Draft, not yet legally reviewed. This text is a draft and does not apply yet. Hubra and a lawyer must review it before it is published. Passages marked in yellow are assumptions that still need to be confirmed. This English version is a translation; the German version prevails.
In short
- We only process data we need to run Hubra. No ads, no analytics, no selling of data.
- The data is stored on servers in Europe (Contabo, Germany). Some service providers are in the USA; recognised safeguards apply.
- The club is responsible for the data in a club. We process it on the club's behalf.
- You can ask for access, correction, deletion and a copy of your data at any time: [email protected].
1. Who is responsible
The controller for personal data on hubra.club and for Hubra accounts is:
Mike Keller, Hubra (sole proprietorship, not entered in the commercial register)
Grossfeld 17, 6423 Seewen, Switzerland
Email: [email protected]
This policy follows the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).
Hubra has not appointed a representative in the EU.
2. Who is responsible for what
Hubra is a platform where many clubs each have their own space. So there are two roles:
- Hubra is the controller for this website, for your Hubra account (name, email, password, sign-ins, security settings), for messages you send us, for problem reports and ideas, and for contracts and invoices with clubs.
- The club is the controller for everything in its club space: member data, fees and invoices, events, attendance, votes, groups, inventory, club mail and files. Hubra processes this data only on the club's behalf, under the data processing agreement. Questions about this data are best sent to your club first.
3. Visiting this website
hubra.club is an information site. It sets no tracking cookies, uses no analytics and loads nothing from third parties. Fonts and images are served by the site itself.
The website is hosted on GitHub Pages (GitHub, Inc., USA). When you visit, GitHub processes technically necessary data such as your IP address, the time, the page and your browser, to deliver the site and protect it from attacks. The legal basis is our legitimate interest in a secure website (Art. 6(1)(f) GDPR). See GitHub's privacy statement.
If you switch the colour scheme, the site stores your choice in the hubra_theme cookie. Details on the cookies and local storage page.
4. Your Hubra account
You need an account for the Hubra app. One account works for every club you belong to.
| Data | Purpose | Legal basis |
|---|---|---|
| Name, email address, password (hash only), language, colour scheme, profile picture | Running your account, sign-in, notifications | Contract (Art. 6(1)(b) GDPR) |
| Email confirmation | Making sure the address is yours | Contract, legitimate interest |
| Passkeys (public key only), one-time code secret for two-factor sign-in (encrypted), recovery codes (hashed) | Secure sign-in | Contract, legitimate interest in security |
| Sign-ins and sessions: time, IP address, browser and operating system | Staying signed in, showing and ending sessions, a mail when you sign in from a new device, detecting abuse | Legitimate interest in security (Art. 6(1)(f) GDPR) |
| Linked accounts (e.g. Discord user ID and name) | Discord plugin features, only if you link the account yourself | Consent (Art. 6(1)(a) GDPR), can be withdrawn at any time |
| Your browser's push subscription | Reminders as push notifications, only if you switch them on | Consent, can be withdrawn at any time |
| Settings for notifications, sidebar and appearance | Showing Hubra the way you set it up | Contract |
5. Data in a club
The club decides what it stores in Hubra. Typical data is membership (tier, join date, offices, groups), contact details and address, date of birth (e.g. for J+S), fees, invoices and payments, sign-ups and attendance, votes, checkouts, keys and door codes, posts and comments, and mail in club mailboxes.
We process this data only to run Hubra for the club: storing, backing up, showing it, and sending mails and reminders. We don't analyse it for our own purposes. When a member is deleted permanently, their poll votes stay without a name so results remain correct.
Hubra staff only see club data when support or operations need it. Support access needs a reason, is time-limited, is logged and shows as a banner in the club.
6. Emails and notifications
Hubra sends mails for sign-in (confirmation, password reset, new devices), for the club (invites, invoices, reminders, announcements) and for operations. You choose which club notifications you get in your account. Our mails contain no tracking pixels.
We use a mail service provider (see service providers). It sees sender, recipient, subject and content as far as needed for delivery.
7. Contact, problem reports and ideas
When you write to us or report a problem or suggest an idea in the app, we use what you send to reply and to improve Hubra. Before you send a problem report, the app shows you which technical details (e.g. browser, screen size, app version) go with it. Ideas we show on the public roadmap appear without your name.
8. Clubs as customers
When a club requests or uses Hubra, we process the club's name and address and the names and contact details of its contact people to conclude the contract and invoice. We keep accounting records for ten years, as Swiss law requires (Art. 958f CO). We use Stripe for billing (see service providers). Card details go straight to Stripe; we only see the last four digits and the expiry date.
9. Service providers and recipients
We only share personal data with service providers we need to run Hubra, and only as much as necessary. We have data processing agreements with all of them or have accepted their standard terms for it.
| Provider | What for | Data location |
|---|---|---|
| Contabo GmbH, Munich, Germany | Servers for the Hubra app and encrypted backups (object storage) | Germany |
| Stripe Payments Europe, Ltd., Dublin, Ireland | Billing and payments from clubs to Hubra, once Hubra charges clubs. Concerns only clubs and their contact people, no member data. | EU, USA |
| Infomaniak Network SA, Geneva, Switzerland | Sending mail | Switzerland |
| Brevo SAS, Paris, France | Backup mail sending, only when the main service fails | EU |
| GitHub, Inc., USA | Hosting this website and the plugin marketplace (plugins.hubra.club) | USA |
| Discord Inc., USA | Only if a club uses the Discord plugin: announcements, roles and direct messages; the Discord ID for linked accounts | USA |
| Your browser's push service (Google, Apple, Mozilla, Microsoft) | Only if you switch on push notifications: delivering the encrypted message | depends on the browser, including the USA |
Otherwise we only share club members' data when the club arranges it (e.g. a plugin it installs or a mailbox it connects) or when the law requires it.
10. Transfers abroad
Some providers are based in the USA or process data there. We only transfer data to the USA to companies certified under the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework, or on the basis of the European Commission's standard contractual clauses as recognised by the Swiss Federal Data Protection and Information Commissioner (FDPIC). Check the providers' certification before publishing.
11. Security
We protect your data with technical and organisational measures, including:
- encrypted connections (HTTPS) everywhere;
- separate data spaces per club and a separate key per club for confidential fields;
- daily backups, encrypted before they leave the server;
- passwords stored only as hashes, passkeys and two-factor sign-in, required two-factor sign-in for Hubra staff;
- roles and permissions in the club and a log of changes;
- support access only with a reason, time-limited and visible to the club.
The full list is in the annex to the data processing agreement. Please report security issues as described in security.txt.
12. How long we keep data
| Data | How long |
|---|---|
| Hubra account | Until you have it deleted. Accounts that were never confirmed are deleted after 30 days. |
| Ended sessions (IP address, device) | 90 days after the session ends |
| Known devices for the new sign-in mail | Until you remove the device in your account or delete the account |
| Platform event log (sent and failed mails, outages) | 30 days |
| Server log files (requests) | 14 days |
| Data in a club | As long as the club needs it. The club decides when members and entries are deleted. After the contract ends we delete the club space within 30 days. |
| Backups | Daily, weekly and monthly, rotating. The oldest backup is at most six months old. Deleted data is gone from backups by then at the latest. |
| Messages, problem reports and ideas | Until resolved, then at most two years |
| Contracts and accounting records with clubs | Ten years (Art. 958f CO) |
Deleting your account
Write to [email protected] from your account's address and we delete it within 30 days. A self-service delete button in the account is planned. Your club memberships end with it. Anything a club must keep by law (e.g. invoices) stays with the club, without a link to your account.
Leaving a club
You can leave a club in your account. What happens to your data in the club afterwards is up to the club, within its own retention duties.
13. Your rights
You have the right to
- access your data (Art. 25 FADP, Art. 15 GDPR);
- have wrong data corrected (Art. 32 FADP, Art. 16 GDPR);
- have your data deleted (Art. 32 FADP, Art. 17 GDPR) unless we must keep it;
- restrict processing (Art. 18 GDPR);
- receive your data in a common format (Art. 28 FADP, Art. 20 GDPR);
- object to processing based on our legitimate interest (Art. 21 GDPR);
- withdraw consent at any time, e.g. for push notifications or a linked Discord account.
Write to [email protected]. We reply within 30 days. If your request is about data in a club, we pass it on to the club and help it answer.
You can also complain to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in the EU the authority where you live.
14. Children and young people
Many clubs have young members. Young people can open their own Hubra account from age 16, younger ones with their parents' consent. The club is responsible for children's data in the club.
15. No automated decisions
Hubra makes no decisions based solely on automated processing that significantly affect you. Only processes the club sets up run automatically, e.g. a payment reminder after the due date.
16. Changes
We update this policy when Hubra or the law changes. The version on this page applies. We tell account holders about significant changes by mail or in the app.