Privacy Policy
Hubly Inc ("Hubly"/"we"/"us"/"our") provides the website www.myhubly.com (the "Website") available together with certain services that may be accessed through the Website (“Services”) and any mobile application (if any) that we may make available from time to time (“App”). As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.
Our Privacy Policy explains:
- What information we collect and why we collect it.
- How we use that information and when we disclose it.
- How to access and update your personal information.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on 29 August, 2019.
We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website and the last revision date of revision will be updated so that you will always be able to understand what information we collect, how we use your information, and under what circumstances we may share your information with others. We may also email you those revisions if we solely have your contact details through information that you submitted through the App.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Third-party Links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
2. THE INFORMATION WE COLLECT
Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
We may collect, use, store and transfer different kinds of personal information about users of our Website, Services and app, (together with any information which they enter through the Services regarding their end users) which we have grouped together follows:
- Identity Data includes first name, last name, address and number or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Usage Data includes information about how you use our Website, app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our application or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website app(s) and the webpage, app(s) you go to next
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the Services or any other contract we have or are trying to enter into with you (for example, to provide you with our services).
- Direct interactions. You may give us your Identity and Data by filling in forms or by corresponding with us by post, phone, email or otherwise, or where you enable our Services to interact with any other electronic data, software or services. This includes personal data you provide when you :
- submit a query through the App;
- enable any integration between our Services and any other third party services;
- sign up for a demo of our services;
- create an account and profile with us;
- purchase one of services;
- subscribe to our email alerts;
- complete one of our online forms to receive our reports and case studies;
- download or otherwise access one of our e-books, magazines, videos;
- contact our customer service;
- request marketing to be sent to you; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our Website, Services and/or App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies. Our API and third party integrations also allow us to collect all personal information from any third party services that you select for such integration.
- We will provide your Contact Data and Identity Data to the applicable management company or
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We may have to share your personal information with the parties set out below.
- Third Party categories as set out below:
- Service Providers who provide hosting, network, system administration and other services that assist us in providing the Website, the App (if any) and the Services. These include:
- AWS®: We host the website and operate the platform using third parties. Our website will be hosted from their data centers throughout the United States, based on where you visit our website from.
- Stripe® and Chargebee: We use their services to process subscription payments, and therefore provide them with the personal data required to charge your credit card.
- Fullstory Analytics: We may use this tracking cookie to track and visualize page interactions and user sessions to help improve the overall user experience and layout in the future.
- We use third-party service providers and platforms (such as Pendo, Customer.io, Zapier, and Zendesk) for customer engagement, customer chat, product feedback and customer support ticketing.
- Analytics, advertising and marketing service providers, including without limitation Google Analytics (and to see how Google uses data when you use our partners' sites or apps" please see the site located at www.google.com/policies/privacy/partners/), and such other service providers as we may notify to you through this policy from time to time.
- Google Analytics: This cookie allows us to see information on user website activities including, but not limited to page views, source, and time spent on the website. This will help to protect your privacy. Using Google Analytics, we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching (and to see how Google uses data, read more at www.google.com/policies/privacy/partners/)
- Google AdWords: Using Google AdWords code, we are able to see which pages helped lead to form submissions. This allows us to make better use of our paid search budget. We also use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future. Read more about it here: http://www.google.com/policies/technologies/ads/
- Hubspot: This cookie allows us to gather demographic information about visitors to our website. HubSpot keeps track of the websites and pages you visit within Hubly. This data is used to deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.
- Social networking sites.
- Facebook: We use retargeting codes (pixel) to log when users view specific pages, allowing us to provide targeted advertising in the future and deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.
- LinkedIn: We use retargeting codes, cookies or similar technologies, to log when users view specific pages, allowing us to provide targeted advertising in the future and deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.
- Professional advisers including lawyers, bankers, auditors and insurers based in Canada and the United States who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other government authorities who require reporting of processing activities in certain circumstances.
- Service Providers who provide hosting, network, system administration and other services that assist us in providing the Website, the App (if any) and the Services. These include:
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legally required purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. DATA LOCALITY
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
- Hubly is the Data Controller as a supplier of services, an employer, and where dealing with its suppliers;
- Hubly is the Data Processor in respect of Personal Information which it processes on behalf of its customers.
If you wish to exercise any of the rights set out above, please contact us using the details set out above.