Data Processing Addendum
Last Updated: February 1st, 2025
This Data Processing Addendum ("Addendum") forms part of the Terms of Service between HubCreate ("Processor") and the Customer ("Controller"). This Addendum applies where HubCreate processes Personal Data on behalf of the Customer in the course of providing the HubCreate services.
1. Nature of Processing
HubCreate provides a platform for HubSpot portal management and asset deployment. Our processing activities include:
- Subject Matter: Facilitating HubSpot API interactions and portal configuration.
- Duration: For the duration of the Customer’s subscription.
- Purpose: To allow Customers to deploy assets and audit connected HubSpot portals.
2. Data Minimization & Stored Data
HubCreate is designed to minimize the collection of Personal Data. We categorize data as follows:
- Persistent Data: We store only administrative data (Name, Email, Company Name) and encrypted OAuth credentials (Tokens) for connected HubSpot portals.
- Ephemeral Audit Data: During portal audits, HubCreate retrieves aggregate statistical metadata (e.g., counts of empty properties). This data is processed in-memory only and is not persisted or cached in our database.
- Explicit Exclusions: HubCreate does not ingest, sync, or store PII from the Customer’s end-clients (e.g., Contact names, email addresses, or phone numbers within the CRM).
3. Technical Security Measures
- Encryption: All OAuth tokens are encrypted at rest using AES-256 and in transit via TLS 1.2+.
- Isolation: Processing is performed in isolated environments to ensure data integrity.
- Confidentiality: Only authorized personnel with a documented "need-to-know" can access technical systems.
4. Sub-processors
Customer agrees that HubCreate may use the following sub-processors to facilitate the service:
| Sub-processor | Purpose | Location |
|---|---|---|
| Cloud Infrastructure Provider | Hosting and Database Services | United States / EU |
| Postmark / SendGrid | Transactional Email Delivery | United States |
| Stripe | Payment Processing | United States |
5. Data Subject Rights
Since HubCreate does not store end-client PII, any requests regarding CRM record access or deletion should be handled within the Customer’s HubSpot portal. HubCreate will assist Customers in managing the data of their own administrative users upon request.
6. Contact Information
For inquiries regarding data processing, please contact: info@hubcreate.io
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