Data controller
The data controller is Huberway LLC, a Wyoming limited liability company, with its registered office at 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801, USA, EIN 35-2903558.
For privacy enquiries and to exercise your rights, email hello@huberway.com.
Categories of data processed
- Identification and contact data: first name, surname, email, telephone number, company and role.
- Account data: credentials, roles, permissions, access logs and configurations.
- Commercial and administrative data: plan, invoicing, payments and support requests.
- Operational data processed in the platform: products, end customers, orders, stock levels, transactions, documents, integrations and communications configured by the customer.
- Technical data: IP address, browser, device, application logs, cookies and online identifiers.
Purposes and legal bases
- Providing the service, creating accounts and managing access and contracts: performance of a contract or pre-contractual measures.
- Responding to sales and support enquiries: pre-contractual measures, performance of a contract or legitimate interests.
- Complying with tax, accounting and regulatory requirements: legal obligation.
- Protecting security, preventing abuse and maintaining technical logs: legitimate interests and security obligations.
- Sending marketing communications, newsletters or promotional campaigns: consent or legitimate interests where permitted.
- Using non-essential cookies and tracking tools: consent, where required.
Data protection roles within the platform
For data entered into the platform by the customer concerning its customers, employees, suppliers or end users, the customer normally acts as data controller and Esdra as data processor.
Processing carried out on behalf of the customer is governed by the Esdra DPA and any other agreements entered into by the parties.
Retention
Data is retained for as long as necessary for the stated purposes, management of the contractual relationship, compliance with legal obligations and the protection of rights.
Account and platform data is retained for the duration of the relationship and for the technical period required for termination, export, deletion or defence against claims.
Recipients and transfers
Data may be processed by technical suppliers, hosting providers, payment, invoicing, support, email, analytics, security and integration services, and professional advisers.
Where a supplier operates outside the EEA or involves international transfers, Esdra adopts the safeguards required by applicable law, including contractual instruments and supplementary measures where necessary.
Data subject rights
- Access to personal data.
- Rectification or updating.
- Erasure where applicable.
- Restriction of processing.
- Data portability.
- Objection to processing.
- Withdrawal of consent, without affecting processing carried out beforehand.
- Lodging a complaint with the Italian Data Protection Authority.
