Privacy Policy

PRIVACY AND COOKIES POLICY OF HUBLOCK

The use of the Website available on the website https://www.hublock.io and on the
relevant subpages implies the acceptance of the following terms of the Privacy Policy
and the Cookies Policy.

As a User, please familiarize yourself with its provisions. The following table of contents
will help you to do so. In this document HUBLOCK informs you how HUBLOCK cares for
your data, how it is processed, with whom it is entrusted and many other important
issues related to personal data.

TABLE OF CONTENTS
§1 GENERAL PROVISIONS
§2 DEFINITIONS
§3 PERSONAL DATA AND PRINCIPLES OF THEIR PROCESSING5
WHO IS THE CONTROLLER OF YOUR PERSONAL INFORMATION? 5
IS THE PROVISION OF DATA VOLUNTARY? WHAT ARE THE CONSEQUENCES OF NOT
PROVIDING THE DATA?
FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS THE PERSONAL
DATA YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE WEBSITE?6
HOW IS DATA COLLECTED?
WHAT ARE THE USER RIGHTS?

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CAN A USER REVOKE THEIR CONSENT? 12
DOES THE CONTROLLER TRANSFER USER DATA TO THIRD COUNTRIES? 13
HOW LONG DOES ADMNISTRATOR KEEP USER DATA? 14
LINKS TO OTHER SITES15
SOCIAL MEDIA ACTIVITY – FACEBOOK/ INSTAGRAM16
SOCIAL MEDIA ACTIVITY – LINKEDIN17
SOCIAL MEDIA ACTIVITY – TWITTER19
DATA SECURITY20
WHO MAY BE THE RECIPIENTS OF PERSONAL INFORMATION?21
HAVE WE APPOINTED A DATA PROTECTION OFFICER?22
DO WE PROFILE USER DATA? 22
§4 FORMS23
§5 DISCLAIMER AND COPYRIGHT26
§6 TECHNOLOGIES27
§7 COOKIE POLICY28
§8 CONSENT TO COOKIES35
§9 SERVER LOGS35
§1 GENERAL PROVISIONS
This Privacy Policy and Cookies Policy sets out the rules for the processing and
protection of personal data provided by Users and Cookies, as well as other
technologies appearing on the Website available on the website https://www.hublock.io
and on relevant subpages, also using the Application.
The administrator of the Website and the personal data transmitted therein is Hublock
UG (Haftungsbeschränkt), Frachtweg 28, 21039 Börnsen, HRB 12138 /Lübeck.
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The Administrator cares about the security of personal data and the privacy of the User
of the Service and the Application. HUBLOCK also processes the personal data of Users
as a Processor in the context of the performance of the Agreement, of which more
hereafter.
If you have any doubts regarding the provisions of this Privacy Policy and Cookies Policy,
please contact the Administrator via e-mail address: info@hublock.io.
The Administrator reserves the right to introduce changes to the Privacy Policy and each
Website User is obliged to be familiar with the current Privacy Policy. Changes may be
caused by the development of Internet technology, changes in generally applicable laws
or development of the Website e.g. through the use of new tools by the Administrator.
At the bottom of the page you will find the date of publication of the current Privacy
Policy.
§2 DEFINITIONS
Administrator, HUBLOCK – Hublock UG (Haftungsbeschränkt), Frachtweg 28, 21039
Börnsen, HRB 12138 /Lübeck, NIP: DE 282640390.
User – any entity staying on the Website and using the Platform by means of an
Application.
Customer – a legal person, an organizational unit with legal capacity, a natural person
placing an Order through the Service, who has full legal capacity to act.
Service, Website – the website available at https://www.hublock.io and on relevant
subpages.
Package – a set of Services provided by HUBLOCK against payment. The Service
Packages are described in detail in the Service, together with an indication of the
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duration of the Services under each Package. Unless explicitly stated otherwise,
Packages are chargeable.
Account – a Customer account set up on the HUBLOCK Platform allowing the User to
access and manage the services provided by HUBLOCK under the Agreement.
Platform – the platform through which the User manages the Services. The period for
which access is granted depends on the Service Package purchased by the Client.
Application – software dedicated to the use of the Platform’s functionality by the Client
or the User on mobile devices to a limited extent.
Form or Forms – places on the Site that allow the entry of personal data by the User, for
the purposes indicated in them, e.g. for the purpose of sending a newsletter, for the
purpose of placing an order, for the purpose of contacting the User.
Newsletter – means a free-of-charge service provided electronically by the
Administrator to the User by sending e-mails through which the Administrator informs
about events, services, products and other elements that are important from the
Administrator’s point of view and/or in order to realize the Administrator’s legitimate
aim which is direct marketing, including sending marketing and commercial contents
with the User’s consent. Detailed information about sending the Newsletter can be
found later in this Privacy Policy.
Agreement – the agreement for the provision of the Electronic Services included in the
Service Package ordered by the Customer concluded between HUBLOCK and the
Customer through the Service. The Agreement is entered into at a distance with the
Customer through the Service, without the simultaneous physical presence of the
parties, with the exclusive use of one or more means of remote communication up to
and including the conclusion of the Agreement.
RODO – means 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
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personal data and on the free movement of such data and repealing Directive 95/46/EC
(General Data Protection Regulation).
Data Protection Act – the Act of 10 May 2018 on the protection of personal data
(Journal of Laws 2018, item 1000, as amended).
Act on provision of services by electronic means – Act of 18 July 2002 on provision of
services by electronic means (Journal of Laws No. 144, item 1204, as amended).
Telecommunications Law – the Act of July 16, 2004. Telecommunications Law (Journal
of Laws of 2021, item 576 as amended).
§3 PERSONAL DATA AND PRINCIPLES OF THEIR PROCESSING
WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
The administrator of your personal data is Hublock UG (Haftungsbeschränkt), Frachtweg
28, 21039 Börnsen, HRB 12138 /Lübeck, NIP: DE 282640390.
The Administrator is not a controller of the personal data of entities that have not
entered into an agreement with the Administrator, whose personal data is entered into
the Website as part of the operation of the Platform and/or the Application by the Client
pursuant to the Agreement and used for the performance of the Agreement. In this
context, the Administrator is the processor of the personal data of such entities. In this
regard, Service Users-Customers are obliged to comply with all obligations arising from
the RODO with respect to entities whose personal data they enter into the Service in
order to use its functionality (among others, the obligation to provide information and to
exercise their rights under the RODO).
The Administrator encourages all Website and Application Users to read this document
regardless of the Administrator’s status with respect to the User.
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IS THE PROVISION OF DATA VOLUNTARY? WHAT ARE THE
CONSEQUENCES OF NOT PROVIDING THE DATA?
Provision of data is voluntary; however, failure to provide certain information, generally
indicated as mandatory on the Administrator’s website and Application, will result in the
impossibility of providing a given service and achieving a given purpose or taking certain
actions.
The provision by the User of data that are not mandatory or of excessive data that the
Administrator does not need to process occurs on the basis of a decision of the User
himself, and then the processing takes place on the basis of the premise contained in
Article 6(1)(a) of the RODO (consent). The User gives his consent to the processing of
these data and to the anonymisation of data that the Administrator does not need and
does not want to process, but nevertheless the User provided them to the
Administrator.
FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE
PROCESS THE PERSONAL DATA YOU PROVIDE IN CONNECTION
WITH YOUR USE OF THE WEBSITE?
The User’s personal data on the Administrator’s Website may be processed for the
following purposes and on the following legal bases:

To provide a service or perform a concluded contract, to send an offer (e.g.
advertising) at the request of the User – on the basis of Article 6(1)(b) of the
RODO (necessity to conclude and/or perform a contract or take action upon
request);
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issuing invoices, bills and fulfilling other obligations resulting from the tax
law in case of making orders on the Website or other products and services –
on the basis of Article 6(1)(c) of the RODO (obligation resulting from the law);
grant a discount or inform about promotions and interesting offers of the
Administrator or entities recommended by it – on the basis of Article 6(1)(a) of
the RODO (consent);
storage of unpaid orders – on the basis of Article 6(1)(f) RODO (legitimate
interest of the administrator);
handling complaints or claims related to the contract – on the basis of Article
6(1)(b) of the RODO (necessary to conclude and/or perform the contract) and on
the basis of Article 6(1)(c) of the RODO (obligation under the law);
establish, pursue or defend against claims – on the basis of Article 6(1)(f) of the
RODO (legitimate interest of the controller);
telephone contact in matters related to the performance of the service – on
the basis of Article 6(1)(b) of the RODO (necessary to conclude and/or perform
the contract);
creation of records related to the RODO and other regulations – based on
Article 6(1)(c) of the RODO (legal obligation) and Article 6(1)(f) of the RODO
(legitimate interest of the controller);
archival and evidential, for the purpose of securing information that can be
used to prove facts – on the basis of Article 6(1)(f) of the RODO (legitimate
interest of the controller);
analytical, consisting, inter alia, of the analysis of data collected automatically
when using the website, including cookies, e.g. Google Analytics cookies,
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Facebook Pixel – on the basis of Article 6(1)(f) of the RODO (legally justified
interest of the administrator);

use of cookies on the Site and its subpages – on the basis of Article 6(1)(a) of
RODO (consent);
Managing the Website and the Administrator’s pages on other platforms –
on the basis of Article 6(1)(f) of the RODO (legitimate interest of the
Administrator);
survey of satisfaction with the services offered – on the basis of Article 6(1)(f)
of the RODO (legitimate interest of the administrator),
for internal administrative purposes of the Administrator related to the
management of contact with the User, which is a legitimate interest of the
Data Controller on the basis of Article 6(1)(f) of the RODO (legitimate interest of
the Administrator),
for the purpose of sending the newsletter – on the basis of Article 6(1)(f) RODO
(legally justified interest of the administrator in processing data for direct
marketing purposes) and on the basis of the Act on electronic provision of
services (consent),
in order to adjust the content displayed on the Administrator’s websites to
individual needs and to constantly improve the quality of the services
offered – on the basis of Article 6(1)(f) of the RODO (legally justified interest of the
Administrator),
for direct marketing directed to the User of its own products or services or
recommended products of third parties – on the basis of Article 6(1)(f) RODO
(legitimate interest of the administrator),
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in order to create Users’ own databases – on the basis of Article 6(1)(f) RODO
(legitimate interest of the administrator),
in order to operate the https://www.facebook.com/hublock.io fanpage on
Facebook and interact with users – on the basis of Article 6(1)(f) RODO
(legitimate interest of the administrator) and Article 6(1)(a) RODO (consent),
in order to operate the fanpage https://www.instagram.com/hublock.io/ on
Instagram and interact with users – on the basis of Article 6(1)(f) RODO
(legitimate interest of the administrator) and Article 6(1)(a) RODO (consent),
in order to operate the fanpage
https://www.linkedin.com/company/hublock/?viewAsMember=true on
LinkedIn and interact with users – on the basis of Article 6(1)(f) RODO
(legitimate interest of the administrator) and Article 6(1)(a) RODO (consent),
in order to operate the https://twitter.com/hublock_io profile on Twitter
and interact with users – on the basis of Article 6(1)(f) RODO (legitimate interest
of the administrator) and Article 6(1)(a) RODO (consent),
for the purpose of operating the You Tube channel under the name
HUBLOCK at the URL
https://www.youtube.com/channel/UC8xoIu03g4CWADilSbzDrlg, interacting
with users – on the basis of Article 6(1)(f) RODO (legitimate interest of the
administrator) and Article 6(1)(a) RODO (consent),
for the purpose of directing advertising in social media and on websites such
as Facebook Leads Ads or Facebook Custom Audience, You Tube and for the
purpose of remarketing – on the basis of Article 6(1)(a) of the RODO (consent)
and on the basis of Article 6(1)(f) of the RODO (legitimate interest of the
Administrator) consisting in the promotion and advertising of the Administrator’s
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services through remarketing targeted at persons subscribed to the mailing or
visiting a given website),
The provision by the User of data that are not mandatory or of excessive data that the
Administrator does not need to process occurs on the basis of a decision of the User
himself, and then the processing takes place on the basis of the premise contained in
Article 6(1)(a) of the RODO (consent). The User gives his consent to the processing of
these data and to the anonymisation of data that the Administrator does not need and
does not want to process, but nevertheless the User provided them to the
Administrator.
HOW IS DATA COLLECTED?
Only the data provided by the Customer or User is collected and processed (with the
exception of – in certain situations – data collected automatically by means of cookies
and login data, which is discussed below).
During a visit to the Website and Application, data concerning the visit itself are
automatically collected, e.g. the user’s IP address, domain name, browser type,
operating system type, etc. (logging data). Data collected automatically may be used to
analyse User behaviour on the Website, collect demographic data about Users or to
personalise the content of the Website in order to improve it. However, this data is
processed solely for the purpose of administering the website, providing efficient
hosting services or directing marketing content, and is not associated with the data of
individual users. You can read more about cookies later in this Policy.
When using the Application, the User’s geolocation data are also collected by means of
telemetry, which are necessary for the performance of the service under the Agreement
between the Customer and the Administrator. Geolocation data are only processed
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within the scope of the performed contract if the Customer enters his/her own or
his/her colleague’s data into the Application. If Customers use third-party transportation
providers, the Service Provider does not process their geolocation data.
Within a part of agreements concluded within the Service, the Administrator’s Clients
may use the service of sending text messages directed to telecommunication end
devices of natural persons, whereas the data of those natural persons are introduced by
the Clients to the Service on their own.
Data may also be collected for the purpose of filling out forms on the Site, as further
described in this Privacy Policy.
Information society services
The Administrator does not collect data from children. The user should be at least 16
years old to independently consent to the processing of personal data for the purpose
of providing information society services, among other marketing purposes.
If you are under the age of 16, you should not use the Website or the Application.
The Administrator shall be entitled to make reasonable efforts to verify that the user
meets the age requirement referred to above.
WHAT ARE THE USER RIGHTS?
The User shall be entitled at any time to the rights contained in Articles 15 to 21 of the
RODO, i.e:
The right of access to the content of his/her data,
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The right to data portability,
Right of rectification,
right of rectification,
The right to erasure of the data if there is no basis for the processing,
The right to restrict processing if it has been done in an incorrect manner or
without legal basis,
The right to object to the processing based on the legitimate interest of the
controller,
The right to lodge a complaint to the supervisory authority – the President of the
Office for Personal Data Protection (under the terms of the Act on Personal Data
Protection), if he considers that the processing of his data is incompatible with
the current legal provisions on data protection.
The right to be forgotten, if further processing is not provided for under current
legislation.
The Administrator points out that these rights are not absolute and do not apply to all
processing of the User’s personal data. This applies e.g. to the right to obtain a copy of
the data. The rights shall not adversely affect the rights and freedoms of other persons,
such as e.g. copyrights, professional secrecy. In order to find out the limitations on the
User’s rights, please refer to the RODO.
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However, the user always has the right to lodge a complaint with a supervisory
authority.
In order to exercise his/her rights, the User may contact the Administrator via e-mail
address: info@hublock.io or by letter to the Administrator’s place of business address, if
provided in this Privacy Policy, indicating the scope of his/her requests. A response will
be provided no later than 30 days from the date of receipt of the request and its
justification, unless an extension of this period is justified in accordance with the RODO.
CAN A USER REVOKE THEIR CONSENT?
If the User has given consent for a given action, such consent may be withdrawn at any
time, which will result in the removal of the e-mail address from the Administrator’s
mailing list and cessation of the indicated actions (in the case of subscription based on
consent). The withdrawal of consent shall not affect the processing of data which was
carried out on the basis of consent before its withdrawal.
In some cases, the data may not be completely deleted and will be retained to defend
against possible claims for a period of time in accordance with the provisions of the Civil
Code Act or, for example, to comply with legal obligations imposed on the Administrator.
Each time, the Administrator will refer to the User’s request, adequately justifying
further actions arising from legal obligations.
DOES THE CONTROLLER TRANSFER YOUR DATA TO THIRD
COUNTRIES?
User data may be transferred outside the European Union – to third countries.
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Due to the fact that the Administrator uses external providers of various services, e.g.
Facebook and subsidiaries, Google, Amazon, etc., User data may be transferred to the
United States of America (US) in connection with their storage on US servers (in whole or
in part). Google and Facebook use compliance mechanisms provided for by the RODO
(e.g. certificates) or standard contractual clauses for their services.They will only be
transferred to recipients who guarantee the highest data protection and security,
including by:
a) cooperation with processors of personal data in countries for which a relevant
decision of the European Commission has been issued,
b) Use of standard contractual clauses issued by the European Commission (as is
the case with Google, for example),
c) application of binding corporate rules approved by the competent supervisory
authority,
or to whom you have consented to provide personal information.
Detailed information is available in the Privacy Policy of each provider of these services,
available on their websites. For example:
Google Ireland Limited: https://policies.google.com/privacy?hl=pl
Facebook Ireland Ltd: https://www.facebook.com/privacy/explanation
Amazon Web Services EMEA SARL: https://aws.amazon.com/privacy/?nc1=f_pr
Currently, the services offered by Google, Facebook or Amazon are mainly provided by
entities located in the European Union. You should, however, always read the privacy
policies of these providers in order to receive the most up-to-date information on data
protection.
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HOW LONG DOES ADMNISTRATOR KEEP USER DATA?
User Data will be retained by the Administrator for the duration of the individual
services/achievement of objectives and:
a) for the period of performance of the service and cooperation, as well as for the
period of limitation of claims under the law – in relation to data provided by
contractors and customers or Users,
b) for the period of talks and negotiations preceding the conclusion of an
agreement or performance of a service – with regard to data provided in the
inquiry,
c) for the period required by law, including tax law, for personal data related to the
fulfilment of obligations under the applicable law,
d) until you successfully lodge an objection submitted on the basis of Article 21
RODO – with regard to personal data processed on the basis of the controller’s
legitimate interests, including for direct marketing purposes,
e) until the withdrawal of consent or the achievement of the purpose of processing,
the business purpose – with regard to personal data processed on the basis of
consent. After the withdrawal of consent, the data may still be processed for the
purpose of defending against possible claims in accordance with the limitation
period for such claims or the period (shorter) indicated to the User,
f) until obsolete or no longer useful – with regard to personal data processed
mainly for analytical, statistical, cookie usage and administration purposes of the
Administrator’s Websites,
g) for a maximum period of 1 year in the case of persons who have unsubscribed
from the newsletter in order to protect themselves against potential claims (e.g.
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information about the subscription and unsubscribe dates, number of
newsletters received, actions taken and activities connected with the received
messages), or after a period of 1 year of lack of any activity by the subscriber, e.g.
not opening any messages from the Administrator.
Data retention periods indicated in years are counted at the end of each year in which
data processing began. Mato is intended to streamline data processing and
management.
Detailed processing periods of personal data, relating to specific processing activities,
can be found in the Register of Processing Activities of the Controller.
LINKS TO OTHER SITES
Links to other websites may appear on the Site. They will be opened in a new browser
window or in the same window. The Administrator shall not be responsible for the
content provided by such websites. The User is obliged to familiarize himself with
privacy policy or regulations of those websites.
ACTIVITY IN SOCIAL MEDIA – FACEBOOK/ INSTAGRAM
The administrator of the personal data of the User of the fanpage HUBLOC.IO at URL:
https://www.facebook.com/hublock.io on Facebook and the fanpage on Instagram at
URL: https://www.instagram.com/hublock.io/ is the Administrator.
User Personal Data provided on Fanpage will be processed for the purpose of
administering and managing Fanpage, communicating with the User, interacting with
the User, directing the User to marketing content and creating a Fanpage community.
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The basis for their processing is the consent of the User and the Administrator’s
legitimate interest in interacting with Users and Fanpage Observers. User voluntarily
decides to like / observe Fanpage.
The rules of Fanpage are set by the Administrator, however the rules of being on
Facebook/Instagram follow the regulations of Facebook.
At any time, User may stop watching Fanpage. However, the Administrator will not
display to the User any content from the Administrator associated with Fanpage.
The Administrator sees the User’s personal data, such as, for example, name, surname
or general information, which the User posts on their profiles as public. The processing
of other personal data is carried out by the social network Facebook and under the
terms of its regulations.
The User’s personal data will be processed for the period of Fanpage
maintenance/existence on the basis of consent given by liking/clicking “Observe” the
Fanpage or interacting with it, e.g. by leaving comments, sending messages and in order
to pursue the Administrator’s legitimate interests, i.e. marketing of its own products or
services or defence against claims.
User’s personal data can be shared with other data recipients, such as Facebook,
cooperating advertising agencies or other subcontractors operating Administrator’s
Fanpage, IT service, assistant, if there is contact outside Facebook.
Your other rights are described in this Privacy Policy.
Your data may be transferred to third countries in accordance with Facebook
regulations.
The data may also be profiled, which helps to better personalize the advertising offer
addressed to the User. However, they will not be processed in an automated manner
within the meaning of RODO (having a negative impact on the User’s rights and
freedoms).
The above rules related to data within Facebook also apply to Instagram.
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SOCIAL MEDIA ACTIVITY – LINKEDIN
The administrator of the personal data of the User observing the Administrator’s
account at URL: https://www.linkedin.com/company/hublock/?viewAsMember=true
(hereinafter Fanpage) on LinkedIn is the Administrator.
User Personal Data provided on Fanpage will be processed for the purpose of
administering and managing Fanpage, communicating with the User, interacting with
the User, directing the User to marketing content and creating a Fanpage community.
The basis for their processing is the User’s consent and the Administrator’s legitimate
interest in interacting with Users and Fanpage Visitors. User voluntarily decides to like /
observe Fanpage.
The rules of the Fanpage are set by the Administrator, however, the rules of being on
the social network are based on the LinkedIn rules.
At any time, User may stop watching Fanpage. However, the Administrator will not
display to the User any content from the Administrator associated with Fanpage.
The Administrator sees the User’s personal data, such as, for example, name, surname
or general information, which the User posts as public on their profiles. The processing
of other personal data is carried out by the social network LinkedIn and under the terms
of its rules.
The User’s personal data will be processed for the period of Fanpage
maintenance/existence on the basis of consent given by liking/clicking “Observe” the
Fanpage or interacting with it, e.g. by leaving comments, sending messages and in order
to pursue the Administrator’s legitimate interests, i.e. marketing of its own products or
services or defence against claims.
User’s personal data may be made available to other data recipients, such as
cooperating advertising agencies or other subcontractors operating the Administrator’s
Fanpage, IT service, virtual assistant, if there is contact outside the portal.
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Your other rights are described in this Privacy Policy.
Your data may be transferred to third countries in accordance with LinkedIn’s rules.
The data may also be profiled, which helps to better personalize the advertising offer
addressed to the User. However, they will not be processed in an automated manner
within the meaning of RODO (having a negative impact on the User’s rights and
freedoms).
SOCIAL MEDIA ACTIVITY – TWITTER
The Administrator is the administrator of personal data of the User who observes the
Administrator’s account at URL: https://twitter.com/hublock_io (hereinafter Fanpage) on
Twitter is the Administrator.
User Personal Data provided on Fanpage will be processed for the purpose of
administering and managing Fanpage, communicating with the User, interacting with
the User, directing the User to marketing content and creating a Fanpage community.
The basis for their processing is the User’s consent and the Administrator’s legitimate
interest in interacting with Users and Fanpage Visitors. User voluntarily decides to like /
observe Fanpage.
The rules on Fanpage are set by the Administrator, however the rules of being on the
social networking site result from Twitter regulations.
At any time, User may stop watching Fanpage. However, the Administrator will not
display to the User any content from the Administrator associated with Fanpage.
The Administrator sees the User’s personal data, such as e.g. name, surname or general
information, which the User posts as public on their profiles. The processing of other
personal data is carried out by the social network Twitter and under the terms of its
regulations.
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The User’s personal data will be processed for the period of Fanpage
maintenance/existence on the basis of consent given by liking/clicking “Observe” the
Fanpage or interacting with it, e.g. by leaving comments, sending messages and in order
to pursue the Administrator’s legitimate interests, i.e. marketing of its own products or
services or defence against claims.
User’s personal data may be made available to other data recipients, such as
cooperating advertising agencies or other subcontractors operating the Administrator’s
Fanpage, IT service, virtual assistant, if there is contact outside the portal.
Your other rights are described in this Privacy Policy.
Your data may be transferred to third countries in accordance with Twitter’s terms of
service.
The data may also be profiled, which helps to better personalize the advertising offer
addressed to the User. However, they will not be processed in an automated manner
within the meaning of RODO (having a negative impact on the User’s rights and
freedoms).
SOCIAL MEDIA ACTIVITY – YOU TUBE
The Administrator is the administrator of personal data of the User who observes the
Administrator’s account at the URL
https://www.youtube.com/channel/UC8xoIu03g4CWADilSbzDrlg (hereinafter Fanpage)
on the You Tube service.
User Personal Data provided on Fanpage will be processed for the purpose of
administering and managing Fanpage, communicating with the User, interacting with
the User, directing the User to marketing content and creating a Fanpage community.
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The basis for their processing is the User’s consent and the Administrator’s legitimate
interest in interacting with Users and Fanpage Visitors. User voluntarily decides to like /
observe Fanpage.
The rules on Fanpage are set by the Administrator, however the rules of being on the
social networking site follow the You Tube regulations.
At any time, User may stop watching Fanpage. However, the Administrator will not
display to the User any content from the Administrator associated with Fanpage.
The Administrator sees the User’s personal data, such as e.g. name, surname or general
information, which the User posts on his/her profile as public. The processing of other
personal data is carried out by the You Tube social network and under the terms of its
regulations.
The User’s personal data will be processed for the period of Fanpage
maintenance/existence on the basis of consent given by liking/clicking “Observe” the
Fanpage or interacting with it, e.g. by leaving comments, sending messages and in order
to pursue the Administrator’s legitimate interests, i.e. marketing of its own products or
services or defence against claims.
The User’s personal data may be made available to other data recipients, such as
cooperating advertising agencies or other subcontractors operating the Administrator’s
Fanpage, IT service, virtual assistant, if there is a contact outside the portal.
Your other rights are described in this Privacy Policy.
Your data may be transferred to third countries in accordance with the You Tube terms
of service.
The data may also be profiled, which helps to better personalize the advertising offer
addressed to the User. However, they will not be processed in an automated manner
within the meaning of RODO (having a negative impact on the User’s rights and
freedoms).
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DATA SECURITY
The User’s personal data are stored and protected with due care, in accordance with the
Administrator’s implemented internal procedures. The Administrator processes User
information with the use of appropriate technical and organisational measures
compliant with the provisions of generally applicable law, in particular the provisions on
personal data protection. These measures are aimed primarily at protecting the Users’
personal data against unauthorized access.
In particular, access to Users’ personal data is provided only to authorized persons who
are obliged to keep such data confidential or to entities entrusted with the processing of
personal data under a separate data entrustment agreement.
At the same time, the User should be careful to protect his/her personal data
transmitted over the Internet, in particular not to disclose his/her login data to third
parties, to use anti-virus protection and to keep his/her software up to date.
WHO MAY BE RECIPIENTS OF PERSONAL INFORMATION?
The Administrator informs that he uses services of external entities. The entities to
which it entrusts the processing of personal data (such as courier companies, companies
mediating in electronic payments, companies offering accounting services, companies
enabling the sending of newsletters) guarantee the application of appropriate measures
for the protection and security of personal data required by law, in particular by the
RODO.
The Administrator informs the User that it entrusts the processing of personal data to,
among others, the following entities:
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EmailLabs, Vercom S.A. Roosevelta 22 Street, 60-829 Poznan, NIP 7811765125_ –
in order to send newsletters and use the mailing system
Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855,
Luxembourg, DigitalOcean, LLC, 101 Avenue of the Americas, 10th Floor, New
York, NY 10013 USA- to store personal information on the server;
Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA. – In order to
process the payment system and electronic transactions,
GMI SOFTWARE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ based in
Gdańsk (80-890) at Jana Heweliusza 11/819, NIP: 5252816287 – for the purpose of
IT support or management of the Site from the IT side,
Other contractors or subcontractors engaged for technical, administrative,
marketing support or to provide services to the Administrator and its clients, e.g.
accounting, IT, graphic design, copywriting, debt collection companies, etc.
Personal data may also be transferred to other recipients, e.g. offices (e.g. the tax office)

in order to perform legal and tax obligations related to settlements and accounting or
to couriers, lawyers.
HAVE WE APPOINTED A DATA PROTECTION OFFICER?
The Personal Data Controller hereby informs you that it has not appointed a Data
Protection Officer (DPO) and performs the duties related to the processing of personal
data independently.
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The User acknowledges that his/her personal data may be disclosed to authorized state
authorities in connection with their proceedings, at their request and upon fulfillment of
prerequisites confirming the necessity of obtaining such data from the Administrator.
DO WE PROFILE YOUR DATA?
The User’s personal data will not be used for automated decision-making affecting the
User’s rights and obligations or freedoms within the meaning of the RODO.
As part of the website and tracking technologies, the User’s data may be profiled, which
helps to better personalize the company’s offer, which the Administrator directs to the
User (mainly through so-called behavioral advertising). However, this should not have
any impact on the User’s legal situation, in particular on the terms of the contracts
concluded by him or the contracts he intends to conclude. It may only help to better
match the content and targeted advertising to the User’s interests. The information used
is anonymous and is not associated with personal data provided by the User e.g. in the
purchase process. It is based on statistical data such as gender, age, interests,
approximate location, language, industry, and Site behavior.
Each User has the right to object to profiling if it would adversely affect the User’s rights
and obligations.
To learn more about behavioral advertising click here:
https://www.youronlinechoices.com/pl/o-reklamie-behawioralnej
§4 FORMS
The Administrator uses the following types of forms within the Site:
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Newsletter subscription form – requires you to enter your name and email
address in the appropriate space. These fields are mandatory. Then, in order to
add the e-mail address to the database of subscribers of the Administrator, the
User has to confirm their willingness to subscribe. The data obtained in this way
are added to the mailing list in order to send the newsletter.
Subscription/subscribing means that the User agrees with this Privacy Policy and
agrees to receive marketing and commercial information by means of electronic
communication, e.g. e-mail, within the meaning of the Act of 18 July 2002 on
electronic services (Journal of Laws No. 144, item 1204, as amended).
By signing up for the newsletter, the User also consents to the Administrator’s
use of the User’s telecommunications terminal equipment (e.g. phone, tablet,
computer) for direct marketing of the Administrator’s products and services and
presentation of commercial information to the User in accordance with Article
172(1) of the Telecommunications Act (Journal of Laws 2014, item 243 as
amended).
The above consents are voluntary, but necessary to send the newsletter,
including but not limited to information about services, new blog posts, products,
promotions and discounts offered by the Administrator or third party products
recommended by the Administrator. Consents may be withdrawn at any time,
which will result in the discontinuation of sending the newsletter in accordance
with the rules contained in this Privacy Policy.
The newsletter is sent for an indefinite period of time, from the moment of
activation until the withdrawal of consent. After the withdrawal of consent, the
User’s data may be stored in the newsletter database for a period of up to 1 year
in order to demonstrate the fact that the User has granted consent for
communication through the newsletter, the User’s actions (e-mail openings) and
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the moment of withdrawal, as well as possible related claims, which constitutes a
legitimate interest of the Administrator (Article 6(1)(f) RODO).
Sending of the newsletter may be discontinued in the case of the User’s inactivity
for at least 1 year from the start of the newsletter service or reading of the last
e-mail message (sent newsletter). In this case, the Administrator will delete the
User’s data from the newsletter sending system (provider). The User shall not be
entitled to receive any message from the Administrator, unless he/she decides to
resubscribe in the Newsletter subscription form or contact the Administrator in
another way selected for this purpose.
The mailing system used to send the newsletter records all activity and actions
taken by the User in connection with the e-mails sent to him (date and time of
opening the message, clicking on links, moment of unsubscribing, etc.).
The Administrator can also conduct remarketing on the basis of art. 6 sec. 1 letter
f RODO (legally justified interest of the Administrator, consisting in promotion
and advertisement of services directed to persons subscribed to the newsletter)
in such a way that the e-mail addresses of subscribers are uploaded to the
marketing tool offered by Facebook Inc., the so-called ad manager, and then the
advertisement created by the Administrator or authorised persons is directed to
them through the Administrator’s advertising account, provided that the
newsletter subscribers are at the same time users of the Facebook platform (they
have created an account there). Each time the data is deleted after the
advertising campaign ends. In the case of another advertising campaign, an
updated database of subscribers is uploaded to the tool). Precise information
about the so-called non-standard groups of recipients, the principles of data
hashing and processing can be found in Facebook’s Privacy Policy at this link
https://www.facebook.com/legal/terms/customaudience# and
https://www.facebook.com/legal/terms/dataprocessing, and the Administrator
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recommends that each User and subscriber familiarize themselves with these
principles.

Contact form – allows you to send a message to the Administrator and contact
him via e-mail. Personal data in the form of name, e-mail address and data given
in the message content are processed by the Administrator in accordance with
this Privacy Policy in order to contact the User.
After the end of contact with you, data may be archived, which is a legitimate
interest of the Administrator. The Administrator is not able to determine the
exact period of archiving and thus deletion of messages. However, the maximum
period will not be longer than the statute of limitations for claims under the law.
Registration form for creating a User’s account on the Platform – the User
has the opportunity to create an account on the Platform and for this purpose
they must perform the appropriate registration and provide the following data:
name, email address and then the password.
Creating an account is done according to the rules specified in the Regulations
and is a service provided electronically. The rules of account maintenance and its
possible deletion are included in the Regulations.
The data marked as such are mandatory and without them it will not be possible
to create a user account. Provision of other data is voluntary.
The Administrator may entrust the processing of personal data to third parties without
the User’s separate consent (on the basis of an entrustment agreement). Data obtained
from forms cannot be transferred to third parties.
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If you use third-party service providers, you should review their privacy policies,
available from those service providers on their websites.
§5 DISCLAIMER AND COPYRIGHT

The content presented on the Site is not expert advice or guidance and does not
relate to a specific factual situation. If the User wishes to obtain assistance in a
particular matter, he should contact a person authorised to provide such advice or
the Administrator at the contact details provided. The Administrator shall not be held
liable for any use of the content of the Website or any actions or omissions made on
its basis.
All content included in the Website is copyrighted by certain persons and/or the
Administrator (e.g. photos, texts, other materials, etc.). The Administrator does not
consent to copying such content, in whole or in part, without his/her express prior
consent.
The Administrator hereby informs the User that any dissemination of the content
made available by the Administrator constitutes a violation of the law and may result
in civil or criminal liability. The Administrator may also demand appropriate
compensation for material or non-material damage suffered, according to the
applicable laws.
The Administrator is not responsible for the use of the materials available on the site
in an unlawful manner.
Content posted on the Site is current as of the date it is posted, unless otherwise
indicated.
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§6 TECHNOLOGIES
In order to use the Administrator’s website, it is necessary to have:
a) Devices with access to the Internet
b) An active electronic mailbox that receives e-mail messages
c) A web browser capable of displaying web pages
d) Software capable of reading content in the presented formats e.g. pdf., video,
mp3, mp4.
§7 COOKIE POLICY

Like most websites, the Administrator’s website uses tracking technologies, i.e.
cookies, to improve the website in order to meet the needs of its visitors.
The site does not automatically collect any information except that contained in
cookies.
Cookies (“cookies”) are computer data, small text files that are stored on an end
device, such as a computer, tablet, smartphone, when a User uses the Site.
These may be our own cookies (which come directly from the Website) and third
party cookies (which come from other websites).
Cookies allow us to tailor the content of the Site to your individual needs and the
needs of other visitors. They also make it possible to create statistics which show
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how users use and move around the Site. This helps to improve the Site, its content,
structure and appearance.

The Administrator uses the following third-party cookies on the Site:
a) Facebook conversion pixel and ads created via the Facebook Facebook Ads
(Facebook Custom Audiences) portal – in order to manage Facebook ads and
conduct remarketing activities, which is the Administrator’s legitimate interest.
The Administrator may also direct advertising content to the User via the
Facebook portal as part of contact ads.
The Facebook Pixel tool is provided by Facebook Inc. and its affiliates. It is an
analytical tool that helps measure the effectiveness of ads, shows what actions
Site Users take, and helps reach a specific group of people (Facebook Ads). The
Administrator may also target advertising content to the User through the
Facebook portal as part of contact ads.
The Administrator can also conduct remarketing on the basis of art. 6 section 1
point f RODO (legally justified interest of the Administrator, consisting in
promotion and advertisement of services addressed to persons who agreed to
send offers or persons similar to them or to users who liked the Fanpage) in such
a way that the provided e-mail addresses are uploaded to the marketing tool
offered by Facebook Inc. Ads manager, and then the ads created by the
Administrator or authorized persons are directed to them through the
Administrator’s advertising account, provided that these persons are also
Facebook users (they have created an account there). Each time the data is
deleted after the ad campaign ends. In the case of another advertising campaign,
an updated contact database is uploaded to the tool). Precise information about
the so-called non-standard groups of recipients, the principles of data hashing
and processing can be found in the Privacy Policy of Facebook under the
following link: https://www.facebook.com/legal/terms/customaudience# and
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https://www.facebook.com/legal/terms/dataprocessing , and the Administrator
recommends that each User reads these principles.
The information collected through the use of Facebook Pixel is anonymous and
does not identify you personally. It shows general data about the user: location,
age, gender, interests. The Facebook Provider may combine this information with
information the User provides the Facebook account, and then use it for its own
purposes.
The administrator recommends reviewing the details related to the use of the
Facebook Pixel tool and possibly asking questions of the tool provider, as well as
managing your privacy settings on Facebook. More information can be found
under the link: https://www.facebook.com/privacy/explanation . At any time you
can opt out of cookies responsible for displaying remarketing ads, e.g. on
https://www.facebook.com/help/1075880512458213/.
By using the site, the user agrees to the installation of the indicated cookie on
his/her end device.
b) Embedded Google Analytics code – to analyze Site statistics. Google Analytics
uses its own cookies to analyse the actions and behaviour of Website users.
These cookies are used to store information, such as which page the User came
from on the current website. They help to improve the Site.
This tool is provided by Google Ireland Limited. Activities undertaken as part of
the use of the Google Analytics code are based on the Administrator’s legitimate
interest in the creation and use of statistics, which then enables the improvement
of the Administrator’s services and optimisation of the Website.
The Administrator does not process any personally identifiable User data when
using the Google Analytics tool.
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The administrator recommends to read the details related to the use of the
Google Analytics tool, the possibility to disable the tracking code and, if
necessary, to ask questions to the provider of this tool under the link:
https://support.google.com/analytics#topic=3544906.
c) Web push notifications from the browser – in order to better communicate
with the User and to provide him/her with valuable content or offers faster, the
Administrator allows the User to agree to receive web push notifications from the
User’s browser.
In order to agree to receive web push notifications, the User should check the
“display notifications” option or a similar option on the message sent by his/her
web browser (each browser may call this option differently).
Consent to receive such notifications can be withdrawn at any time by changing
the settings of the User’s web browser. The Administrator does not process any
personal data of the Users who use web push notifications. Users are identified
only on the basis of information stored by their web browsers, to which the
Administrator has no access.
d) Social media referral plugins e.g. Facebook, Instagram, Twitter, LinkedIn, You
Tube.
After clicking on the icon of the plugin, the user is redirected to the website of the
external provider, in this case the owner of the social network, e.g. Facebook.
Then the user can click “Like” or “Share” and like the Administrator’s Facebook
fanpage or directly share the content (post, article, video, etc.).
The Administrator recommends reading Facebook’s privacy policy before
creating an account on this portal. The Administrator has no influence on the
data processed by Facebook. As soon as the User clicks on the button of a social
media plug-in, personal data are processed by the social network e.g. Facebook,
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which becomes the controller and decides the purpose and scope of the
processing. Cookies left by the Facebook plug-in (or other third parties) can also
be applied to your device when you visit the Website and then associated with
the data collected on the Facebook portal. By using the Website, you accept this.
The Administrator has no influence over the processing of data by third parties in
this way.
The above instructions also apply to handling:
Facebook – fanpage located at URL: https://www.facebook.com/hublock.io
Instagram- the profile located at the URL:
https://www.instagram.com/hublock.io/
Twitter- the profile found at the URL:
https://twitter.com/hublock_io
LinkedIn- the profile found at the URL:
https://www.linkedin.com/company/hublock/?viewAsMember=true
Channel on You Tube located at the URL:
https://www.youtube.com/channel/UC8xoIu03g4CWADilSbzDrlg
e) Tools for evaluating the effectiveness of Google Ads advertising campaigns –
in order to conduct advertising and remarketing campaigns, which is a legitimate
interest of the Administrator.
The Administrator does not collect any data which would allow for identification
of the User’s personal data. The Administrator recommends reading Google’s
privacy policy in order to learn how these functions work and how to disable
them from the User’s browser.
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f) Plugin for User.com chatbot
In order to facilitate communication with the User on the Website, the
Administrator uses a chatbot provided by User.com Sp. z o.o.
The Administrator recommends reading the privacy policy of User.com Sp. z o.o.
in order to learn more about the operation of the chatbot provider.
https://user.com/pl/polityka-prywatnosci/
g) Content from third-party provider portals and websites,
The Administrator may embed content from portals, services, blogs and other
websites of external entities on the Website. In particular, this may include videos
from the You Tube service.
These third parties may record certain data about the reproductions of content
that you have made.
If you do not want this to happen, you should log out of the relevant portal (if you
have an account there and are logged in) before visiting the Site or not playing
the relevant content on the Site. You can also change your browser settings to
block the display of certain content from certain portals.
You Tube
The YouTube service is operated by Google Ireland Limited and enables the
playback of recordings on the Administrator’s website. You Tube may save
cookies on the User’s device and associate them with the User’s account on You
Tube, if the User is logged in.
By using the recordings uploaded to the YouTube website, the User is using
services provided electronically by Google Ireland Limited. For details regarding
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the processing of personal data by You Tube, please refer to its privacy policy and
terms of service: https://policies.google.com/privacy and
https://www.youtube.com/t/terms .

Again, the Administrator recommends that you review the privacy policies of each of
the providers of the above services to learn how you can make changes and settings
to ensure that your rights are protected.
The website uses two types of cookies: session cookies, which are deleted after
closing the browser, logging out or leaving the website, and permanent cookies,
which are stored in the end user’s device to enable the recognition of the browser on
the next visit to the website, for the time specified in the parameters of cookies or
until they are deleted by the User.
In many cases, software used to browse the Internet (web browser) by default allows
you to store cookies on User’s end device. Users of the Website may at any time
change their settings concerning cookies. These settings can be changed in particular
in such a way as to block the automatic handling of cookies in the settings of your
web browser or inform on their timely placement in the device of a User of the
Website. Detailed information on the possibility and methods of using cookies is
available in the software (web browser) settings.
The Administrator informs that restricting the use of cookies (switching them off,
limiting) may affect some of the functionalities available on the Website and hinder
its operation.
More information about cookies is available at https://wszystkoociasteczkach.pl/ or
in the “Help” section of your web browser’s menu.
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§8 CONSENT TO COOKIES
When you first access the Service, you must consent to cookies or take other possible
actions indicated in the message in order to continue using the content of the Service or
Application. By using the Website or the Application, you signify your consent. If the
User does not wish to give such consent, he/she should leave the Website or the
Application. You can always change your browser settings, disable or delete cookies. The
“help” tab of the User’s browser contains the necessary information.
§9 SERVER LOGS

The use of the Website and/or the Application involves sending requests to the
server on which the Website and the Platform are stored
Every request made to the server is recorded in server logs. The logs include,
among other things, the User’s IP address, the date and time of the server,
information about the Internet browser and the operating system used by the
User.
Logs are saved and stored on the server.
Server logs are used to administer the Site and/or Application, and their contents
are not disclosed to anyone other than the individuals and entities authorized to
administer the server.
The Administrator does not use server logs to identify the User in any way.
Date of publication of the Privacy Policy: ____________
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Definitions:

a. User – an individual using the [Truck Drive by Hublock].
b. Post – content added by the User within the “Feed” feature.

General Rules:

a. Users have the right to publish posts in accordance with these terms.
b. All posts published by Users reflect their own opinions and do not represent the views of the app creators.

Content of Posts:

a. Users commit not to publish content that is:
i. offensive, vulgar, or hateful,
ii. infringing on copyright or other intellectual property rights,
iii. promoting illegal or unethical activities.
b. Users are fully responsible for the content of their posts.

Moderation and Removal of Posts:

a. App administrators have the right to moderate, edit, or remove posts that violate these terms or are deemed inappropriate.
b. Users can report posts they believe violate these terms.

Privacy:

a. Users should avoid sharing private information, such as addresses, phone numbers, or personal data, in their posts.
b. The app is not responsible for any consequences of users sharing their personal data.

Final Provisions:

a. Using the “Feed” feature implies acceptance of these terms.
b. The creators of the app reserve the right to change these terms at any time, informing the users accordingly.

Shared Links:

a. Users may share links within their posts. However, [Truck Drive by Hublock] is not responsible for the content, accuracy, or practices of third-party websites linked within the “Feed.”
b. Links to malicious sites, spam, or content that violates the terms of this agreement will be removed. Users sharing such links may face penalties, including but not limited to the suspension or termination of their accounts.
c. Users are advised to exercise caution and discretion when clicking on links shared by others, as [Truck Drive by Hublock] cannot guarantee the safety or reliability of third-party content.