Privacy Policy

Hubtiger Proprietary Limited

REG: 2018/316615/07

This Privacy Policy outlines how Hubtiger Holdings (“Hubtiger,” “we,” “us”) collects, processes, and safeguards your personal information in compliance with global privacy laws, including but not limited to the Protection of Personal Information Act 2013 (POPIA) and the General Data Protection Regulation (GDPR) [EU Regulation 2016/679]. This policy also incorporates requirements under relevant national privacy laws where applicable.

By using the Hubtiger Application (the “Platform”), you (“User”) agree to the terms of this Privacy Policy. Hubtiger may update this policy from time to time, and all amended terms take effect immediately upon posting. Continued use of the Platform following an update indicates your acceptance of the revised terms.

Hubtiger does not knowingly market or provide services to individuals under 18 without parental consent. This Privacy Policy applies to all access methods, including internet browsers, smartphones, tablets, or other devices. If you do not agree to this Privacy Policy, please discontinue using the Platform.

This Privacy Policy was last updated on 06 November 2024. Please check our website at www.hubtiger.com regularly for updates or contact us at info@hubtiger.com with any questions.

1. Understanding Personal Information

The term “personal information” refers to any data that can personally identify you, as defined by applicable privacy laws in the country where you are based or use the platform. This may include, but is not limited to, your name, surname, address, telephone number, email address, and occupation. If the information we collect identifies you personally, or you are reasonably identifiable from it, we treat it as personal information. Hubtiger will not share, sell, rent, or disclose your personal information except as described in this Privacy Policy.

 

Processing of Personal Information
Processing personal information includes activities such as collection, receipt, recording, organization, storage, updating, retrieval, alteration, use, dissemination, or making available by other means; as well as merging, linking, blocking, degradation, erasure, or destruction of information.

Hubtiger adheres to the principles and requirements of the applicable privacy legislation when processing personal information, striving to ensure that processing is lawful, adequate, relevant, and not excessive for the intended purpose.

If you choose to connect your account with third-party platforms (e.g., Strava), you consent to these third parties providing registration and other relevant account information to Hubtiger. Using these credentials to log into your Hubtiger account signifies your agreement to the third-party platform’s terms, conditions, and policies.

2. Personal Information Collected

2.1 The Platform collects and processes information that can be used to identify you personally (“Personal Information”) when it is necessary for providing, facilitating, and maintaining the Hubtiger services and ensuring compliance with relevant data protection laws.

 

2.2 We collect Personal Information from the following entities:

a) Individuals over 18;

b) Users who have signed up to use the Hubtiger Application;

c) Facebook, Apple, or Strava, for Users who choose to log in using an existing Facebook, Apple, or Strava account;

d) Data caches and logs collected automatically from your device and our internet service provider.

 

2.3 Personal Information collected by Hubtiger may include:

a) Name and surname;

b) Email address;

c) Date of birth (used to confirm age and eligibility);

d) Gender (optional);

e) Telephone number;

f) Location information;

g) Device identifiers such as IP address.

 

2.4 When you register or log into your account via Facebook, Apple, or Strava, you consent to these third parties providing Hubtiger with relevant registration details and profile information as required to facilitate account access. Logging in via third-party platforms implies acceptance of each platform’s terms, conditions, and privacy policies.

 

2.5 Geographic location information is collected only if you enable location settings on your device. You can use the Application without sharing your location data; however, opting out may limit the full range of Hubtiger’s services available to you.

 

2.6 We may collect Personal Information through your activities on the Platform, including account setup, interaction with service features, and participation in community events.

 

2.7 Occasionally, we may collect information that does not identify you individually, such as aggregated data about how users engage with the Platform. This type of data is not considered Personal Information.

 

2.8 Hubtiger also collects non-personal information related to your activities on the Platform, such as mileage, gear settings, service history, routes planned, and events attended. This data enables us to provide a more personalized and functional service.

 

2.9 If you do not want us to collect Personal Information, please refrain from submitting it when prompted. Note that without this information, certain features of Hubtiger’s services may not be available.

3. Purpose of Collecting Personal Information

3.1 The primary purpose for collecting and processing Your Personal Information is to enable us to provide You with access to the Hubtiger Platform and its related services. Hubtiger also collects and processes Your Personal Information for the following specific purposes:

3.1.1) To create and manage Your account on the Platform;
3.1.2) To track bicycle component usage in order to provide Users with relevant service indicators and reminders;
3.1.3) To enable cycling service providers to better understand cyclists’ needs and improve service offerings;
3.1.4) To track cycling routes, distances, and times for performance and progress analysis;
3.1.5) To track incidents and provide alerts to cyclists for safety purposes;
3.1.6) To process and respond to any complaints or inquiries You may have, ensuring that Your concerns are addressed;
3.1.7) To assess the performance, effectiveness, and user satisfaction of Hubtiger services;
3.1.8) To send legitimate electronic communications, including but not limited to notifications, service-related updates, and transactional messages;
3.1.9) To provide You with responses or feedback on any related inquiries or requests;
3.1.10) To send You direct marketing communications related to Hubtiger’s services, in accordance with applicable laws and Your consent;
3.1.11) To update and maintain our records, including ensuring that Your contact details are accurate and up-to-date;
3.1.12) To comply with applicable laws, rules, regulations, or any lawful direction from regulatory bodies or governmental authorities of any country.

 

3.2 Additionally, we may use the information collected to improve our internal technical and business processes, including but not limited to:

  • Measuring cycling route patterns and bicycle part usage in aggregate;
  • Analysing trends, user behaviour, and usage patterns to improve services and performance;
  • Administering the Hubtiger Platform, tracking User interactions, and gathering anonymized demographic information for service optimization.

 

3.3 Contacting You During a Trial Period

By signing up for a trial, you expressly consent to be contacted by Hubtiger for the purposes of offering support, guidance, and follow-up related to your trial experience. This may include, but is not limited to, email or phone communication regarding the trial, feedback requests, product updates, or other relevant information necessary to enhance your trial experience. You may withdraw your consent at any time by following the instructions in the communication or by contacting us directly at info@hubtiger.com.

4. Consent to Processing Personal Information

4.1 By using the Platform, You hereby consent to the collection, use, and processing of Your Personal Information for the purposes described in this Privacy Policy and for any other associated purposes necessary for providing, maintaining, and improving the Platform and our services. This includes, but is not limited to:
a) updating and maintaining our records;
b) keeping Your contact details accurate and up to date;
c) complying with applicable laws, rules, regulations, lawful and binding determinations, decisions, or directions from a regulator, or cooperating with any governmental authority in any jurisdiction where Hubtiger operates.

 

4.2 By using the Platform, You affirm that You have read, understood, and agreed to the terms set forth in this Privacy Policy. You consent to the collection and processing of Your Personal Information as described herein, including consent for the processing of sensitive personal data, where applicable.

 

4.3 Your Personal Information may be processed by Hubtiger in the country where it was collected and in other countries, including jurisdictions where the laws regarding the processing of Personal Information may differ. By providing Your Personal Information and continuing to use the Platform, You expressly consent to the transfer of Your Personal Information to these countries, subject to the applicable laws and safeguards in place to protect Your data.

 

4.4 Consent to receive direct marketing communications from Hubtiger is obtained during the registration process. By completing the registration process and continuing to use the Platform, You confirm that You have provided informed consent to receive communications about Hubtiger’s business activities, products, services, updates, and promotional offers. You retain the right to withdraw Your consent or opt-out of direct marketing communications at any time, in accordance with the applicable laws and your personal preferences. Unsubscribing from marketing communications does not affect the provision of service-related communications necessary for the operation of the Platform.

5. Handling of Personal Information

5.1 Hubtiger seeks to ensure the quality, accuracy, and confidentiality of the Personal Information in its possession. You warrant that all Personal Information supplied by You is accurate, complete, and correct at the time of provision. If any aspect of Your Personal Information changes, it is Your responsibility to promptly update Your profile information via the Platform. You acknowledge and agree that Hubtiger is not liable for any inaccuracies or errors in the information you provide.

 

5.2 You warrant that You have obtained all necessary consents, permissions, and authority to provide Hubtiger with any third-party information submitted to Hubtiger. You further agree to indemnify Hubtiger from any claims, losses, or damages arising from a breach of this warranty.

 

5.3 Hubtiger will take all reasonable and appropriate technical and organizational measures to ensure that Your Personal Information is appropriately safeguarded. These precautions include, but are not limited to, access control mechanisms (such as usernames and passwords), encryption, and secure storage of information. We also conduct regular audits and security assessments to ensure the ongoing confidentiality, integrity, and availability of Your Personal Information.

 

5.4 In the event that an unauthorized person gains access to Your Personal Information, Hubtiger will notify You of such an event within a reasonable time frame, in compliance with applicable data breach notification laws, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). The notification will include relevant details of the breach, its potential impact, and steps taken to mitigate the breach.

 

5.5 Hubtiger shares Your Personal Information with authorized third parties, such as bicycle retailers, servicing shops, and other service providers necessary to facilitate the services provided through the Platform. Hubtiger ensures that any third parties with whom Your data is shared are contractually bound to maintain confidentiality and only use Your Personal Information to provide the services they were engaged to perform. All processing by third parties is carried out in compliance with applicable laws and Hubtiger’s data protection policies. Hubtiger does not permit these third parties to use Your Personal Information for any purposes other than as necessary to perform the contracted services. Additionally, Hubtiger may share aggregated and anonymized data for analytical and reporting purposes, provided that such data cannot be used to identify You directly.

6. Retention and Restriction of Records

6.1 Upon receipt of a request from You, Hubtiger will take all reasonable steps to delete or destroy records of Your Personal Information that Hubtiger is no longer authorized to retain. This is subject to certain exceptions, such as when Hubtiger is required by law to retain certain records for a specified period. Hubtiger is entitled to retain de-identified or anonymized data for legitimate, authorized purposes, such as research, statistical analysis, and business improvement activities, provided that such data cannot be used to identify You.

 

6.2 If You wish to withdraw Your consent to the processing of Your Personal Information and request that Hubtiger remove or delete Your Personal Information entirely, You can cancel Your account. You may also contact Hubtiger directly at info@hubtiger.com to request the deletion of all Your Personal Information. Hubtiger will comply with Your request, subject to any legal obligations to retain certain records or for legitimate business purposes.

 

6.3 You expressly consent to Hubtiger retaining Your Personal Information for a period of time after the termination of Your relationship with Hubtiger for evidential purposes. Hubtiger may also use Your Personal Information for aggregate, statistical, and research purposes, provided that any data used for these purposes is anonymized or aggregated in a manner that does not allow the identification of You or any other individual.

 

6.4 Hubtiger may retain records of the provision of information to and/or by You in accordance with legislative record retention requirements. This may include Your Personal Information if required by applicable laws, regulations, or contractual obligations.

 

6.5 Hubtiger may retain records for a period longer than is required by law for statistical, research, or analytical purposes, and You hereby consent to such retention of Personal Information for those purposes, provided that such retention complies with applicable data protection regulations and ensures Your information remains adequately protected.

7. Updating Personal Information

7.1 You may request access to any Personal Information we hold about You at any time by sending an email to info@hubtiger.com. Hubtiger will respond to such requests within a reasonable time frame, and in accordance with applicable data protection laws.

 

7.2 If You believe that Personal Information we hold about You is incorrect, incomplete, or inaccurate, You may request that we correct or update the information. Upon receiving your request, Hubtiger will assess whether the information requires amendment. If we determine that the information cannot be amended, we will inform You of the reasons for this decision and retain a note of your request.

 

7.3 You have the right to access, update, and correct Your account information at any time through the Platform. You are entitled to add, delete, or amend information in Your account, and Hubtiger will update its records accordingly.

 

7.4 There may be certain circumstances where we cannot grant You access to the Personal Information we hold. We may refuse access if granting access would interfere with the privacy rights of others or if it would result in a breach of confidentiality or other legal obligations. In the event of a refusal, Hubtiger will provide You with written reasons for the decision and advise You of any available recourse.

8. Sharing Personal Information

8.1 Business records relating to the provision of information or services to You may be retained by Hubtiger in accordance with legislative record retention requirements, and may include Your Personal Information. These records are kept for operational, business, and evidential purposes. When Hubtiger shares Your Personal Information with employees or other Users, Hubtiger ensures that such parties are authorized to use the information solely for the purpose of using, maintaining, and/or operating the Platform and the services provided by Hubtiger.

 

8.2 We may disclose Your Personal Information to the following parties for the purposes outlined in this Privacy Policy:

8.2.1) Our employees, contractors, or agents to enable us to operate the Platform and provide services to You;

8.2.2) Third-party service providers (such as payment processors, cloud storage providers, or technical support) to assist in the provision of products or services to You;

8.2.3) Service Providers to help administer, maintain, or improve the Platform or services;

8.2.4) Any third-party organization for an authorized purpose with Your explicit consent.

 

8.3 Hubtiger will not permit any third parties to use Your Personal Information for purposes other than those required for using, maintaining, administering, and/or running Hubtiger services. Third-party service providers are required to treat Personal Information in accordance with this Privacy Policy and applicable laws.

 

8.4 We may disclose Your Personal Information in the following instances:

8.4.1) To comply with any applicable law, legal process, or regulatory requirements;

8.4.2) To protect Hubtiger’s rights, property, and other assets, including intellectual property;

8.4.3) To protect Hubtiger from misuse, fraud, or unauthorized use of the Platform;

8.4.4) To safeguard the interests of Users or third parties affected by actions you take while using the Platform, particularly where those actions may negatively impact others.

 

8.5 Hubtiger may further disclose Your Personal Information to Service Providers who monitor usage of the Platform and security systems to identify and prevent unauthorized access, uploads, or attempts to alter any stored Personal Information.

 

8.6 Your Personal Information may be stored on servers outside of South Africa and, in certain cases, outside the country of your residence. This means Your Personal Information could be subject to different data protection laws. By using the Platform, You explicitly consent to the transfer and storage of Your Personal Information in countries that may have different data protection standards from those in South Africa or your country of residence.

 

8.7 Hubtiger has implemented contractual and technical safeguards to protect Your Personal Information when it is transferred to or stored with third-party Service Providers. These safeguards include the use of data processing agreements in compliance with applicable data protection laws (such as the GDPR). While Hubtiger ensures that appropriate safeguards are in place, we will not be held liable for any damages resulting from illegal or unauthorized activities by third parties who process or store Your Personal Information.

9. Uploading Personal Information

9.1 If You are uploading Personal Information in connection with Your use of the Platform, You undertake that You are responsible for ensuring compliance with all applicable privacy and confidentiality regulations that apply to You and that You warrant the following:

9.1.1) You have the legal right and/or consent to upload the Personal Information. This consent must be provided by You and pertains to Your use of the Platform, including for any third-party data uploaded.

9.1.2) You are aware that processing sensitive Personal Information (such as health data, racial or ethnic origin, etc.) without explicit consent is prohibited under privacy regulations, and You have obtained such explicit consent when necessary.

9.1.3) You are fully aware of the specific purposes for which Your Personal Information is being collected and processed.

9.1.4) Hubtiger’s processing of Your Personal Information is reasonably associated with the purpose for which it was collected and/or for which consent was obtained, in accordance with applicable laws.

9.1.5) You do not object to the processing of Your Personal Information by Hubtiger, as outlined in this Privacy Policy.

9.1.6) You have taken reasonable steps to ensure that the Personal Information uploaded is complete, accurate, not misleading, and updated where necessary, taking into account the purposes for which it was collected, as well as the requirements of relevant privacy laws.

9.1.7) You agree that Hubtiger will not be held liable for any illegal activities or other claims for damages resulting from the mishandling or lack of protection of Personal Information while under the care of third parties, provided Hubtiger has fulfilled its responsibilities to ensure proper data protection measures are in place.

10. Security of Safeguards

10.1 We take reasonable steps to ensure that Your Personal Information is protected from misuse, loss, and unauthorized access, modification, or disclosure. However, we cannot guarantee the absolute security of Your Personal Information. As a result, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access, or other acts beyond our reasonable control. Please note that despite our efforts, no method of electronic transmission or storage is completely secure.

 

10.2 We use third-party service providers who may have access to Your Personal Information, and these providers have undertaken contractual obligations to protect Your Personal Information in compliance with applicable data protection laws, including taking adequate security measures to prevent unauthorized access or disclosure.

 

10.3 In the event of an unauthorized access to or use of Your Personal Information, we will notify You as soon as reasonably practicable via both email and cell phone. We will provide You with sufficient information to allow You to understand the nature of the breach, and we will work with the relevant authorities, if necessary, to mitigate any harm resulting from the breach.

 

10.4 As our Application is linked to the internet, which is inherently insecure, we cannot provide absolute assurance regarding the security of the transmission of information You communicate to us online. While we take reasonable security measures to protect Your data during transmission, we cannot guarantee that information will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information that You transmit to us online is done at Your own risk.

11. Indemnity

You agree to indemnify and hold Hubtiger, its officers, directors, employees, agents, licensors, suppliers, and members harmless from and against any claims, damages, actions, and liabilities, including without limitation, loss of profits, direct, indirect, incidental, special, consequential, or punitive damages, arising out of any errors, inaccuracies, or irrelevance in the Personal Information you provide, should such information be incorrect, incomplete, or misleading in connection with your use of the Application.

12. Data Subject Participation

If You have any enquiries concerning Personal Information processed by Hubtiger, You may request information regarding the Personal Information Hubtiger holds about You, including details about third parties or categories of third parties who provide services to Hubtiger and who have had access to Your information. You may also request that Hubtiger correct or delete Personal Information in its possession or under its control that is inaccurate, irrelevant, excessive, misleading, or obtained unlawfully; or that Hubtiger destroy or delete any Personal Information it is no longer authorized to retain. As a User, You can access Your Personal Information via the Application and the Website.

In addition to the above, Users entitled to broader protection standards may exercise any of the following rights:

  • Learn whether data relating to You is being processed.
  • Request further information about the processing of Your Personal Data.
  • Learn the purpose for the processing of Your Personal Data and whether such processing complies with the stated purpose.
  • Request a copy of Your Personal Data held by Hubtiger.
  • Learn to which third-party recipients Your Personal Data has been disclosed.
  • Request rectification of incomplete or inaccurate Personal Data and have such rectification communicated to any third parties to whom the Personal Data was transferred.
  • Request the deletion or destruction of Your Personal Data when it is no longer necessary for the purpose for which it was collected, subject to applicable legal obligations, and request such deletion to be communicated to any third parties to whom the Personal Data was transferred.
  • Obtain Your Personal Data in a structured, commonly used, and machine-readable format, and request Hubtiger to transmit this data to another data controller.
  • Object to decisions made solely on the basis of automated processing that produces legal effects concerning You or similarly significantly affects You.
  • Object to the processing of Your Personal Data in certain circumstances (particularly when Hubtiger no longer needs the data to meet contractual or legal requirements, or where Hubtiger is using the data for direct marketing purposes).
  • If You have unresolved concerns, You have the right to lodge a complaint with a supervisory authority in the EU or UK, or in the jurisdiction where You reside or where the breach occurred.

Under the GDPR, these rights may be subject to certain limitations, such as when fulfilling Your request would reveal personal data about another person, infringe on the rights of a third party (including Hubtiger’s own rights), or if You request the deletion of information Hubtiger is legally obligated to retain, or where there are compelling legitimate interests in retaining the data. Hubtiger will inform You of any applicable exemptions when responding to requests.

13. Openness

13.1 If You have any questions, concerns, or complaints regarding our privacy practices, please contact us via email at info@hubtiger.com. We will address Your concerns promptly and to the best of our ability. We are committed to responding to all inquiries in a timely and transparent manner.

 

13.2 We will treat all requests or complaints confidentially, and we will work with You to resolve any concerns. If we are unable to resolve Your complaint, we will inform You of any available options for escalating the issue, including the option to lodge a complaint with the relevant data protection authority, where applicable.

14. Applicability of Broader Protection Standards

14.1 While most provisions of this Privacy Policy apply to all users, certain provisions will apply only when the processing of Personal Data is subject to broader protection standards as set out in the General Data Protection Regulation (GDPR). These broader protection standards may apply when the processing:

14.1.1) Is carried out by a data controller or data processor established in the European Economic Area (EEA) or the United Kingdom (UK);

14.1.2) Concerns the Personal Data of users who are located in the EEA or UK, and relates to the offering of goods or services, whether paid or unpaid, to those users; or

14.1.3) Concerns the Personal Data of users who are located in the EEA, EU, or UK, and enables a data controller to monitor the behaviour of such users within the EEA or UK.

15. Lawful Bases (EEA or UK)

15.1 The lawfulness of personal data processing is a fundamental principle under the General Data Protection Regulation (GDPR). For the purposes of EU or UK data protection law, we typically process personal data based on the following lawful bases:

15.1.1) Performance of a contract: We need to process personal data to perform a contract we are about to enter into or have already entered into with you, such as when we process payments or deliver services.

15.1.2) Legitimate interests: It is in our legitimate interests, or those of a third party, to process personal data, provided that your data protection rights and freedoms do not override those interests. This may include securing services, fraud prevention, and certain direct marketing activities.

15.1.3) Compliance with a legal obligation: We process personal data to comply with a legal or regulatory obligation to which we are subject, such as tax reporting or compliance with data retention laws.

15.1.4) Consent: We have obtained your consent to process your personal data for specific purposes, such as for marketing or sharing your data with third parties.

16. Notice to Users from the EEA or UK

16.1 Personal Information that we collect and use may be processed outside your country or region. When we transfer personal data to third parties located in countries outside the European Economic Area (EEA) or United Kingdom (UK), we ensure that appropriate safeguards are applied to protect your data. For instance, data transferred from the EEA and UK is typically protected using EU Standard Contractual Clauses (SCCs), or other appropriate legal mechanisms recognized under the GDPR. By using our services, you:

16.1.1) Acknowledge that your personal information will be processed as described in this Privacy Policy; and

16.1.2) Consent to the transfer of your personal information to third-party partners, including those located in the USA, whose servers are used to process and store data. These third-party partners may also transfer your data across borders to other countries, including those outside your country of residence, depending on how the data is processed and stored. Please note that these countries (including the USA) may not have data protection laws as comprehensive as those in your country of residence; however, our collection, storage, and use of your personal information will continue to be governed by this Privacy Policy, with adequate safeguards in place to protect your data.

16.1.3) By providing your personal information to us, you expressly consent to the transfer and processing of your personal information outside the EEA or UK, including in the USA, subject to the terms of this Privacy Policy.