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Privacy policy & Data Processing Agreement

Privacy Policy last updated: May 24th, 2018

Privacy Policy

1. Important Information

1.1. General terms

At hubsell (“hubsell,” “we,” “us” or “our”), putting our users (“you” or “your”) first means exceeding global privacy and data protection standards in order to keep important contacts and sensitive data and communications private, safe and secure.

We set up our infrastructure, applications and tools in a way that enables you to strengthen and leverage your important relationships when they matter the most, without having to worry about data security or privacy concerns.

Our Privacy Promise:

No one will access, read, or delete your emails.

When hubsell connects to your email server, we pull only the minimum amount of information required for our service to function.

Our server only stores emails you have sent via hubsell and any responses you received to those emails, so we can detect replies and you can have access to them from the application.

You own your data.

Your personal data will be kept private according to this policy and to the greatest extent allowed by the law.

Additional questions? Don’t hesitate to send us an email at

hubsell is committed to maintaining the privacy and security of any of your personal information on the website or in our applications or information received in any other manner. This Privacy Policy (“Agreement” or “Policy”) defines how hubsell uses and protects any personal information that it collects and stores.

For the purpose of this Policy, “Personal Information” means information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual.

For the purpose of this Agreement, “Services” refers to the Company’s website which can be viewed or accessed at (“Website”), our applications or any other services that we may supply to you which are further described in our Terms of Service.

By accepting our Policy and our Terms of Service, you expressly consent to our collection, storage, processing, use and disclosure of your Personal information as described in this Policy.

In case your organization acts as a data controller under ‘General Data Protection Regulation (EU) 2016/679’ of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data you will need to sign or agree to an additional Data Processing Agreement with hubsell in order to process data in our Services.

1.2. Revision of the Privacy Policy

hubsell reserves the right to revise, modify or update this Policy at any time. Your continued use of the Services after any such revisions, modifications or updates constitutes your acceptance of any such change.

If we make any material changes we will notify you by posting the revised Privacy Policy on our Website or conspicuously in the Services and, if you subscribe to our Subscription Service, providing notice through the in-app Notifications.

2. Use of our services

2.1. Our customers use

You can use the Services to create communication campaigns in order to reach out to or nurture prospects with sales, marketing or customer success purposes.

hubsell does not control the content of campaigns (text, email or other communications templates) or the types of information that our customers may choose to collect or manage using the Services.

That information belongs to you and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy.

hubsell processes our customers’ information as they direct and in accordance with our agreements with our customers, and we store it on our service providers’ servers, but we do not have control over its collection or management.

hubsell acknowledges that you have the right to access your Personal Information.

You control and are responsible for correcting, deleting or updating information they have collected from you using the Services.

If requested to remove data we will respond within a reasonable timeframe.

We may work with you to help them provide notice to their visitors about their data collection, processing and usage.

Our agreements with you customers prohibit usage of the Services to collect, manage, or process Sensitive Information.

We are not responsible for your customers’ use of information on the Services.

hubsell collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes.

If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our Services, please contact the customer that you interact with directly or leave a request on our Trust page.

We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the processing agreements with our customers.

2.2. “Sensitive Information”

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

3. Information We Collect

When you provide hubsell with your Personal Information you consent to our providing your information to any third parties that are necessary to offer, support and improve the Services.

hubsell also collects Personal Information from you when you place an order including your name, physical address, email address. hubsell only uses this data for the purpose of fulfilling orders or communicating with you and hubsell’s partners regarding the Services.

3.1. When You Visit our Website

You are free to explore our Website without providing any Personal Information about yourself. hubsell collects your Personal Information when you register and open an account with hubsell to help us operate and support the Services and to contact you in connection with your use of the Services. Also we collect navigational Information.

3.2. “Personal Information”

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.

Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

3.3. “Navigational Information”

This refers to information about your computer and your visits to and use of the Services such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.

We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, to verify users have the authorization needed for the Services to process their requests, and for advertising purposes.

For more details please see the “Navigation Information” section below.

3.4. Payment Information

We collect and process payment information from you when you subscribe to the Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.

3.5. Information About Children

The Websites and our Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at, so that we may delete the information.

3.6. Information You Provide

You may also provide us information that you post to the Services. Your questions, answers, and other contributions on the Services, and metadata about them (such as when you posted them), are publicly viewable on the Services. This information may be found by search engines and be published elsewhere on the web in accordance with our Terms of Service and this Policy.

3.7 Google User Data

If you choose to connect a Gmail account, we will, after we have confirmed your permission, securely access information obtained from your account. In particular, we may need to access your inbox folder in order to detect replies to emails, that have been sent via hubsell; this is necessary in order to make work the core functionality of our Services work as intended.

Our servers only stores emails you have sent via hubsell and any responses you received to those emails, so we can detect replies, classify them and you can have access to them from the Services.

Also, we may store your authentication token and account email address. This data will be securely stored in order to be used by hubsell to provide you with the Services (including but not limited to logging in to your account, sending emails via the hubsell platform, accessing emails you sent and viewing replies you received). Under no circumstances will this data be voluntarily shared with any third parties; hubsell would only provide this information to legal authorities upon their rightful request or in the case of an emergency. Should you choose to disconnect your Gmail account or choose to close your account, any information from Google stored on our servers will be deleted permanently.

3.7.1 Use of Sensitive or Restricted scopes

hubsell’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. Should you have any questions or comments regarding how we use Google APIs, please feel free to contact us at

3.8 Web beacons

We may also collect information using web beacons (also known as “tracking pixels”).

4. Use of Information We Collect

4.1. We do not sell Personal Information

We do not sell your Personal Information to any third party.

4.2 Navigational data, cookies and web beacons.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. hubsell uses cookies to identify and track visitors, and your website access preferences.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the hubsell Services.

Web beacons are electronic images (also called “gifs”) that may be used in the hubsell Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

You can decline to show gifs or pictures in your email clients to avoid being tracked by email web beacons.

Also we use Navigational Information to operate and improve the Services.

4.3 Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

(a) improve your browsing experience by personalizing and improving the Services;

(b) send information to you which we think may be of interest to you by post, email, or other means;

(c) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, and

(d) provide other companies with aggregated and Non-Personal Information about our users — but this information will not be used to identify any individual user,

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party.

In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your personal information with these companies, contact us at

We use the information collected/stored via our Services by our customers for the following purposes:

(a) to provide the Services (which may include the detection, prevention and resolution of security and technical issues);

(b) to respond to customer support requests;

(c) otherwise to fulfill the obligations under the hubsell Terms of Service.

4.5. Customer Testimonials and Comments

We post customer testimonials and comments in our Services, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

4.6. Use of Credit Card Information

If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

4.7. Service Providers

We employ other companies and people to provide services to the visitors and users of the Services and we may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive or invalid information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such third parties, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

4.8. Confidentiality and Security of personal information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

All the Personal Information we have where hubsell acts as a processor for a customers data (e.g., use of the hubsell Services) is encrypted via database encryption. All connections to our Website or Services are protected via the use of encrypted connections, such as the Secure Socket Layer (SSL) protocol.

Also we do store all email accounts or email accounts passwords we use to provide our services via your emails servers encrypted.

Do not forget that your account in hubsell service is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and keep it long and complicated enough and by logging out of your account after each use.

If you have any questions about the security of your Personal Information, you can contact us at

4.9. Social Media

Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

4.10. External Websites

Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

4.12. Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information.

We will delete this information from the servers at an earlier date if you so request, as described in “Opting Out and Unsubscribing” below.

If you provide information to our customers as part of their use of the hubsell Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Service, then we will provide customer with access to all information stored for the customer by the Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the hubsell Service.

4.13. International Transfer of Information

All our employees and contractors related to working with personal data as part of their duties are signed agreements that covers hubsell and their responsibility regarding transfer of data to remote working locations.

4.14. Sharing with Third party applications

Certain aspects of the hubsell Service allow or require you to connect with third party applications or services. In connection with your use of any such third party applications or services, such third parties may receive information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary.

The hubsell Service may automatically collect and upload certain data from such applications via direct integrations or proxy services.

This Privacy Policy does not apply to your use of such third party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

4.15. Compelled Disclosure

hubsell reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and security breaches , or comply with a law, court order, or legal process.

4.16. Data retention

After hubsell account cancellation all the data within this account are due to be deleted in 60 days period time.

At the same time personal data of customers could be retained longer as it needed for providing legal and financial trace of past operations up to the time required by US law.

5. Opting Out and Unsubscribing

5.1. Reviewing, Correcting and Removing Your Personal Information

Upon request hubsell will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:

To review the user information that you have supplied to us

To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us

To request that your user information not be used to contact you

To request that your user information be removed from any solicitation list that we use

To request that your user information be deleted from our records

To opt out of being solicited by hubsell or third parties

To exercise any of these rights, please contact us at We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

5.2. Anti-Spam Policy

We at hubsell committed to provide customers with tools and expertise to curate highly targeted and relevant communications via our platform. We monitor and prohibits use of the hubsell Service to send unsolicited commercial email in violation of applicable laws as stated in our Terms of service, and requires the inclusion in every email sent using the Service of an “opt-out” mechanism and other required information.

We require all of our customers to agree to adhere to the Terms of Service Policy at all times, and any violations of the Terms of Service Policy by a customer can result in suspension or termination of the hubsell Service.

We also provide customers with the tools to manage their sending reputation and customer success team work closely to monitor all customer metrics and best-practices to ensure high quality and targeted campaigns.

5.3. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us email us at Customers cannot opt out of receiving transactional emails or notifications related to their account with us or the hubsell Service.

5.4. To Unsubscribe from Our Customers’ Communications

Our customers are solely responsible for their own sales or marketing emails and other communications;

We make sure that all emails sent using hubsell service has proper unsubscribe mechanics (links or text + Auto opt out).

You can unsubscribe from our customers’ communications by clicking on the “unsubscribe” link located on the bottom of their emails, responding to unsubscribe via email or by contacting them directly.

Contact Us

Any questions about this Privacy Policy should be addressed to

Data Protection Supplement

This Privacy and Data Protection Supplement (“Supplement“) supplements the hubsell Terms of Service (“hubsell TOS”) and as such is part of the agreement that we have with you for your use of the Services (the “Agreement“).

The contents of the hubsell TOS shall apply to this Supplement.

Next to the definitions as provided in article 1 below, terms used in this Supplement have the same meaning as those used in the hubsell TOS, unless explicitly provided otherwise. If there are any conflicts or inconsistencies between this Supplement and hubsell TOS, the provisions in this Supplement prevail.


Applicable Data Protection Law” means all laws and regulations and sectoral recommendations containing rules for data protection and privacy which are applicable to the processing of Personal Data under the Agreement (e.g. the General Data Protection Regulation 2016/679/EC), including without limitation security requirements.

Approved Measure” means a code of conduct or certification mechanism as meant in article 46 of the General Data Protection Regulation.

EC Standard Contractual Clauses” means the EC Standard Contractual Clauses as published in the Decision of the European Commission of February 5, 2010 (Decision 2010/87/EC).

Data Subjects” means any individual whose Personal Data is processed by hubsell in the course of the performance of the Agreement.

Non-Adequate Country” means a country that is deemed not to provide an adequate level of protection of Personal Data within the meaning of the General Data Protection Regulation 2016/679/EC.

Personal Data” means any information relating to a Data Subject.

Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Sub-Processor” means any Third Party that processes Personal Data under the instruction or supervision of hubsell but that does not fall under the direct authority of hubsell.

Third Party” means any party other than the parties to the Agreement.

1. Description of the processing

1.1 The subject-matter of this Supplement is the processing of Personal Data by hubsell on behalf of you and in accordance with your written instructions as described in the Agreement (which includes this Supplement) or otherwise in writing.

1.2 This Supplement shall be valid for the duration of the Agreement. The nature and purpose of the processing, the types of Personal Data and the Data Subjects concerned are described in the Agreement.

2. Instructions

2.1 hubsell shall process Personal Data as described in this Supplement only (i) on behalf and for the benefit of you, (ii) in accordance with the instructions you provide to us through your Member Account and (iii) for the purposes authorised by the Agreement. hubsell shall comply with Applicable Data Protection Law when carrying out the obligations under the Agreement.

2.2 hubsell shall not process the Personal Data further than as instructed in writing and as strictly necessary for the performance of the Agreement, or as required by applicable EU or EU member state law. In case of such requirement of EU or EU member state law, hubsell shall inform you of that legal requirement before the processing takes place, unless that law prohibits such information on important grounds of public interest.

3. Non-disclosure and confidentiality

3.1 hubsell shall keep Personal Data confidential and shall not disclose Personal Data in any way to any Third Party without your prior written approval, except where, subject to this Supplement, (i) such disclosure is required for the performance of the Agreement or the processing by a Sub-Processor, (ii) where Personal Data need to be disclosed as required for audit purposes as described in article 10 or (iii) such disclosure is allowed in accordance with article 11 of this Supplement.

3.2 hubsell shall ensure that any employee, agent, contractor or any other person working under the direct authority of hubsell is committed to respect and maintain the confidentiality and security of the Personal Data.

4. Security

4.1 hubsell applies technical, physical and organisational security measures to it systems and data as described in the Annex to this Supplement. You agree that these security measures ensure an appropriate level of information security as required per article 32 GDPR. Please note that the security measures may be updated in the future if required to enable hubsell to meet the conditions of article 32 GDPR. If that happens then we will make sure to provide you with an updated Annex.

5. Sub-Processors

5.1 hubsell shall only permit Sub-Processors to process Personal Data with your prior written consent. hubsell will remain fully liable to you for the Sub-Processor’s performance of the Agreement and this Supplement.

5.2 hubsell shall ensure that Sub-Processors are contractually bound to the same restrictions and obligations with respect to the processing as those to which hubsell is bound under the Agreement and this Supplement.

5.3 You are deemed to have consented in writing to the processing of Personal Data by our current Sub-Processors. The identity of these current Sub-Processors will be communicated to you by hubsell subject to your prior request. hubsell shall inform you of any intended changes concerning the addition of processor or their replacement, thereby giving you the opportunity to object to such changes.

6. Cooperation obligations

6.1 hubsell shall deal promptly and appropriately and in a commercially reasonable manner with your enquiries or requests for assistance of related to the processing under the Agreement.

6.2 hubsell shall cooperate with you and provide assistance in cases where Data Subjects wish to exercise their rights of access, rectification, erasure, restriction or data portability in the following manner. Our cooperation and assistance is provided to you exclusively by providing you with the functionality of the Software. The Software will enable you to delete, extract and amend Personal Data or unsubscribe a particular Data Subject from receiving further communications from you. If a record is deleted on the request of a Data Subject you must retain a record of such deletion to ensure that the record of that Data Subject remains deleted over time in the database that is connected to the Software.

6.3 hubsell shall cooperate with and you in as far as this is reasonably necessary for you to be able to comply with your data protection impact assessment and prior consultation obligations under Applicable Data Protection Law. You agree that we are entitled to (partly) provide this cooperation by sending you a copy of a data protection impact assessment that we have conducted ourselves.

7. Personal Data Breaches

7.1 hubsell shall, without undue delay, inform you if hubsell or a Sub-Processor has become aware of the occurrence of a Personal Data Breach.

7.2 In the event of a Personal Data Breach, hubsell shall promptly take adequate remedial measures. Furthermore, hubsell shall promptly provide you with all relevant information as requested by you regarding the Personal Data Breach, cooperate with you to investigate the nature and scope of the Personal Data Breach and provide any other assistance as reasonably required by you to allow you to comply with any legal obligations, including notification obligations to regulators and Data Subjects, in this respect.

8. Return and destruction of Personal Data

8.1 Upon termination of the Agreement you may delete the Personal Data from your Member Account. If you fail to delete it, we will delete all data in your Member Account within thirty (30) days of the termination of the Agreement. If we are required by applicable EU or EU member state law to continue storing your Personal Data, hubsell shall inform you of such legal obligation, shall keep the Personal Data confidential and shall only process the Personal Data to the extent required by the applicable EU or EU member state law.

8.2 You accept that when you delete Personal Data from your Member Account this means that hubsell will remove your label from the record of the deleted Personal Data from its database. Deleted Personal Data may continue to be available for other customers that process the Personal Data. The Personal Data will be finally deleted from the hubsell database if no other customers process the Personal Data or, if other customers process the Personal Data, these other customers also have deleted the Personal Data from their member accounts.

9. Compliance and right of audit

9.1 hubsell shall make available to you all information necessary to demonstrate compliance with the provisions of this Supplement. Such information will in any case include information on (i) the security measures, (ii) Sub-Processor agreements (including copies thereof with commercial elements blacked-out), (iii) Personal Data Breaches, (iv) deletion of Personal Data, (v) international data transfers and the safeguards taken to address transfer restrictions and (vi) measures in place to allow you to comply with your obligations in relation to Data Subject’s rights.

9.2 You shall have the right to inspect hubsell’s and Sub-Processor’s compliance of the obligations under this Supplement. Any such inspection shall be conducted on behalf of you by and independent professional auditor subject to professional secrecy rules, like an EDP auditor or an accountant.
You shall: 1) give hubsell reasonable notice of the intention to have an audit performed pursuant to Clause 9.2; 2)procure that the audit is performed in compliance with hubsell’s and Sub-Processor’s reasonable confidentiality provisions, as notified by hubsell to you; and 3) procure that reasonable efforts are used to minimise any disruption to hubsell’s or Sub-Processor’s business caused by the performance of the audit.

10. International data transfer

10.1 hubsell may transfer Personal or make Personal Data accessible to approved Sub-Processor(s) established in Non-Adequate Country/Countries, including but not limited to India.

10.2 You hereby provide hubsell with a mandate to enter into EC Standard Contractual Clauses (Processor-Processor) with a Sub-Processor that is located in a Non-Adequate Country on your behalf.

10.3 Article 10.2 will not apply if the transfer is or the transfers are covered by Approved Measures. In such case, hubsell shall ensure that all required measures, commitments, certifications and safeguards necessary to be able to rely on such Approved Measure are maintained. If hubsell no longer maintains the Approved Measure, hubsell will immediately inform you thereof and ensure that the necessary EC Standard Contractual Clauses are concluded in absence of the Approved Measure.

10.4 Where any of the EC Standard Contractual Clauses or Approved Measures applying to a transfer under this article 11 requires adjustment or is invalidated as a result of any change in, or decision of a competent authority under, Applicable Data Protection Law, hubsell will ensure that the necessary adjustments to the EC Standard Contractual Clauses or Approved Measure are made or the necessary alternative EC Standard Contractual Clauses or Approved Measure are implemented to ensure that the transfer(s) remain to be performed in compliance with Applicable Data Protection Law.

Annex to Privacy and Data Protection Supplement: Technical and Organisational security measures (TOMs):

Introduction: This Annex describes the current technical and organisational security measures applied by hubsell for its systems and data.

1. Technical measures:

1.1. the system is hosted on Amazon Web Services servers, with strict firewall rules, you may review the AWS security process at the following link:

1.2 access from the web is only possible via https based on SHA-256 certificates with RSA Encryption

1.3 Full Database Backups are done on a daily basis with a weekly rolling period

2. Organisational measures:

2.1 the registration and activation of a new account is only possible by contacting our personnel

2.2 he password choice is logically enforced by hubsell to be a long and secure format

2.3 ssh access to the servers and data is only possible from specific IP addresses and only by a limited number of people of the staff (only the CTO at the moment)

2.4the research team can only access the data they’re assigned to find and enrich, only from a segregated web application with the same security level of the main web app

2.5 the sub-processor (research team) has signed an NDA.

3. Confidentiality, integrity, availability and resilience of processing systems and services;

3.1 The registration and activation of a new accounts is only possible by contacting our personnel.

3.2 The password choice is logically enforced by hubsell to be a long and secure format.

3.3 SSH access to the servers and data is only possible from specific IP addresses and only by a limited number of people of the staff (only the CTO at the moment).

3.4 Full Database Backups are done on a daily basis with a weekly rolling period.

3.5 The system is hosted on Amazon Web Services servers, the servers are physically located in Frankfurt (Germany), with 99.99% uptime.

4. The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

4.1 In case of partial or complete data loss, we can, depending on the event, restore the entire database or part of the data from the latest available backup. See point 3.4.

5. Process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing:

5.1 We enforce a continuous assessment to assure that the security policies are respected: 1) during the development of new features, 2) while executing the unit test, integration tests and system tests, and 3) while processing data to be delivered to the customers.