Privacy policy

Everything about how we handle your privacy and the functioning of our cookies.

This is the Privacy- and Cookie statement of Hubper Ltd., located on Arsenaalgas 8c, Nijmegen.

In this statement we will explain how we handle your personal data.

1 Introduction

Hubper Ltd. (hereafter: Hubper, ‘we’ or ‘our’), processes among other things personal data of users (hereafter: the ‘users’ or ‘you’). We process (certain) personal data on behalf of and based on the instructions of our customers with whom we have concluded a processing agreement. Based on the General Data Protection Regulation (GDPR) we are qualified in this context as processor.

Moreover, we process (certain) personal data for our own purposes, such as improving our products and services and offering the helpdesk services. In this context we are qualified as controller.

In this privacy statement we will inform you about the processing of the personal data for our own purposes (as a controller). We will explain, among other things, which personal data we process, for which purposes and how long these personal details will be saved. The privacy statement of the organisation that invited you to use the e-Learning software will inform you about the processing of personal data from our role as processor.

We take your privacy very serious and understand that it is important to be informed about the way your personal data is processed. We will only process personal data in the way described in this privacy statement and for the purposes described here as well. We will do this in accordance with our obligations and your rights that arise from the GDPR and the Act General Data Protection Regulation (AGDPR).

2 Our data

Hubper Ltd. Registered at the Chambre of Commerce with the number 70498717 Registered office on the Sint Annastraat 198c (6525 GX) Nijmegen.

E-mail address:

Phone number: 085 130 2698
Post address: Sint Annastraat 198c (6525 GX) Nijmegen

3 Which personal data do we process?

We process the following personal data you provided to the e-Learning environment:

Personal details:

  • Names
  • Email addresses
  • Passwords
  • Company
  • Department
  • Position


  • General functioning of the e-learning software
  • Offering helpdesk services
  • Analysing errors to improve your products and services
  • Controlling fraud, abuse or misuse of accounts
  • Developing new products

Legal grounds:

  • Processing is essential for our legitimate stakes to keep products up-to-date and working flawlessly, to develop new products and services and to ensure the trustworthiness of the products.
  • IP-address
  • URL
  • Browser type
  • Date and time of the visit

4 How long do we keep your personal details?

We do not keep your personal data any longer than necessary for the purposes for which we process your personal details (see section 3 for an overview of our process purposes). Only when we are lawfully obliged or when it is essential to represent our interests will we keep the personal data for a longer period of time.

The following retention periods apply:

Personal data – 1 month after deregistration within the e-learning system:

  • Names
  • E-mail addresses
  • Passwords
  • Company
  • Department
  • Position

5 How do we protect your personal data?

We will take the needed administrative, technical and organisational measures to guarantee a safety level that suits the specific risks we identified. We protect your personal data against destruction, loss, modification, unlawful publication of or access to personal data that are send, saved or otherwise processed.

6 Do we share or transfer your personal data?

As part of the goals listed above, we share your personal data with third parties in some situations:

  • We possibly share your e-Learning results with your employer. We will only do this when your e-learning software is facilitated by your employer. The purpose is to offer your employer insight into your progress and achieved results.
  • Under certain circumstances we are possibly obliged to share (your) personal details, for example when we are involved in a legal procedure or when we must comply with legal obligations, a court order or instructions from insurances or public authorities such as a data protection authority.
  • We possibly work together with third parties that process personal data on behalf of us (for example, providers of IT applications we use as a part of our activities). We will conclude the required process agreement with such parties in order to ensure a rightful and decent procession of personal data.
  • We possibly transfer personal data as a part of a sale or transfer of our company, when this is required on behalf of that transaction.

If relevant, we ensure when transferring your personal details to third parties for sufficient guarantee for protecting your personal data. We conclude, for example, a process agreement with relevant parties (in which limitations are listed towards the use of the personal data as well as obligations given the protection and security of your personal data).

7 Can I view my personal data?

If you want to know which personal details we have of you, you can make a request and we will provide you (if desired) a copy of them (as far as we have your details). This is called a ‘request for access’.

Such a request needs to be submitted written per e-mail or post (see article 10 for our address). In principle, we do not charge any costs for a request for access. If your request is ‘manifestly unfounded or excessive’ (for example when you unnecessarily submit a request repeatedly) we can charge a compensation for our administrative costs.

After receiving your request for access you will receive an answer within 1 month. We aim to provide you with a complete reaction within this time frame, including a copy of your personal data. In certain cases, mostly when your request is more complex, we need more time. You will receive our response within (maximum) three months, counting from the date of receival or your request. In that case, we will of course keep you updated on the progress.

8 Which other rights do you have?

Under certain circumstances you have the right:

  • To receive additional information concerning the processing of your personal data;
  • To rectify of your personal data;
  • To delete your personal data;
  • To object to (a part of) the processing of your personal data;
  • To limit (a part of) the processing of your personal data; and
  • the transferability of your you data (in other words: the right to receive your personal data in a structured, common and machine readable form and to transfer these data to another organisation).

Finally, you have got the right to submit a complaint at the Authority Personal data. Address: Bezuidenhoutseweg 30 (2594 AV) Den Haag. Phone number: 0881805250.

9 Automated decision making and profiling

We do not use automated decision making or profiling.

10 Contact details

To contact us concerning everything linked to your personal data and/or data protection, including practicing your rights as a person involved in section 7 and 8, especially your right to object, you can use the contact details below:

E-mail address:
Phone number: 085 130 2698
Post address: Arsenaalgas 8C, 6511 PE Nijmegen