PRIVACY STATEMENT

1. Introduction
We (“INNOVATION DEVELOPMENT HUB” LLC (hereinafter referred to as “IDHUB”) are strongly committed to protecting personal data. This Privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this Privacy statement or as otherwise stated at the point of collection. Personal data is any information relating to an identified or identifiable living person. IDHUB processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

2. Security
We take the security of all the data we hold very seriously. We adhere to internationally recognized security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

3. Data processing

3.1 Visitors to our website

3.1.1 Collection of personal data
Visitors to our websites are generally in control of the personal data shared with us.
We receive personal data, such as name, email address from website visitors; for example, when an individual subscribes to send an email to us through the website.
We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

3.1.2 Cookies
We use small text files called ‘cookies’ which assist in personalizing and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you.
The use of cookies is now standard operating procedure for most websites.
However, if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
You can find out more details regarding our use of cookies on our Cookies page.

3.1.3 Use of personal data
When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection). Typically, personal data is collected to:
• enquire for further information;
• distribute requested reference materials;
• aggregate data for website analytics and improvements.
Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

3.1.4 Legal basis for the processing
We will process personal data of visitors to our website based on our legitimate business interests or the consent, if the data subject has been requested to express one.

3.1.5 Data retention
Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).

3.2 Visitors to our offices
We have security measures in place at our offices, including CCTV and building access controls.
There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We will rely on the legitimate interest basis (assuring security at our offices).

4. Legal basis for processing
Legal bases for each processing activity are specified in the relevant sections above. When we process personal information for our legitimate interests, we make sure to consider and balance any potential impact on a data subject (both positive and negative), and the data subject’s rights under data protection laws. Our legitimate business interests do not automatically override interests of the data subjects – we will not process personal data for activities where our interests are overridden by the impact on the data subject (unless we have the consent or are otherwise required or permitted to by law).

5. Personal data sharing
We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
• Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

6. Data controller and processor
The data controller and processor is IDHUB. We have an official who is responsible for protecting personal data. If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Ukraine, Kyiv, Okhtyrsky lane, 7. ‘Forum Victoria Park’, Building 3, office 3-204
Email: info@idev-hub.com
Phone: +380 44 5947555

7. Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

7.1 Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at info@idev-hub.com.

7.2 Amendment of personal data
To update personal data submitted to us, you may email us at info@idev-hub.com .
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

7.3 Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time.
To withdraw consent to our processing of your personal data please email us at  info@idev-hub.com.

7.4 Right to restrict or object to our processing of personal data
You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by applicable law.
In such case, we will no longer process or restrict the processing of the personal data, unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

7.5 Other data subject rights
This Privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access, amendment and restriction or objection to processing referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion and the right to data portability. If you wish to exercise any of these rights, please send an email to info@idev-hub.com.

8. Complaints
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to info@idev-hub.com. We will look into and respond to any complaints we receive.