Privacy Policy

Privacy Policy

1. INTRODUCTION

UKHUB Data Exchange ltd (UKDE) is a non-profit membership company, established in July 2018. We provide the UK Hub Service to the oil&gas Industry on UKCS. More info about the UK Hub Service is available in the Terms section of this website.

We are committed to protect and respect your privacy.

This policy has been developed to explain how we may collect, process, share, transfer and retain your personal data when you are acting as:

  • A User of the UK Hub Service, meaning an individual having a user account in the UK Hub Service, and/or
  • A company representative towards UKDE,  where you have been appointed by your company, being an UK Hub Service member, to fulfil certain duties and responsibilities towards UKDE.

2. WHY DO WE COLLECT PERSONAL DATA?

We collect and process personal data in order to be able to provide the UK Hub Service to the Users.

Our collection and processing of personal data is necessary in order to enter into and/or perform a contract regarding the UK Hub Service, therefore, necessary for the purposes of the legitimate interests pursued by your company.

3. WHICH PERSONAL DATA DO WE COLLECT?   

We do not collect any sensitive personal data, and will only collect limited personal data required to be able to fulfil our role as a provider of the UK Hub Service according to agreements and regulations governed by agreements with our UK Hub Service member companies, their services providers  and  suppliers/manufacturers of equipment. Our collection and use of personal data is in accordance with applicable data protection legislation (including GDPR) and embedded into UKDE’s processes and procedures.

The processing of personal data by UKDE on behalf of the UK Hub Service member companies, their services providers  and  suppliers/manufacturers of equipment, only covers categories of personal data which are implied under the Agreement for the purpose of entering into the Agreement, management and/or follow-up of the Agreement and providing the UK Hub Service, and only to the extent and as long as necessary to fulfil such purposes.

UKDE may and will use system event information for enabling secure and efficient delivery and operation of the UK Hub Service and/or to identify and correct security Incidents. Such information is not stored longer than necessary to reach the goal of secure operation and are not shared with the UK Hub Service member companies, their services providers  and  suppliers/manufacturers of equipment or other third parties (sharing with subcontractors on a need-to-know basis will be allowed). The UK Hub Service member companies, their services providers  and  suppliers/manufacturers of equipment acknowledges that UKDE is not obliged to disclose information to the UK Hub Service member companies, their services providers  and suppliers/manufacturers of equipment in respect of individual Users’ use of the Services.

As an individual user of the UK Hub Service our aim is to only collect data required to provide  secure access for you to the UK Hub Service, as well as fulfilling our obligations to your company according to relevant and applicable agreements. When you use the UK Hub  Service, UKDE act as data processor, and your company having instructed you to use the UK Hub Service, act as data controller.

UKDE’s operations may from time to time require us to maintain various contact points towards the industry including but not limited to UK Hub Service member companies, their services providers  and  suppliers/manufacturers of equipment. When you have been instructed by your company to fulfil certain duties and responsibilities towards UKDE, we may collect limited personal information about you that typically include name, email, company you represent, title/role and phone numbers. This personal information is typically stored in our relationship support systems and used for efficient management of the referenced duties. In these settings UKDE act as data controller as we define the use of the personal data.

4. AUTOMATIC COLLECTION TOOLS AND COOKIES  

The UK Hub Service may store and retrieve information, such as cookies, on your devices. Such storage and retrieval of information will in most cases be technically required in order to provide the service and requires no further actions from you unless otherwise instructed.

5.UK HUB SERVICE PROCESSING OF PERSONAL DATA

During the provision of the UK Hub Service, UKDE may process personal identifiable information limited to the Users of the UK Hub Service. No personal preferences categorized as personal identifiable information are used. Personal identifiable information for the UK Hub Service are:

User Account information

  • Full name
  • Job title
  • Email address
  • Log-in name
  • Company (where user is employed)
  • Phone/Mobile number  
  • Account status (active/deactivated)

Logging of User activity

  • Last login
  • Login history
  • Originating IP address
  • Browser type
  • Uploaded document/data
  • Edited document/data
  • Deleted document/data
  • Password change time

User Account information may be processes for identification of Users as part of the login process, sending important information to end users or by service desk staff as part of dialog with User related to support requested by User.

User activity logging information may be processed for qualifying problems reported to service desk  by the User, logging for legal compliance, basis for analysis to improve the performance of the UK Hub Service (anonymized data for this purpose) and security management

If you are not a User, but working with us as a representative for your company, we may process your personal data to send relevant information related to your role as contact point for your company, giving you access to any systems UKDE use related to you role and duties or for processing of business transactions like purchase orders, invoicing, payments and similar.

6.SHARING, TRANSPORTING AND RETAINING  PERSONAL DATA  

UKDE is provider of the UK Hub Service and do not sell or market any personal information we collect about you to any Third party. We may share your personal data with any of our  subcontractors directly involved in the delivery of the UK Hub Service, e.g. subcontractors delivering cloud services, information verification services and service desk. UKDE will in all such matters have a data processor agreement towards the subcontractor, preventing use of your personal data for other purposes than defined herein. The UK Hub Service is a collaborative service supporting the work scope for Users across companies. Limited information about you may as a consequence be shared with other Users, but then as part of your work scope where such sharing is key for executing.

UKDE is hosting the UK Hub Service within EU. Should processing require transfer of data for processing outside of the EU or involvement of subcontractors outside of the EU, we will make sure that the agreement with that subcontractor includes data processor agreements based on EU standard terms and conditions or is certified according to the EU/US Privacy Shield framework, if located in the US. In such cases, we will also inform your Company about such export of data.

Your User data related to the UK Hub Service ( ref. section 5 above) will for legal compliance not be deleted.

When you no longer represent your company towards UKDE we will delete your accounts from our systems.   These systems might still have traces of your earlier activities as representative for your company. Examples could be document metadata (created by), approval history on documents and other information required as part of the duties and roles you had related to UKDE on behalf of your company.

7. YOUR RIGHTS  

For personal data processing within the UK Hub Service, UKDE act as a data processor, only processing data according to the data processor agreement we have in place with your company, acting as the data controller. You should contact your company if you have questions about privacy not being answered by this privacy policy Similarly, you should contact your company if you want to exercise any of your other rights regarding protection of personal data.

If you are representing your company related to UKDE other than as a User of the UK Hub Service you have the following rights;

  • opt-out of receiving communications from UKDE which is not directly related to your duties and roles as a representative of your company.
  • request a copy of what personal data UKDE have stored about you and request the correction of any inaccuracies in your personal data, unless this can be done by yourself.
  • file a complaint with relevant data protection authority if you believe that our processing of personal data relating to you infringes applicable laws.

UKDE only store information about you as a representative of your company. Therefore rights to be “forgotten”, object to processing and data portability are considered not relevant for our processing of personal data regarding you.

8. PROTECTION OF PERSONAL DATA

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorised access, disclosure, and alteration. While we are dedicated to secure the UK Hub Service and other systems, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the personal data we maintain about you is accurate and current.

9. GENERAL

This Privacy Policy for the UK Hub Service may be changed from time to time to reflect changes to our business, the UK Hub Service, or applicable laws. Should changes be substantial, we will inform relevant contact point in your company.

We value your opinion. Should you have any comments, questions or concerns related to  this Privacy Policy please send them to us at support@uk-hub.co.uk.

All requests will be treated confidentially and we aim to ensure that complaints are resolved in a timely and appropriate manner.