g., race, ethnicity, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, sexual life or criminal record) in their Hubler profile. If you choose to post any such data, it is visible to others like the rest of the profile information you provide. As a Business User you can add company information such as banners, profile logo, short description of the firm, contact person and his/her email address, links to the company website and its social media accounts as well as events, internship and job positions. As with the User, the company is free to choose which information to provide. The (Business) User is liable for the correctness of the data he or she provides. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey, submit a resume and apply for or save events or calendars or send invitations. If you sync your calendars with our Services, we will collect your calendar meeting information (e.g. times, places, attendees and contacts).

1.2 Information From Others

Content and News
As a Business User, you and others may post content that includes information about you on our Services (as part of an event you are attending). For example, event organisers can link your company to their event when you are participating to it.

Contact and Calendar Information
We receive personal data about you when others import or sync their address book or calendar with our Services, or send messages using our Services (including invitations).

1.3 Service Use

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor. GA makes use of cookies, details of which can be found on Google’s developer guides. For your information, our website uses the gtag.js implementation of GA. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

1.4 Cookies, Web Beacons and Other Similar Technologies

Hubler uses cookies and similar technologies (e.g., local storage, web beacons, pixels, ad tags and device identifiers) to make the use of our platform faster and easier. Cookies are small pieces of data that are automatically saved in your computer’s memory to make it easier to access websites and navigate them in a fast an efficient way. There are several types of cookies, of which we only use the authentication type. This is the most common method used by web servers to know whether the user is logged in or not and on which account they are logged in. This is essential for our platform, as without these cookies, we won’t know which information we can show you, especially concerning more sensitive information such as your profile, your calendar and as a business user your premium features. Without these cookies you would be required to login multiple times during one session. You can control cookies through your browser settings and other tools. By agreeing to the user agreement, you agree to the use of cookies. If anything material changes in our cookie policy, you will be notified and be asked for your consent.

Hubler also makes use of Google analytics which uses cookies as described in section 1.3.

1.5 Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a Hubler invitation to an event, we track whether you have acted on it and will send you reminders.

1.6 Workplace Provided Information

An employer (or other person or entity procuring our Services for your use) may provide us information about their employees or contractors who make use of these Services. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services.

2. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide, support, personalize and make our Services more relevant and useful to you and others.

2.1 Services

We use your data to authenticate you and authorize access to our Services.

Stay Connected
As a User, our Services allow you to follow companies and calendars that interest you. We will use data about you (such as the content you viewed) to suggest other events, calendars internships, job opportunities and/or companies to you. You can also opt to allow us to use your precise location or proximity to suggest interesting events nearby. If you decide to share your address book with us, you have the option to invite your contacts to Hubler and/or notify them about events, calendars, internships, job opportunities or companies on Hubler.

As a Business User, our Services allow you to promote your company, events, internships and job opportunities as well as invite (Business) Users to your events and open positions, depending on your subscription. We will use the data you share on your company page to make suggestions to you about potentially interesting (Business) Users for your activities on Hubler.

Career
With your consent, your profile can be found by those looking to hire or be hired by you. As Business User, you can explore the profiles of interesting talent within the limits of your subscription and their consent as well as the public events and company profiles of other Business Users. As a User, our Services allow you to explore company profiles and the (recruitment) events they are organizing as well as their internships and job opportunities. We will use your data (your profile and activity) to recommend events, calendars, internships and job opportunities and to suggest your profile to companies.

2.2 Premium Services

We sell premium services that allow Business Users to promote their (recruitment) events, internships and job opportunities in a more personal and direct manner. Under certain conditions, these Business Users are allowed to view information from your profile such as your name, current location, current position/education and resume, if you give your consent.

2.3 Communications

We will contact you through email, notices posted on our website and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, content suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices. We also enable communications between you and others through our Services, including for example invitations.

2.5 Marketing

We use data and content about (Business) Users for invitations and communications promoting membership and network growth, engagement and our Services.

2.7 Customer Support

We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs). We will not use the data you provide (e.g. your email address) for marketing purposes (e.g. automatic adding to the newsletter mailing list) when you reach out to us for support, unless requested.

2.8 Aggregate Insights

We use your information to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, their profession or industry, the number of event impressions served or clicked on, or the demographic distribution of visitors to a site.

2.9 Security and Investigations

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our (Business) Users or Visitors.

3. How We Share Information

3.1 Our Services

Profile
As a User, your profile is fully visible to Business Users of our Services under certain conditions. Your settings, your interest in the Business User, the subscriptions they may have and search types (e.g. search using blind or open invites) impact the availability of your profile. As a Business User, your profile is fully visible to everyone, including Visitors.

Posts, Follows, Attends, Messages
Our Services allow viewing and sharing information including through posts and follows.
  • When you share an event, a calendar, internships or job opportunities, the default (which you can change) is to share it publicly. (Business) Users who are not following your calendar, will be able to find and see your events, calendar, internships and job opportunities.
  • Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
  • When you follow organization, you are visible to others and that “page owner” as a follower. We provide aggregate insights about the followers and viewers to the respective page owners.
  • We let senders know when you act on their invitations, subject to your settings where applicable.


Enterprise Accounts
Your employer may offer you access to our enterprise Services such as the subscription package. Your employer can review and manage your use of such enterprise Services. Depending on the enterprise Service, before you use such Service, we will ask for permission to share relevant data from your profile or use of our non-enterprise Services, if you have or use any. For example, your name, current title and location. We understand that certain parts of your profile such as your personal calendar and personal messages are sensitive and so we do not share those with your employer unless you choose to share it with them through our Services (for example, when you attend an internal (recruitment) event).

3.2 Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes. Our third party data processors comply to the GDPR regulation.
Our third party data processors are:
Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

3.3 Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Hubler, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.3 Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. How we store your personal data

4.1 Pseudonymization

The personal data that we collect is stored in an identifiable fashion for use by the user. The content management systems that we use are those of Heroku Postgres (SQL database) and Mailchimp. For data processing purposes we are committed to storing the data in a pseudonymous fashion. This means that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.

4.2 Data security

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. On the one hand, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. On the other hand, we do intend to keep your data as safe as possible for example:
The Hubler platform is hosted by Heroku. Heroku’s physical infrastructure is hosted and managed within Amazon’s secure data centers and utilize the Amazon Web Service (AWS) technology. Images, video and other static Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Amazon’s data center operations have been accredited under:
ISO 27001
SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II)
PCI Level 1
FISMA Moderate
Sarbanes-Oxley (SOX)
For more information check here (https://www.heroku.com/policy/security)
The images on the platform are stored directly on Amazon Web Services (AWS) for which above security measures apply.

4.3 Data breach

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

5. Your Choices & Obligations

5.1 Data Retention

We retain the personal data you provide while your account is in existence or as needed to provide you Services. We will retain your information and keep your profile open until you decide to close your account. However, when your account shows no activity during 3 years, we will ask you whether or not you want to maintain your account by email.

5.2 Rights to Access and Control Your Personal Data

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile to controlling the visibility of your actions to communication controls. You can access the personal data we have on you upon request by email.

5.3 Account Closure

If you choose to close your Hubler account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed. Information you have shared with others (e.g., through event posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other (Business) Users copied out of our Services, even though we will request them to delete those data as well. For business users, your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

6. Other Important Information

6.1 Data controller

The data controller of this platform is Hubler BVBA with company number 683856631 and whose registered office is:
Zerkegemstraat 21
8480 Bekegem
Belgium

6.2 Contact Information

If you have questions or complaints regarding this Policy, please contact Hubler by email: support@hubler.io.