Data Protection Policy

Your privacy is very important to us. Cross Border Hub have developed this Data Protection Policy in order for you to understand how we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively “Process”) your Personal Data. This Data Protection Policy describes the measures we take to ensure the protection of your Personal Data. We also tell you how you can reach us to answer any questions you may have about data protection.

SCOPE

The Data Protection Policy applies to the Cross Border Hub (hereinafter designated as “CBH”) for all dimensions and activities, in all geographies where we operate when data protection law, namely the General Data Protection Regulation (or “GDPR”) apply

This policy applies to the Processing of Personal Data collected by CBH, directly or indirectly, from all individuals including, but not limited to CBH’s current, past or prospective job applicants, employees, clients, consumers, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with “Personal Data” being defined as any data that relates to an identified or identifiable individual or a person who may be identified by means reasonably likely to be used.

In this Policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “CBH” means the Cross Border Hub company.

COLLECTION AND PROCESSING USE OF YOUR PERSONAL DATA

COMPLIANCE WITH THE DATA PROTECTION LAW AND ANY ADDITIONAL APPLICABLE LOCAL DATA PROTECTION LAW

CBH are committed to complying with any applicable legislation relating to Personal Data and we shall ensure that Personal Data is collected and processed in accordance with provisions of the data protection law and other applicable local law, if any.

LAWFULNESS, FAIRNESS AND TRANSPARENCY

We do not collect or process Personal Data without having a lawful reason to do so. We may have to collect and process your Personal Data where necessary for the performance of a contract to which you are party, or when it is necessary for compliance with a legal obligation to which we are subject or where required, with your prior consent. We may also collect and process your Personal Data for CBH’s legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms.

When collecting and processing your Personal Data, we will provide you with a fair and full information notice or privacy statement about who is responsible for the processing of your Personal Data, for what purposes your Personal Data are processed, who the recipients are, what your rights are and how to exercise them, etc., unless it is impossible, or it requires disproportionate efforts to do so.

When required by applicable law, we will seek your prior consent (e.g. before collecting any Sensitive Personal Data).

LEGITIMATE PURPOSE, LIMITATION AND DATA MINIMIZATION

When required by applicable law, we will seek your prior consent (e.g. before collecting any Sensitive Personal Data).

DATA ACCURACY AND STORAGE LIMITATION

CBH will keep Personal Data that is processed accurate and, where necessary, up to date. Also, we will only retain Personal Data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements and, where required for CBH to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. If you want to learn more about our specific retention periods for your Personal Data established in our retention policy, you may contact us at [email protected] .

Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations.

DISCLOSURE OF YOUR PERSONAL DATA

We share your Personal Data, in the following circumstances:

With CBH partners for the purposes described in this policy;
With third parties including certain service providers we have retained in connection with the purposes described in this policy and the services we provide;
With companies providing services for money laundering and terrorist financing checks and other fraud and crime prevention purposes and companies providing similar services, including financial institutions and regulatory bodies with whom such Personal Data is shared;
With courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
With service providers who we engage within or outside of CBH, domestically or abroad, e.g. shared service centres, to process Personal Data for any of the purposes listed above on our behalf and in accordance with our instructions only;
– if we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.

INTERNATIONAL PERSONAL DATA TRANSFERS

Data protection law does not allow the transfer of Personal Data to third countries outside that do not ensure an adequate level of data protection. Some of the third countries in which CBH operates do not provide the same level of data protection as the country in which you are stabelish and are not recognized as providing an adequate level of protection for individuals’ data privacy rights.

For transfers of your Personal Data to such countries, either to entities within or outside CBH, CBH has put in place an adequate safeguard to protect your Personal Data. You will be provided with more information about any transfer of your Personal Data outside of your country at the time of the collection of your Personal Data through appropriate privacy notices or privacy policies.

For further information, including obtaining a copy of the documents used to protect your information, please contact us at [email protected].

COOKIES

Some of our websites may use “cookies.” Cookies are portions of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a website.

We will let you know when you visit our website what types of cookies we use and how to disable such cookies. When required by law, you will have the ability to visit our websites and refuse the use of cookies at any time on your computer. For more details, please consult our Cookies policies.

CHILDREN

Children merit specific protection with regard to their Personal Data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the Processing of Personal Data. Such specific protection should, in particular, apply to the use of Personal Data of children for the purposes of marketing or creating personality or user profiles and the collection of Personal Data with regard to children when using services offered directly to a child.

CBH do not collect and process Children’s Personal Data without the consent of the holder of parental responsibility where required. In particular, we do not promote or market our services to Children, except for specific services and upon the consent of the holder of parental responsibility. If you believe that we have mistakenly collected a Children’s Personal Data, please notify us using the contact details provided below.

UPDATE

We may update this policy from time to time as our business changes or legal requirements change. If we make any significant changes to this policy, we will post a notice on our website when the changes go into effect, and where appropriate, send a direct communication to you about the change.

YOUR RIGHTS

CBH is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:

Right of access and rectification

You can request a copy of the Personal Data we hold about you. You may also request rectification of inaccurate Personal Data, or to have incomplete Personal Data completed.

Right to erasure

Your right to be forgotten entitles you to request the erasure of your Personal Data in cases where:

the data is no longer necessary for the purpose for which it was collected;
you choose to withdraw your consent;
you object to the processing of your Personal Data;
your Personal Data has been unlawfully processed;
there is a legal obligation to erase your Personal Data;
erasure is required to ensure compliance with applicable laws.

Right to restriction of processing

You may request that processing of your Personal Data be restricted in the cases where:

you contest the accuracy of your Personal Data;
CBH no longer needs your Personal Data for the purposes of the processing;
you have objected to processing for legitimate reasons.

Right to data portability

You can request, where applicable, the portability of your Personal Data that you have provided to CBH, in a structured, commonly used, and machine-readable format you have the right to transmit this data to another company without hindrance from CBH where:

the processing of your Personal Data is based on consent or on a contract; and
the processing is carried out by automated means.

You can also request that your Personal Data be transmitted to a third party of your choice (where technically feasible).

Right to object to Processing

You may object (i.e. exercise your right to “opt-out”) to the processing of your Personal Data particularly in relation to profiling or to marketing communications. When we process your Personal Data on the basis of your consent, you can withdraw your consent at any time.

Right not to be subject to automated decisions

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal affect upon you or significantly affects you.

Right to lodge a Complaint

You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. You have also the right to lodge your Complaint before the courts where the CBH has an establishment.

You may, at any time, exercise any of the above rights or contact us with any data protection related queries or concerns:

by completing the Request form and send it to the generic email address as indicated in the privacy notices and/or the privacy policies provided to you at the time of the collection of your Personal Data; and/or to the Group Data Protection Officer at [email protected] ; or,

by completing and submitting the dedicated Request webform.

CONTACT US

If you have questions, comments and requests regarding this policy you can send address them to the Group Data Protection Officer at [email protected] . or send a letter to:

Cross Border Hub LLC
Data Protection
244 Biscayne Blvd #808
Miami, FL
33132
USA