Version 2026.07.24.1 — effective 24 July 2026
This Data Processing Agreement ("DPA") is part of the Terms of Service between each merchant (the controller) and the HubLane.app platform operator (the processor) and governs the processing of personal data the merchant stores in HubLane.app.
1. Subject matter and duration
We process CRM content (clients, leads, contacts, deals, activities, appointments, calls, shipments, invoices, messages, files, workflow runs, property listings, property enquiries / offers / buyer briefs, listing-agent assignments and related records) solely to provide the platform, for as long as the merchant account exists.
2. Nature and purpose
Storage, retrieval, organization, transmission (email, SMS/WhatsApp, voice and notifications the merchant triggers, including workflow automations), public publication of opted-in property listings and assigned agent contact details on HubLane Properties, map coordinate storage, backup and deletion — only on the merchant's documented instructions as expressed through the platform's features and connected integrations.
3. Categories of data subjects and data
The merchant's customers, prospects, property enquirers and staff. Typical data: names, contact details, addresses, phone numbers, communication and call history, appointment and transaction records, property listing content and photos, enquiry messages and offer amounts, map coordinates, uploaded files, and any custom fields the merchant defines. Merchants must not store special-category data unless they have a lawful basis to do so.
4. Our obligations
- Process data only as needed to provide the service; never for our own purposes.
- Ensure staff with access are bound by confidentiality.
- Apply the technical and organizational measures described in the Privacy Policy (tenant isolation, role-based access, encryption of secrets at rest, hashed credentials and API keys, audit logging).
- Assist the merchant with data-subject requests: per-record export and anonymization tools are built into the platform (client/lead export and erasure).
- Notify the merchant without undue delay after becoming aware of a personal-data breach affecting their data.
- Delete or return CRM content at contract end, subject to statutory retention duties.
- Provide temporary support access to a merchant workspace only after a Merchant Owner has approved a support request with an explicit disclosure acknowledgement for that session; refuse access if consent is denied or expires; keep each such session short-lived, attributable to the support operator in audit logs, and endable by that operator (or when the session expires).
- Limit platform-console visibility of merchant CRM financial records; platform staff may administer merchant user accounts (view team directory, reset passwords, revoke sessions, deactivate users) without that equating to access to CRM content, and must audit-log those account actions.
5. Consented support access
At the merchant's request for technical support, a platform Super Admin may open a time-limited support session inside the merchant's workspace. This is an instruction of the controller (the merchant) for that session, given through the platform's consent UI by a Merchant Owner. Without that approval, platform staff must not enter the workspace via support impersonation. Consent, session start and session end are recorded for accountability. Privacy tools that belong to the account owner remain disabled for the support operator during the session.
6. Platform account administration
Independently of support impersonation, platform staff may view the merchant's team-member directory and perform account-security actions (password reset, session revocation, deactivation/reactivation) for legitimate operational reasons. Merchants acknowledge that these capabilities exist and that team members should expect the platform operator can take those steps. This does not authorize browsing merchant CRM financial or customer records outside a consented support session.
7. Subprocessors
The merchant authorizes the use of infrastructure and delivery subprocessors required to run the service. Platform records are hosted in Albania. Depending on features the merchant enables, processing may involve:
- Hosting / infrastructure in Albania for the application database and file storage.
- Email delivery providers configured for outbound mail.
- Twilio for click-to-call, SMS and WhatsApp when the merchant configures Twilio.
- Stripe for card payments when the merchant connects Stripe.
- Google and/or Microsoft for calendar sync when a user connects those accounts.
- Map / geocoding providers (for example OpenStreetMap tile hosts, CARTO, Nominatim) when merchants or public visitors use map features or address lookup.
We remain responsible for subprocessors we engage to provide the core platform and will inform merchants of material changes. Providers a merchant or user connects remain under that party's configuration and contracts with those providers.
8. International transfers
Where a connected provider processes personal data outside Albania or the EEA, the merchant acknowledges that such processing is necessary to deliver the chosen integration and relies on that provider's transfer mechanisms (for example Standard Contractual Clauses).
9. Audits
On reasonable request we will provide information necessary to demonstrate compliance with this DPA.