Privacy Policy

Last updated: 30th of June2026

UPSKILLHUBS LIMITED, trading as Uhubs (“Uhubs”, “we”, “our” or “us”), is committed to protecting your privacy and handling personal data responsibly, securely and transparently.

This Privacy Policy explains how we collect, use, store, share and protect personal data when individuals use the Uhubs platform, visit our website, participate in assessments, access analytics, receive AI-generated insights, or otherwise engage with our services.

Uhubs provides workforce capability, performance and behavioural intelligence solutions designed to help organisation sunderstand skills, performance drivers, coaching opportunities, development needs and capability gaps across teams.

UPSKILLHUBS LIMITED is registered in England and Wales under company number 11869565.

Our registered office is:

4th Floor, Silverstream House
45 Fitzroy Street
London
W1T 6EB
United Kingdom

For the purposes of UK data protection law, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Uhubs acts as either a Data Controller or Data Processor depending on the context in which personal data is processed.

If you have any questions about this Privacy Policy or our data practices, please contact:

Privacy Team
UPSKILLHUBS LIMITED trading as Uhubs
Email: support@uhubs.ai
Website: www.uhubs.ai

1. Data Controller and Data Processor Roles

Uhubs acts in different capacities depending on the nature of the processing.

1.1 Customer Platform Data

When organisations use Uhubs to conduct assessments, manager reviews, peer reviews, benchmarking, performance analytics, coaching programmes, AI-generated insights or workforce capability initiatives, the customer organisation acts as the Data Controller and Uhubs acts as a Data Processor.

In these circumstances, Uhubs processes personal data only in accordance with the customer’s instructions and the applicable contractual agreements, including any Data Processing Agreement.

Where Uhubs acts as a Data Processor, it processes personal data strictly on the documented instructions of the customer and does not determine the purposes of that processing. Uhubs ’processor commitments - including restrictions on the use of AI, on benchmarking and on international transfers - are set out in the applicable Data Processing Agreement.

Questions regarding employee data, assessment results, manager reviews, peer reviews, performance data, CRM data, call intelligence data or workforce analytics should generally be directed tothe relevant employer or customer organisation.

1.2 Uhubs Business Operations

Uhubs acts as a Data Controller inrelation to personal data processed for its own business purposes, including:

●   Website visitors

●    Sales enquiries

●    Marketing communications

●    Customer relationship management

●    Customer support

●    Supplier management

●     Recruitment

●     Business administration

●     Security and compliance

2. Information We Collect

Depending on how our services are used, we may collect and process the following categories of personal data.

2.1 Identity and Account Information

This may include:

●   Name

●   Business email address

●   Job title

●   Employer

●   Department

●  Team

●   Manager or reporting line information

●   User role and permissions

●   Login and authentication information

2.2 Assessment and Review Data

This may include:

●      Self-assessment responses

●      Manager review responses

●      Peer review responses

●      Coaching and development inputs

●      Skills and competency scores

●      Capability ratings

●      Blindspot analysis

●      Development priorities

●      User comments and free-text responses

2.3 Performance and Operational Data

Where provided by a customer orconnected system, this may include:

●      Quota attainment

●      Revenue performance

●      Sales performance metrics

●      Pipeline metrics

●      Forecasting metrics

●      CRM activity data

●      Customer success metrics

●      Account management metrics

●      Productivity and activity indicators

2.4 CRM and Business Systems Data

Where enabled by a customer, Uhubs may connect with customer systems, including:

●      Salesforce

●      Microsoft Dynamics

●      HubSpot

●      Other CRM or business systems connected through customer-approved APIs

The data processed will depend on the configuration agreed with the customer.

2.5 Communication and Call Intelligence Data

Where enabled by a customer, Uhubs may process information obtained from third-party communication, meeting orconversation intelligence platforms through customer-approved APIs.

This may include:

●      Call transcripts

●      Meeting summaries

●      Conversation analytics

●      Coaching observations

●      Communication patterns

●      Call-related performance indicators

●      Sales methodology or process indicators

2.6 Benchmarking Data

Uhubs may create aggregated, anonymised or de-identified benchmark datasets to provide comparative insights by:

●      Industry

●      Geography

●      Company size

●      Function

●      Role type

●      Performance cohort

●      Capability area

●      Seniority level

●      Sales motion

Where benchmarking is produced, Uhubs aims to ensure that individuals are not directly identifiable from aggregated benchmark outputs.

2.7 Technical and Usage Data

This may include:

●      IP address

●      Browser type

●      Device information

●      Operating system

●      Usage logs

●      Session activity

●      Authentication events

●      Platform interaction data

●      Error logs

●      Security logs

2.8 AI Processing Data

Where AI-powered features are enabled, we may process information submitted to generate summaries, recommendations, coaching suggestions, analytical outputs, reports and insights.

This may include assessment data, review data, CRM data, call intelligence data, platform usage data and other customer-approved inputs.

2.9 Special Category Data

Uhubs does not intentionally requireor request special category data, such as health information, racial or ethnicorigin, political opinions, religious beliefs, trade union membership, biometric data or sexual orientation, as part of standard platform use.

Customers and users should not submit special category data into Uhubs unless there is a lawful basis for doing so and this has been agreed with Uhubs in writing where required.

If special category data is includedin free-text fields, call transcripts, CRM notes or other customer-provided sources, Uhubs will process that information only in accordance with thecustomer’s instructions and applicable data protection requirements.

3. How We Collect Personal Data

We may collect personal data from:

●      Individuals who use the Uhubs platform

●      Customer organisations

●      Employers or sponsoring organisations

●      Managers and colleagues participating in reviews

●      CRM systems connected bycustomers

●      Call intelligence or communication platforms connected by customers

●      Website forms

●      Sales and marketing interactions

●      Customer support communications

●      Authentication providers

●      Analytics and security tools

4. How We Use Personal Data

Uhubs processes personal data for the following purposes.

4.1 Platform Delivery

We use personal data to:

●      Provide access to the Uhubs platform

●      Manage user accounts

●      Authenticate users

●      Configure user permissions

●      Deliver reports, dashboards and analytics

●      Provide customer support

●      Maintain platform performance

4.2 Assessments and Reviews

We use personal data to:

●      Deliver capability assessments

●      Process self-assessments

●      Process manager reviews

●      Process peer reviews

●      Generate capability scores

●      Identify strengths and development areas

●      Support coaching and development initiatives

4.3 Performance Analytics

We use personal data to:

●      Analyse performance data

●      Identify capability gaps

●      Compare performance against skills and behaviours

●      Support sales effectiveness initiatives

●      Support customer success and account management development

●      Provide trend analysis

●      Help organisations understand performance drivers

4.4 AI-Powered Features

Where enabled by customers, Uhubs mayuse AI technologies to:

●      Generate summaries

●      Produce coaching recommendations

●      Identify patterns and trends

●      Generate capability insights

●      Support reporting and analysis

●      Assist users in interpreting platform data

●      Suggest development actions

Capability and competency scores are calculated by the Uhubs platform using defined algorithms, not generated by artificial intelligence. Where AI is used, it draws on those calculated scores to produce insights, summaries and recommendations; it does not produce the scores themselves.

4.5 Benchmarking and Product Improvement

We may use aggregated, anonymised or de-identified information to:

●      Improve our products andservices

●      Improve our assessment frameworks

●      Develop benchmark datasets

●      Produce industry insights

●      Analyse platform effectiveness

●      Improve reporting and analytics

Product improvement, benchmarking andindustry-insight activities use aggregated, anonymised or de-identified information that does not identify any individual or customer. Uhubs does not use identifiable customer personal data, call transcripts, CRM exports, pricing information, negotiation content or roleplay content to train, fine-tune or otherwise improve any foundational, shared or third-party AI model, nor todevelop or improve Uhubs’ products. Such identifiable information is not usedin marketing or case-study materials except with the customer’s prior written consent.

4.6 Security and Compliance

We use personal data to:

●      Maintain platform security

●      Detect and prevent misuse

●      Monitor authentication events

●      Investigate security incidents

●      Comply with legal obligations

●      Protect customer data

●      Enforce contractual rights

4.7 Sales, Marketing and Business Communications

Where Uhubs acts as Data Controller, we may use personal data to:

●      Respond to enquiries

●      Manage customer relationships

●      Send relevant business communications

●      Provide product updates

●      Share marketing communications where permitted by law

●      Manage events, webinars and customer communications

5. Legal Bases for Processing

Where Uhubs acts as a Data Controller, we process personal data under one or more lawful bases.

Processing Activity

Providing access to Uhubs services

Managing customer relationships

Customer support

Website administration

Security monitoring

Product improvement

Business analytics

Marketing communications

Recruitment activities

Legal and regulatory obligations

Establishing, exercising or defending  legal claims

LawfulBasis

Contract

Contract

Contract

Legitimate interests

Legitimate interests

Legitimate interests

Legitimate interests

Consent and/or legitimate interests

Legitimate interests

Legal obligation

Legitimate interests and/or legal obligation

Where Uhubs acts as a Data Processoron behalf of customer organisations, processing is carried out in accordance with customer instructions and applicable contractual agreements.

The customer organisation is responsible for identifying and communicating the appropriate lawful basis for processing employee, worker, contractor, manager, CRM, call intelligence, performance or assessment data submitted to Uhubs.

6. Workforce Assessment, Profiling and Benchmarking

Uhubs provides workforce capability, behavioural and performance intelligence services.

Our services may involve:

●      Capability assessments

●      Self-assessments

●      Manager reviews

●      Peer reviews

●      Performance analysis

●      Benchmarking

●      Trend identification

●      AI-generated recommendations

●      Skills and competency scoring

●      Blindspot analysis

●      Coaching recommendations

These activities may constitute profiling under applicable data protection laws.

Where Uhubs acts as a Data Processor, any profiling is carried out only on the customer’s documented instructions. The customer remains responsible for identifying the lawful basis for the profilingand for obtaining any consent or providing any notice required under applicable law.

Profiling is used to generateinsights, identify strengths and development opportunities, support coaching activities, provide benchmarking information and help organisations understand capability and performance trends.

Benchmarking outputs are generatedusing aggregated, anonymised or de-identified datasets and are designed to provide comparative insights across industries, functions, regions, role typesand performance cohorts.

Cross-company benchmarking operatesonly on aggregated and anonymised competency and capability scores. The underlying raw inputs a customer provides - including call transcripts, CRM exports, pricing data, negotiation scripts and roleplay content - remain within that customer’s own instance, are used solely to generate that customer’s own coaching and development outputs, and are never pooled with, compared against, or made visible across other customer accounts.

Uhubs does not recommend that assessment scores, benchmark results, profiling outputs or AI-generated outputsare used as the sole basis for employment, promotion, compensation, disciplinary or termination decisions.

Customers are responsible for ensuring that their use of Uhubs insights complies with applicable employment, privacy and data protection laws.

7. AI-Powered Features and Automated Analysis

Uhubs may use artificial intelligence technologies to support analysis, reporting, coaching recommendations, summarisation and insight generation.

AI-powered functionality may be usedto:

●      Analyse assessment data

●      Generate coachin grecommendations

●      Identify patterns and trends

●      Produce summaries and reports

●      Support benchmarking and workforce analytics

●      Assist users in interpreting platform data

●      Support development planning

Uhubs currently uses third-party AIproviders, including Anthropic, to deliver certain AI-enabled functionality.

AI-generated outputs are intended tosupport human decision-making and should not be relied upon as the sole basisfor employment, promotion, compensation, disciplinary or termination decisions.

AI outputs may contain inaccuracies, omissions or recommendations that require human review and validation.

Where Uhubs acts as a Data Processorfor a customer, the following safe guards apply to AI processing of that customer’s personal data and confidential information: (a) the data is notentered into any public or consumer AI service (such as the public versions of ChatGPT, Gemini or Claude); (b) the data is not used to train, fine-tune, retrain or otherwise develop or improve any foundational, shared or third-partyAI model; and (c) AI processing is carried out only through secured, enterprise-grade interfaces operating under terms that provide for zero retention of the data for model-training purposes. Details of AI subprocessors and the applicable safeguards are set out in Uhubs’ subprocessor informationand the applicable Data Processing Agreement.

Uhubs implements governance, securityand contractual safeguards designed to support the responsible use of AItechnologies.

8. Sharing Personal Data

Uhubs may share personal data with the following categories of recipients.

Uhubs does not sell personal data. Where Uhubs acts as a Data Processor, it shares customer personal data only with the sub-processors approved under the applicable Data Processing Agreement, as the customer otherwise instructs in writing, or as required by law.

8.1 Customer Organisations

Assessment participants, employees, contractors, managers and users may have their information made available to their employer or sponsoring or ganisation in accordance with the services being provided.

This may include assessment results, review outputs, dashboards, reports, AI-generated insights, benchmarking outputs and performance analytics.

8.2 Service Providers and Subprocessors

Uhubs engages trusted third-party service providers to support the operation, delivery, security and administration of its services. Depending on the services used and the customer’s configuration, personal data may be processed by the following categories of providers:

  • Cloud hosting, database and infrastructure providers
  • Authentication and identity management providers
  • Artificial intelligence service providers
  • Analytics, logging and performance-monitoring providers
  • Customer support and communication providers
  • CRM and business systems providers
  • Security, compliance and incident-management providers
  • Other professional and operational service providers necessary to support the Uhubs platform and business operations

Uhubs requires its service providers to process personal data only for the purposes for which they have been engaged and subject to appropriate contractual, confidentiality, security and data protection obligations. Where Uhubs acts as a Data Processor, customer personal data is shared only with authorised subprocessors in accordance with the applicable Data Processing Agreement, the customer’s documented instructions, or as required by law.

8.3 Integrated Customer Systems

Where customers connect third-party systems to Uhubs, such as CRM platforms, call intelligence tools or communication platforms, data may flow between Uhubs and those systems inaccordance with the customer’s configuration and instructions.

8.4 Legal and Regulatory Authorities

Uhubs may disclose personal data where required by law, regulation, court order, lawful governmental request or toestablish, exercise or defend legal claims.

8.5 Corporate Transactions

If Uhubs undergoes a merger, acquisition, restructuring, financing, investment transaction or sale ofassets, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

Where personal data is processed on behalf of a customer, that data remains subject to the applicable Data Processing Agreement, which continues to govern the data for as long as Uhubs holds it.

Provider
Purpose
Location / Notes
Supabase
Database and platform infrastructure
United States
Auth0
Authentication and identity management
European Union
Anthropic
AI processing and AI-enabled features
May involve international processing
Salesforce
Customer CRM integration where enabled
Customer-controlled integration
Microsoft Dynamics
Customer CRM integration where enabled
Customer-controlled integration
HubSpot
Customer CRM integration and/or business systems where enabled
Customer-controlled or Uhubs business use depending on context
Call intelligence platforms
Call transcript and conversation intelligence processing where enabled
Customer-controlled integration

9. International Data Transfers

Uhubs may process personal data incountries outside the United Kingdom.

This may occur where our hostingproviders, infrastructure providers, authentication providers, analytics providers, AI providers, CRM providers, communication providers or service partners operate internationally.

For example, Uhubs currently uses Supabase infrastructure in the United States and Auth0 authentication servicesin the European Union. Certain AI, infrastructure or software providers mayalso involve processing outside the United Kingdom.

Where personal data is transferred internationally, Uhubs implements appropriate safeguards designed to protect personal data and comply with applicable data protection laws.

These safeguards may include:

●      UK International Data Transfer Agreements

●      UK Addendums to Standard Contractual Clauses

●      Adequacy regulations recognisedunder UK law

●      Contractual safeguards

●      Technical and organisational security measures

●      Transfer risk assessments where required

Customers with specific data residency requirements may contact Uhubs to discuss UK or EU hosting options where available. Uhubs may be able to host or migrate customer data to UK or EU infrastructure where this is agreed contractually and technically feasible.

10. Data Retention

Uhubs retains personal data only foras long as necessary to fulfil the purposes for which it was collected, perform contractual obligations, comply with legal requirements and protect interests.

Unless otherwise agreed with acustomer in writing:

Data Category
Retention Period
Customer platform data
Duration of the customer contract
Former customer platform data
Returned or deleted within the period set by the applicable Data Processing Agreement (30 days where it so provides); otherwise up to 12 months
Customer support records
Up to 24 months
Website enquiry records
Up to 36 months
Marketing records
Until consent is withdrawn, an objection is received, or the information is no longer required
Security and audit logs
Up to 24 months
Recruitment records
Up to 12 months unless a longer period is required or agreed

Upon expiry of the applicable retentionperiod, personal data will be securely deleted, anonymised or de-identifiedunless continued retention is required by law, contractual obligation or alegitimate business purpose consistent with the original reason for processing.

Customers may request earlier deletion of customer platform data, subject to contractual terms, legal obligations and technical feasibility.

Where customer platform data is processed under a Data Processing Agreement, the deletion or return timeframeset out in that Agreement applies. On termination or expiry, Uhubs will delete or return that data within the period specified in the Data Processing Agreement and will provide a written certificate of destruction.

Where customer data contributes to benchmarking, industry insights or statistical analysis, Uhubs may retainag gregated, anonymised or de-identified information that no longer identifies individuals or organisations.

Such anonymised datasets may beretained indefinitely for research, benchmarking, product improvement and analytical purposes.

11. Security

Uhubs maintains technical, organisational and administrative measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.

Security measures may include:

●      Encryption in transit

●      Access controls

●      Authentication controls

●      Role-based permissions

●      Audit logging

●      Security monitoring

●      Secure development practices

●      Vendor risk assessments

●      Data minimisation controls

●      Internal access restrictions

●      Incident response procedures

●      Encryption of personal data intransit and at rest

●      Multi-factor authentication oncritical systems

●      Pseudonymisation or anonymisation of data where appropriate

●      Third-party penetration testing

●      A designated data protectionlead responsible for data protection matters

Uhubs’ information security anddata-governance controls are documented in its Trust Center and are designedand maintained in alignment with the Cloud Security Alliance CAIQ (v4.0.3) andthe SOC 2 criteria. These controls are reviewed at least annually. Where Uhubs acts as a Data Processor, it will notify the relevant customer without unduedelay, and in any event within 72 hours of becoming aware, of any personal databreach affecting that customer’s data. Independent security documentation, including third-party penetration-test reports, can be made available to customers on request.

No system can guarantee absolute security. However, Uhubs continually reviews and improves its security controls.

Customers are responsible for managing their own user access, permissions, connected systems and internal use of Uhubs outputs.

12. Data Subject Rights

Where Uhubs acts as a Data Controller, individuals may have the following rights under applicable data protection laws:

●      Right of access

●      Right to rectification

●      Right to erasure

●      Right to restrict processing

●      Right to object

●      Right to data portability

●      Rights relating to automated decision-making and profiling

●      Right to withdraw consent where processing is based on consent

Requests can be submitted to:

support@uhubs.ai

We will normally respond within one calendar month. We may request additional information to verify identity before responding.

This includes the right to request acopy of the personal data Uhubs holds about you and the right to request its deletion.

Where Uhubs acts solely as a Data Processor on behalf of a customer organisation, requests relating to work force assessments, employee data, customer programme data, CRM data, call intelligence data, performance analytics or platform outputs should generallybe directed to the relevant employer or customer organisation.

If we receive such a request directly, we may refer the request to the relevant customer organisation where appropriate.

13. Cookies and Website Technologies

Uhubs may use cookies and similar technologies to:

●      Operate the website

●      Improve website performance

●      Understand website usage

●      Enhance user experience

●      Support security and authentication

●      Analyse marketing effectiveness

Users can manage cookie preferences through browser settings and any cookie management tools provided on ourwebsite.

Where required by law, we will requestconsent before placing non-essential cookies.

14. Marketing Communications

Where permitted by law, Uhubs may send marketing communications to business contacts, customers, prospects orindividuals who have expressed interest in our services.

Marketing communications may include:

●      Product updates

●      Event invitations

●      Research insights

●      Benchmark reports

●      Thought leadership

●      Commercial information about Uhubs services

Individuals can opt out of marketing communications at any time by using the unsubscribe link in our emails or bycontacting support@uhubs.ai.

We may continue to sendservice-related or contractual communications where necessary.

15. SMS / Text MessageCommunications

If you provide your mobile number and optin to receive SMS messages from Uhubs (Upskillhubs Limited), we use your numberonly to send the messages you requested (for example, consultation, webinar andevent reminders). We do not sell, share, or transfer mobile numbers or SMSopt-in consent to any third parties or affiliates for marketing or promotional purposes. Mobile information is shared only with service providers that help usdeliver these messages, and otherwise only as required by law, in connection with a business merger or acquisition, or with your consent. You can opt out atany time by replying STOP.

 

16. Children’s Privacy

Uhubs services are designed for business and professional users and are not intended for individuals under theage of 18.

We do not knowingly collect personaldata from children.

17. Links to Third-Party Websites

Our website or platform may contain links to third-party websites, applications or services.

Uhubs is not responsible for the privacy practices, content or security of third-party websites or services. Users should review the privacy policies of those third parties before providing personal data.

18. Changes to This Privacy Policy

Uhubs may update this Privacy Policyfrom time to time to reflect changes in legal requirements, technology, products, services, suppliers or business practices.

Updated versions will be published onour website with a revised effective date.

Material changes may be communicatedto customers or users where appropriate.

19. Contact Us

If you have any questions about this Privacy Policy or our handling of personal data, please contact:

Privacy Team
UPSKILLHUBS LIMITED trading as Uhubs
4th Floor, Silverstream House
45 Fitzroy Street
London
W1T 6EB
United Kingdom

Company Registration Number: 11869565
Email: support@uhubs.ai
Website: www.uhubs.ai

You also have the right to lodge acomplaint with the UK Information Commissioner’s Office if you believe your personal data has been processed unlawfully.

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