Privacy Notice

PROCESSING OF CLIENT’S REPRESENTATIVES AND/OR STAFF DATA

Who is concerned?

The representatives, officials, persons of contact and/or staff of i-Hub’s clients:

• using i-Hub’s solution, a solution that consists of a database of Know Your Customer
  (KYC) information and related documents; and/or
• acting as point of contact with i-Hub for business purposes; and/or
• having a representative function or beneficial ownership within i-Hub’s (prospective) clients
  (hereinafter “you”).

Who is data controller?

• When accessing & using i-Hub’s solution

When you are accessing and using i-Hub’s solution as a representative and/or staff member
of a company that is i-Hub’s client (as defined in the section “Who is concerned”), i-Hub is
exclusively acting as a data processor. The company which granted you access to the solution
and which you are representing and/or which is your employer (the “Company”) is thus acting
as data controller. Please contact the Company, should you wish to have further information
on the processing carried out in this context.

• Management of the business relationship by i-Hub

In certain circumstances, i-Hub may need to process your personal data for its own purposes,
which are:

• the conduct of the business relationships with the Company and any related communication;
• the performance of AML/KYC checks on the Company as i-Hub’s client;
• the invoicing and accounting;
• the performance of verifications to check the compliance of your Company with its obligations set out in the agreement entered into with i-Hub;
• to remember your preferences when you access and use i-Hub’s solution and
• the marketing of i-Hub’s services.

Which personal data does i-Hub process about you?

i-Hub may process the following personal data about you:
• personal identification information: e.g. name, surname;
• professional related information: e.g. job title, professional phone number, address and
email addresses;
• information systems and networks security information: e.g. IP address, token number,
cookies;
• AML/KYC related information: e.g. ID card, passport number, criminal convictions, interests held in the Company.

If you refuse the processing of your personal data, i-Hub might be unable to perform the agreement (to be) entered into with the Company (in particular for AML/KYC data).

What is the lawfulness basis of this processing?

i-Hub carries out accounting and AML/KYC processing in order to comply with a legal obligation to which i-Hub is subject.

The other processing of personal data are carried out on the basis of i-Hub’s legitimate interest
described above (such as the genuine pursuit of a business relationship with the Company
and any related communication, as well as in the context of the invoicing of i-Hub’s services)
and which shall at no time override your interests or fundamental rights and freedoms.

Who are the recipients of your personal data?

The recipients of your personal data may be, besides i-Hub:

• i-Hub’s service providers (e.g. accounting or IT service providers) and
• competent authorities.

How long does i-Hub process your personal data?

Your personal data will be retained by i-Hub during a maximum period of 10 years as from the
termination of the agreement entered into between i-Hub and the Company, to the extent
necessary to comply with laws and regulations, or in order to establish / exercise / defend
actual / potential legal claims.

What are your rights?

Subject to the provisions of the GDPR and in accordance to the lawfulness basis of processing, you may exercise the following rights to:
• access to the personal data;
• have any inaccurate/incomplete personal data be modified or erased;
• request the limitation of processing of the personal data;
• object to any processing of personal data carried out on the basis of our legitimate
interests.

You may exercise your rights as mentioned in the Regulation (EU) 2016/679 (as amended),
by completing the form available in this link (click here).

You have the right to lodge a complaint with the Luxembourg data protection authority, the
CNPD (click here for further information), or the data protection authority in the EU/EEA Member State where you have your habitual residence.

Amendments to this Privacy Notice

i-Hub may modify this Privacy Notice from time to time. i-Hub will notify such a modification
via a message on the i-Hub solution, however, it is recommended to consult this Privacy Notice
regularly.