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.

Your privacy matters to us so please take the time to familiarize yourself with our policies, and if you have any questions please contact us at privacy@myhubly.com

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.


1.  IMPORTANT INFORMATION AND WHO WE ARE
‍Purpose of this Privacy Policy‍
This Privacy Policy aims to give you information on how Hubly collects and processes your personal information through your use of the App, Website and the Services, including any information you may provide when you use our Services, when you search our App or Website, when you subscribe to our email alerts, when you contact our customer service, when you participate in surveys, public forums, chats, or when you respond to one of our requests for suggestions and other content.

Please note that neither the Website nor the Service is intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website or through our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.


Contact Details
Our full details are:
Hubly Inc.
Email address: privacy@myhubly.com
Postal address: 289-2366 Main Mall, Vancouver, BC, CANADA V6T 1Z4
Telephone number: 1 888 329 0276
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Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on 29 August, 2019.
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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.
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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.
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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.

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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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.
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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.

If you fail to provide personal information
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).


3.  HOW IS PERSONAL INFORMATION COLLECTED
We use different methods to collect data from and about you including through:

• 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.

4.  HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• 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.

By using our Services you are consenting to our use of your personal data in the manner set out in this policy.

Cookies
When you interact with the Website we strive to make that experience easy and meaningful. When you come to our Website, our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer's hard drive and are used to tell us whether customers and visitors have visited the Website previously. If you click on a link to a third-party Website, such third party may also transmit cookies to you.

Standing alone, cookies do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to HUBLY, either by responding to a promotional offer, opening an account, or registering for a free trial, you remain anonymous to HUBLY. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser.

HUBLY uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows HUBLY to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the HUBLY application. HUBLY uses persistent cookies that only HUBLY can read and use, to identify the fact that you are an HUBLY customer or prior HUBLY Website visitor (whatever the case may be). We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users who disable their web browsers ability to accept cookies will be able to browse our Website but will not be able to successfully use our Services. End Users may be able to limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.

Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@myhubly.com.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law


5.   DISCLOSURES OF YOUR PERSONAL INFORMATION
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.
• 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 require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service Hublys to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6.  DATA SECURITY
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.
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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.

7.  DATA RETENTION
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.
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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.
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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 you can ask us to delete your information: see Request erasure below for further information.
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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.

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8. DATA LOCALITY
The data that we collect from you may be transferred to, and stored in, Canada which is outside the European Economic Area ("EEA") and for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. The data that we collect from you may also be transferred to, and stored at, United States of America outside the European Economic Area ("EEA") for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. For information about the adequate security safeguards that have been put in place for data based in the United States of America, you can reach out to privacy@myhubly.com

9.  YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:

• 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.

For the purposes of the European General Data Protection Regulation (the “GDPR”) :

• 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 are a resident of the European Union, you may also lodge a complaint with your local privacy commissioner or other Supervisory Authority with respect to our processing of your Personal Information. The local Supervisory Authority in each European country can be found here.

If you wish to exercise any of the rights set out above, please contact us using the details set out above.


No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Effective date: 29 August 2019