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:

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

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:

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.

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:

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:

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.

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.

7.  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.

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.

8.  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.

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

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.

9. 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:

* 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