This Privacy Policy will help you understand what data we collect when you use Offhub, what we use it for and how you can exercise your rights. It applies to services offered through our website (https://offhub.io) and all of its subdomains (“Website”), as well as our Android and iOS mobile apps (“ Mobile Apps”). Our Website and Mobile Apps may contain links to other websites. Once redirected to such websites this Privacy Policy is no longer applicable.

Who does this Privacy Policy apply to?

Offhub has different types of users depending on the way in which Offhub is used:

• visitors to our Website (“Site Visitors”);
• users of free versions of Offhub (“Free Users”);
• users of paid versions of Offhub (“Subscribers”);
• users of our Mobile Apps (“Mobile Apps Users”);
• users who are invited to join workspaces created on Offhub by Free Users and Subscribers (“End Users”).

In this Privacy Policy, we will refer to all users simply as “you” or collectively as “Users”. This Privacy Policy applies to all Users.

Who we are?

Offhub is part of Tooploox, a software development company which helps build innovative new tech products.

Tooploox is a limited liability corporation (sp. z o.o.) established under the laws of the Republic of Poland (member state of the European Union). Our registered seat is in Wrocław (53-601) at Tęczowa street 7. Our EU VAT ID number is PL8992740358 and our Polish enterprise ID is 022047421.  We are entered into the register of entrepreneurs of the Polish National Court Register under KRS number 445336, and our registration records are kept by the District Court for Wrocław - Fabryczna in Wrocław, Poland.

You can contact us via privacy@offhub.io or, for topics not necessarily related to Offhub, via hello@tooploox.com.

What information do we collect and when?

Site Visitors

Who is the controller of your personal data?

If you are a Site Visitor, Offhub is the controller of your personal data.

Browsing our Website

We will record certain information connected with your use of our Website when you visit it. This information may encompass:

• our servers log information (e.g. your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences as well as data from cookies and similar technologies);
• information about the device that you use to connect with our Website (e.g. the type of device that you are using, the system under which it operates, your network information and unique device identifiers such as your MAC address);
• information about your approximate geographic location inferred from your IP address;
• information about the ways you interact with our Website (e.g. the way you navigate the website, the features and functionalities that you interact with).

The processing of your personal data in this case is either necessary to perform a contract which is concluded between you and us when you decide to use our Website (points a. and b.) or is based on our legitimate interest -  the need to conduct statistical analysis on how our Website is used in order to make it better (points c. and d.).

When the processing of your data is necessary to perform a contract we will keep it until all your claims associated with your use of our Website become time-barred. When the processing of your data is based on our legitimate interest, we will keep it until you object against such processing.

Contacting us

If you are a Site Visitor and decide to contact us, we will ask you to give us your contact details. We will use this data to answer your questions. The processing of your personal data in this case is based on our legitimate interest, i.e. the need to respond to business queries received from Site Visitors. You are not obliged to give us any of the information above, but we may not be able to answer your questions if you do not give us your personal data. We will delete your personal data after your matter is solved and information about you is no longer needed.

Free Users and Subscribers

Who is the controller of your personal data?

If you are a Free User or a Subscriber, Offhub is the controller of your personal data.

Creating an Offhub account

To become a Free User or Subscriber you have to create your Offhub account. To do so, you will be asked to connect Offhub to your Google Account. To create your Offhub account, we will request your name, email address and profile picture associated with your Google Account. During the registration process, you will also be asked to provide the name of your organization and your organization’s mailing domain. We need this data to be able to create a single workspace for all your End Users and to make it possible for you to add your End Users to your Offhub workspace. The processing of your personal data in this context is based on a contract which is concluded between you and us once you become our Free User or Subscriber.

If you are a Free User or you decide to discontinue your subscription before the first payment for your subscription is made, we will delete your personal data provided when creating your Offhub account after all claims that you may bring against us in connection with your use of Offhub become time-barred.

We may also use your contact details provided during the registration process to pursue our legitimate goals such as getting your feedback on Offhub and providing you with vital information about Offhub (e.g. updates, bug fixes, etc.) during the time that you use Offhub. We may use your contact details for this purpose until you tell us to stop it. In order to do so, you can contact us at privacy@offhub.io.

Becoming a Subscriber

To become a Subscriber you will be additionally asked to give us your credit card data and/or other billing information. This data is necessary for us to be able to charge you for your Offhub subscription. The processing of your personal data in this context is based on a contract which is concluded between you and us when you activate your subscription. We will not directly process your billing information as we use a third-party payment services provider. It is this provider who directly stores your billing information. As we do not have direct access to your credit card data/billing information we may not use it for any other purposes.

If you are a Subscriber and decide to discontinue your subscription, we will archive your personal data and process it to fulfill data retention obligations imposed on us by Polish accounting and tax regulations. We will delete your data after all such statutory data retention periods lapse.

Using Offhub

Whenever you make use of Offhub as our Free User or Subscriber, we will record certain information connected with the way you use Offhub. This information may encompass:

• our servers log information gathered when you connect with our Website  (e.g. your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences as well as data from cookies and similar technologies);
• information about the device that you use to connect with our Website (e.g. the type of device that you are using, the system under which it operates, your network information and unique device identifiers such as your MAC address);
• information about your approximate geographic location inferred from your IP address;
• metadata about your interactions with Offhub - whenever you use Offhub, some metadata which provides high-level (non-content) information about the way you use Offhub is generated  (e.g. the way you navigate the website, the features and functionalities that you interact with, third party services and integrations that you use).

The processing of your personal data in this case is either necessary to perform a contract which is concluded between you and us when you decide to use our Website (points a. and b.) or is based on our legitimate interest - the need to conduct statistical analysis on how our Offhub is used in order to make it better (points c. and d.).

When the processing of your data is necessary to perform a contract we will keep it until all your claims associated with your use of our Website become time-barred. When the processing of your data is based on our legitimate interest, we will keep it until you object against such processing.

End Users data

As a Free User or Subscriber, you remain the controller of your End Users personal data included in your Offhub workspace and workspace content. When we process the content of Offhub workspace, which encompasses personal data of End Users, we are a data processor, which means that we collect and process personal data solely on your behalf. We will process your End Users’ personal data in accordance with the Personal Data Processing provisions contained in our Terms of Service. These Terms contain all of our representations and obligations as data processor and – once accepted by you – constitute a Data Processing Agreement, as prescribed by art. 28 of the GDPR.

End Users

Who is the controller of your personal data?

If you are an End User, the Free User and Subscriber who invited you to join their Offhub workspace is the controller of your personal data included in your Offhub workspace content. When we process the content of Offhub workspace, which encompasses personal data of End Users, we are a data processor, which means that we collect and process personal data solely on behalf of respective Free User or Subscriber who owns that workspace. Thus, if you have any questions about your workspace privacy settings and/or practices and/or want to exercise your rights in relation to personal data contained in an Offhub workspace that you use, you should contact directly the Free User or Subscriber who manages that workspace.

As Offhub, we will, however, record certain information connected with your use of Offhub. This information may encompass:

• our servers log information gathered when you connect with our Website  (e.g. your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences as well as data from cookies and similar technologies);
• information about the device that you use to connect with our Website (e.g. the type of device that you are using, the system under which it operates, your network information and unique device identifiers such as your MAC address);
• information about your approximate geographic location inferred from your IP address;
• metadata about your interactions with Offhub - whenever you use Offhub, some metadata which provides high-level (non-content) information about the way you use Offhub is generated  (e.g. the way you navigate the website, the features and functionalities that you interact with, third party services and integrations that you use).

The processing of your personal data in this case is either necessary to perform a contract which is concluded between you and us when you decide to use our Website (points a. and b.) or is based on our legitimate interest - the need to conduct statistical analysis on how our Offhub is used in order to make it better (points c. and d.).

When the processing of your data is necessary to perform a contract we will keep it until all your claims associated with your use of our Website become time-barred. When the processing of your data is based on our legitimate interest, we will keep it until you object against such processing.

Contacting us

If you are an End User and decide to contact us, we will ask you to give us your name and your contact details. We will use this data to answer your questions. The processing of your personal data in this case is based on our legitimate interest, i.e. the need to respond to business queries received from our End Users. You are not obliged to give us any of the information above, but we may not be able to answer your questions if you do not give us your personal data. We will delete your personal data after your matter is solved and information about you is no longer needed.

Mobile Apps Users

The rules for the processing of personal data concerning Free Users, Subscribers and End User apply respectively to the processing of personal data in connection with the use of our Mobile Apps. Thus:

• when you use Mobile Apps as our Free User or Subscriber, we will be the controller of your personal data;
• when you use Mobile Apps as End User, the Free User or Subscriber who invited you to join their Offhub workspace is the controller of your personal data included in your Offhub workspace content; we may, however, gather some general information about the way you interact with Offhub and the ways you use our Mobile Apps, as described above.

How long do we keep Mobile Users data?

If you are a Mobile User, we will keep your personal data for the whole period of your use of Offhub and no longer than 12 months after you stop using Offhub.

What are your rights?

General

You may ask Offhub to exercise the rights described below when Offhub is controller of your personal data.

In order to comply with requests concerning your rights, sometimes we may ask you to give us some additional information that we will use to verify your identity. If you fail to provide such information and the information that you have already given to us is not sufficient to identify you, we may refuse to fulfill your request.

If you wish to exercise any of the rights described below you can do this by contacting us at privacy@offhub.io.

Access to data

You have the right to access the information that we have on you. If you choose to exercise this right, upon your request, we will also make sure to provide you with a copy of the data we process about you.

We will fulfill your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.

Rectification of data, erasure and restriction of processing

If you believe that the information we have about you is incorrect, you are welcome to contact us, so we can update it and keep your data accurate.

We will automatically delete information about you after it is no longer needed for the purposes it was collected for. Nonetheless, if at any point you wish for us to delete information about you, you have the right to do so.

You also have the right to obtain restriction of processing of your data.

Data portability

In case the processing of your personal data is based on a contract or your consent, you have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format. You can also request us to transmit such data to another controller if it is technically feasible.

Withdrawal of consent and the right to object to processing

If the processing of your data is based on a consent, you have the right to withdraw your consent at any time. Remember that withdrawal of consent will not affect the lawfulness of processing based on this consent before its withdrawal.

In case the processing of your data is based on our legitimate interest you have the right to object to such processing.

Profiling

We do not use any information provided by you for the purposes of automated decision-making, including profiling.

Disclosure of your data

We guarantee that all your personal information is protected, and that we will not make this information available to third parties in cases different than those specified below, unless you give us a permission to do so or unless such disclosure is necessary to comply with a legal obligation that is imposed on us.

We may share information that you gave to us with the following:

• Free Users, Subscribers and End Users:
  - providers of services necessary to make Offhub available to you (e.g. hosting and other IT services);
  - providers of services necessary to automate and simplify the deployment and maintenance of Offhub (e.g. services such as sentry.io and Mixpanel);
• Free Users and Subscribers:
  - providers of services necessary to send transaction-related and product-related information via email to the extent that such disclosure is necessary to automate, simplify and analyze these processes.
  - our legal advisors to the extent that such disclosure is necessary to obtain legal advice or protect our rights in legal proceedings;
  - governments and law enforcement authorities only if we are required to do so by law. We will always attempt to redirect the law enforcement agency or government to request any data directly from you. If compelled to disclose your data, we will promptly notify you and provide a copy of the demand.
• Subscribers:
  - payment processors in order to be able to process and complete the payment process for your subscription;
  - external accounting and bookkeeping services providers to the extent that such disclosure is necessary to have these services provided to us.

We may share information on End Users that we process on behalf of Free Users or Subscribers only if required to do so by law or if necessary to protect our rights in legal proceedings.

International data transfers

Whenever possible, we will try to use processors which process personal data within the European Economic Area (“EEA”). In case there is a need for us to use processors located outside of the EEA, we will only disclose personal data to them provided that appropriate international data transfer safeguards described in the GDPR are in place.

As of the date of this Privacy Policy, we may transfer information that you provided us with to the United States of America. Such transfer will rely either on Binding Corporate Rules implemented by our subprocessors, standard data protection clauses approved by the European Commission or will be made within the Privacy Shield framework.

If you have further questions about international data transfers that we make or want to obtain a copy of the safeguards that are in place to guarantee the legality of the transfer you can contact us by sending an email at privacy@offhub.io.

Third-party integrations

If you choose to use or connect Offhub to any third-party integrations (e.g. Slack), such third parties may allow us to have access to and store additional information about your interactions with those services as it relates to your use of Offhub. Moreover, if you initiate these connections, you also understand that we will share information about you that is required to enable your use of Offhub through a third-party integration. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through them, and you understand that the privacy policies of these third parties govern such connections.

Cookies

Our Website supports the so-called 'cookies', which are small files containing information saved to your hard drive. We use cookies for several purposes:

• to improve user experience, e.g. to make it possible for you to log in to your Offhub account without having to retype your credentials. This kind of cookies are necessary for our Website to work properly, but you can disable some of the functionalities that use cookies (such as the “Keep me logged in” functionality) without any consequences.
• to collect anonymous and aggregated statistical data about users’ visits on our Website. We use this data to analyze how our websites are used and to improve them using Google Analytics. We use the following cookies from Google Analytics:

Unless you set up your internet browser (e.g. Mozilla Firefox or Google Chrome) not to accept cookies, it will accept the use of them. You can always disable cookies in your browser’s preferences even if you have consented to the use of cookies in the past. You may also delete cookies stored on your computer at any given time. Please note that disabling cookies may negatively impact your online experience on our Website or prevent you from using certain websites or logging into our web applications.

Changes to the Privacy Policy

We constantly review our Privacy Policy and strive towards making it better. That is why we reserve the right to amend this Privacy Policy from time to time. We will not reduce any of your rights stated in this Privacy Policy without asking for explicit prior consent to the changes. Each amendment to the Privacy Policy will be signed with the date of publishing and will be effective from that date. You can access previous versions of this Privacy Policy [here].

How to contact us and seek additional help?

If you have any questions or doubts related to this Privacy Policy or want to know more about how we protect your personal data or your rights, you can contact us by sending an email at privacy@offhub.io.

We hope that we will be able to answer all your questions and settle all disputes amicably. Nonetheless, if you think that your rights were not observed or that your privacy was harmed, you can always lodge a complaint with a competent data protection authority.