1. European Economic Area, United Kingdom, and Switzerland
Under the EU GDPR, UK GDPR, and Swiss FADP you have rights of access, rectification, erasure (subject to the journalistic and public-interest exemption under Article 85 GDPR and equivalents), restriction of processing, objection, portability, and withdrawal of consent. Automated decision-making producing legal or similarly significant effects is subject to Article 22 safeguards, including the right to obtain meaningful information about the logic involved and to request human review; every HOD Report passes through mandatory manual Back Office review prior to publication.
EU Representative (GDPR Article 27): to be identified in your account and in every response to an EU data-subject request. UK Representative (UK GDPR Article 27): to be identified in your account and in every response to a UK data-subject request. Swiss FADP Representative: identified on request.
Transfer mechanism: EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), the UK International Data Transfer Addendum, and the Swiss FADP addendum, supplemented by technical and organizational measures documented in a transfer impact assessment.
Complaints: you may lodge a complaint with your local supervisory authority, including the Information Commissioner’s Office (UK), CNIL (France), BfDI (Germany), Garante (Italy), AEPD (Spain), Datatilsynet (Denmark, Norway), IMY (Sweden), or the FDPIC (Switzerland).
2. United Kingdom consumer credit and reference agencies
Where an HOD Report is furnished to a UK credit provider or is used as part of a credit reference activity, we align with the Information Commissioner’s Office guidance for credit reference agencies and the Financial Conduct Authority CONC sourcebook where applicable. Data subjects may request a copy of their file and challenge inaccurate information at no cost.
3. Canada
The Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec Law 25, Alberta PIPA, and British Columbia PIPA govern the collection, use, and disclosure of personal information in Canada. You may access your personal information, request corrections, and complain to the Office of the Privacy Commissioner of Canada, the Commission d’accès à l’information du Québec, or the applicable provincial commissioner. Under provincial consumer reporting statutes (including Ontario’s Consumer Reporting Act), we honor free file access, dispute, and correction rights.
4. Brazil
Under the LGPD you may request confirmation of processing, access, correction, anonymization, blocking, portability, deletion (subject to legal retention obligations), and information about sharing. Our Data Protection Officer for Brazil can be reached at dpo-br@hubordub.com. Complaints may be lodged with the Autoridade Nacional de Proteção de Dados (ANPD). Where the LGPD Cadastro Positivo framework applies, we align with Law 12.414/2011 as amended.
5. Australia
The Privacy Act 1988 (Cth) and the Australian Privacy Principles govern our processing in Australia. Where an HOD Report is used for credit reporting under Part IIIA of the Privacy Act, we align with the Privacy (Credit Reporting) Code 2014. Complaints may be lodged with the Office of the Australian Information Commissioner (OAIC).
6. Japan
The Act on the Protection of Personal Information (APPI) governs our processing in Japan. You may request disclosure, correction, addition, deletion, suspension of use, or suspension of third-party provision through privacy-jp@hubordub.com. Complaints may be lodged with the Personal Information Protection Commission (PPC).
7. South Korea
The Personal Information Protection Act (PIPA) governs our processing in the Republic of Korea. You may exercise access, correction, deletion, and objection rights and complain to the Personal Information Protection Commission (PIPC) or the KISA Personal Information Infringement Report Center.
8. Singapore
The Personal Data Protection Act 2012 (PDPA) governs our processing in Singapore. Complaints may be lodged with the Personal Data Protection Commission (PDPC). Our Data Protection Officer for Singapore can be reached at dpo-sg@hubordub.com.
9. South Africa
The Protection of Personal Information Act (POPIA) governs our processing in South Africa. Complaints may be lodged with the Information Regulator. Our Information Officer can be reached at info-officer@hubordub.com.
10. India
The Digital Personal Data Protection Act, 2023 (DPDP Act) governs our processing in India as the framework comes into force. You may exercise access, correction, and grievance-redress rights and complain to the Data Protection Board of India.
11. Mexico and Latin America
The Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP) and comparable statutes in other Latin American jurisdictions (Argentina, Chile, Colombia, Peru, Uruguay) govern our processing in those countries. You may exercise ARCO rights (acceso, rectificación, cancelación, oposición) and complain to the applicable national data-protection authority.
12. Middle East and Africa
Where the UAE Personal Data Protection Law, the DIFC Data Protection Law, the ADGM Data Protection Regulations, the Saudi Personal Data Protection Law, the Turkish KVKK, the Nigerian NDPA, or comparable statutes apply, we honor the substantive rights granted by local law and identify the appropriate representative or contact in each response.
13. Cross-border transfer mechanisms
We rely on adequacy decisions where available (including EU adequacy for the UK, Switzerland, Israel, Japan, Republic of Korea, and others), and otherwise on EU Standard Contractual Clauses, the UK International Data Transfer Addendum, the Swiss FADP addendum, ANPD-approved LGPD transfer instruments, PDPA cross-border transfer contracts, and comparable mechanisms, supplemented by transfer impact assessments and additional technical and organizational measures.
14. Language and translations
This page and other legal materials are published in English. Where a translation is provided, the English version prevails in the event of a discrepancy, unless local mandatory law provides otherwise.
15. Contact
International privacy inquiries: privacy@hubordub.com. Specific representative addresses are identified in each jurisdiction’s response.