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PRIVACY POLICY

HUBILATION Privacy Policy
Effective Date: April 15, 2019.

This Privacy Policy explains which personal data we (HWI Hold OÜ, in subject to the project ‘HUBI’) collect and how we use such personal data when you use the HUBI website (www.HUBILATION.com/) and/or any of HUBI’s online or mobile products (including the HUBI mobile apps), HUBI software, or other services (“Services”). The controller according to Art. 4 (7) of the General Data Protection Regulation (“GDPR”) is HWI Hold OÜ, (J. Kunderi tn. 8a, 10121 Tallinn, Email: info@hubilation.com).
We will post any modifications or changes to the Privacy Policy on the HUBI website. We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. If we make a material change to this Privacy Policy, we will notify you by email or by means of a notice on the HUBI website or via push notifications within our mobile applications prior to the changes taking effect. We regularly update our software applications (including our mobile and desktop applications and website) to make improvements, including improvements that better serve your privacy rights. To ensure that this Privacy Policy accurately reflects your use of the Services you will need to ensure that you are using the most recent release of the HUBI’s software applications.

1. HUBI International Compliance
We may process, transfer and store your information in the United States and in other locations outside of the European Economic Area. Any transfer of your data to the United States or another location outside the European Economic Area will be in compliance with applicable European data protection laws. In respect of transfers to the United States comply with the E.U. – U.S. and Swiss U.S. Privacy Shield Frameworks, details of which are set out in Section 13 below. In order to safeguard data transfers to other recipients located outside of the European Economic Area and in order to grant sufficient protection of your Personal Data in this context, we use standard data protection clauses adopted by the European Commission according to Art. 46 (2)(c) GDPR. You can find out more about those by contacting us at HUBI Privacy Department, Email: info.HUBI@gmail.com.

2. The Information We Collect
Information You Provide
HUBI collects a variety of information that you provide directly to us, including personal data that may be contained in any videos, comments, or other submission you upload or post to the Services. “Personal Data” is information that identifies you and which is collected in the context of:
• Account registration and administration of your HUBI account (in which case we collect the following categories of personal data: Name and email address);
• Uploads or posts to the Services (in which case we collect the following categories of personal data: any Personal Data included within the content that you upload or post);
• Contest registration and price acceptance (in which case we collect the following categories of personal data: Name, postal address, payment details, date of birth, telephone number and email address);
• Customer support and technical assistance (in which case we collect the following categories of personal data: Customer ID, name, postal address, geo-location, IP address, license number, ticket or case number, telephone number and email address);
• Processing your order for products or Services offered by HUBI (in which case we collect the following categories of personal data: Customer ID, name, date of birth, postal address, billing address, payment details, telephone number and email address);
• Registration for your HUBI license (in which case we collect the following categories of personal data: Customer ID, name, date of birth, postal address, telephone number, license number and email address);
• Newsletter subscriptions (in which case we collect the following categories of personal data: Name, date of birth, postal address and email address);
• Access to HUBI licenses or Services on social networks or third party services (in which case we collect the following categories of personal data: Those categories of data that you provide in accordance with your settings on the social networks or third party services); or
• Services provided online or by way of the HUBI software (in which case we collect the following categories of personal data: Name, date of birth, postal address, billing address, payment details, telephone number and email address).

3. Information We Automatically Collect
When you use HUBI’s Services that connect to the Internet, including but not limited to, when you access the Services via HUBI applications (web, mobile, desktop software, cloud services, connected TV and games console), your HUBI account, and our websites and web store, we collect the Personal Data from you as described in the following. Such information includes aggregated user data (which does not allow us to identify you), as described in more detail in the following. We also use third party analytics providers and technologies to assist in collecting this information, as further disclosed in the Cookie Policy.
• Websites
When you use our websites (including our web store), we collect and analyze the following information about your computer or mobile device: Your browser type, IP address, location, a mobile device identifier (e.g., a IDFA on Apple products like the iPhone and iPad or similar advertising identifiers), browser language, operating system, videos viewed, processed, uploaded, downloaded, assembled, modified and liked, error logs, and other similar information.
• Mobile Software Applications
When you use a HUBI mobile application we automatically receive certain information about your mobile device and use of the application, including a mobile device identifier (e.g., a IDFA on Apple products like the iPhone and iPad or similar advertising identifiers), operating system, version, IP address, location, videos viewed, processed, uploaded, downloaded, assembled, modified and liked, and other similar information, such as time spent in different portions of the HUBI mobile application and error rates.
• HUBI Desktop Software Applications
Our desktop software, including but not limited to HUBI Desktop App, automatically sends data about usage of the service or the software when it connects to the Internet. This information includes information about your computer such as operating system, IP address, location, technical specifications, videos viewed, processed, uploaded, downloaded, assembled, modified and liked, and data related to your use of the service or the HUBI software on the computer such as time spent in different portions of the HUBI desktop application and error rates.
• Connected TV Applications
When you use a HUBI TV or Screening app, we collect and analyze information such as operating system, IP address, location, the number of clicks, videos viewed, processed, uploaded, downloaded, assembled, modified and liked, the amount of time spent on particular videos and the app, error logs, and other similar information.
• Location Information
When you install our mobile applications, you will if legally required be asked for your consent to grant access to your mobile device’s geolocation data. If you grant such permission, we will collect information about your geolocation and will use that information to customize the Services with location-based information and features. You can withdraw your consent at any time. Moreover, you can disable the GPS or other location-tracking functions on your mobile device, provided your mobile device allows you to do this. See your device manufacturer’s instructions for further details.
Some video and audio recording devices may associate your location with the content that you create on that device. On such devices you will be asked for your consent to activate the HUBI’s geolocation functionality. If you grant such permission, any content that you create on that device will have the location where the content was created embedded on the content file. If you no longer wish to use the geolocation functionality you can disable it in the device’s settings.
• Information from Other Sources
If you connect to a third party network (such as a social network), platform, or service through the Services, you are asked to authorize us to collect, store, and use in accordance with this Privacy Policy any and all information (such as name, email address and location) that you agreed the network or other third party platform could provide to HUBI based on your settings on the third party network or platform. You will be asked for your consent when you connect with the third party network, platform, or service via our Services, and/or when you connect with one of our applications through one of these services.
You can revoke your consent at any time with future affect which will not affect the processing of your Personal Data being undertaken until the withdrawal by contacting us at info.HUBI@gmail.com. Please note that this might have the effect that you cannot use some or any of HUBI’s services.

4. Cookies and Similar Technologies
Please see our Cookies Policy.

5. Uses of Information
HUBI uses the Personal Data that it collects as further described in Section 2 above for the purposes and on the legal basis as described in the following:
Customer Service - Based upon the Personal Data you provide us at the time of HUBI account registration or purchase, we will send you a confirmation email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your HUBI account. We will communicate with you by email, telephone or chat, in accordance with your preferences.
Such processing of your Personal Data is necessary for the performance of our Services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you order-related communications.
Newsletters, Social Media Campaigns, Special Offers and Updates - Only with your prior consent, we will occasionally send you information on products, services, special promotions, contests, events, customer satisfaction surveys and opportunities to interact with HUBI and our community. You can sign up to receive these emails and social media campaigns from us on our newsletter sign up page and/or during checkout while purchasing a product. You have the option to opt-out of these types of communications at any time.
The legal basis for such processing of your Personal Data is therefore your consent (Art. 6(1)(a) GDPR). Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to send you our newsletters and other information as described above.
Service-Related Announcements - We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your HUBI account. Please note that this might have the effect that you cannot use some or any of HUBI’s services.
Such processing of your Personal Data is necessary for the performance of our Services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you order-related communications.
HUBI Personalization Services – Only with your prior consent, we use the information which we collect when you access the Services via HUBI applications (web, mobile, desktop software, cloud services, connected TV and games console), your HUBI account, and our websites and web store to create profiles and to further personalize and improve the Services for you, such as by providing personalized customer support (e.g. to access your HUBI logs to troubleshoot a technical issue you have experienced), delivering in-application messages and promotions, recommending features, and tailoring content and advertising to you.
The legal basis for such processing of your Personal Data is therefore your consent (Art. 6(1)(a) GDPR). Please note that you are not legally required to provide us with your consent. However, without your Personal Data we will not be able to offer you our HUBI personalization services as described above.
Order-Related Communications - If you place an order, we will use your name and email address to send you an order confirmation email, a release and accessibility confirmation email.
Such processing of your Personal Data is necessary for the performance of our Services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you order-related communications.
Project Processing – In order to fulfill the provided HUBI services your personal information, uploaded and provided media files and other related data and information will be stored, processed and shared within the project groups you participate in. Such processing is necessary to provide the fundamental service of HUBI. Once you agree to participate in a project, you give your consent to the use of your data and information for the purpose of fulfilling the project within the HUBI framework and its means in general. Please note, that once published, the related data and information can not withdrawn. That relates in specific to information, data, visual and audio content of you in uploaded media files, including your name, “nick-name”, email address.

6. Sharing and Disclosure of Information
HUBI does not share, sell, transfer or otherwise disseminate your Personal Data to third parties, unless required by law according to Art. 6 (1)(c) GDPR, unless required for the purpose of your contract according to Art. 6 (1)(b) GDPR or unless you have given us express consent to do so according to Art. 6 (1)(a) GDPR.
We use other third party service providers to offer or facilitate services on our behalf and share your Personal Data with such providers to the extent necessary for such providers to perform their services on our behalf., In particular, we are using an Ecommerce platform to a provide our web store, a credit card processing company to bill you for goods and services, cloud based enterprise resource planning software providers to record and manage web store sales and subscriptions, cloud based customer relationship management software to enable us to record and plan our customer interactions, a cloud based subscription software provider to automate our subscription billing, a data center to administer all online aspects of the Services, a cloud based storage provider to store any content that you upload to your HUBI account, an accounts payable provider to process any payments that we make to you, a social media agency to manage our social campaigns, a data onboarding company to implement our social campaigns, email service providers to send out emails on our behalf, an in app messaging provider to send out mobile app notifications on our behalf and a web messaging provider to serve messages while you browse HUBI.com. When you order licenses or services from HUBI, we will share your Personal Data as necessary for such third party services providers to provide the applicable service to us or on our behalf. Any sharing of your Personal Data with such third party service providers will be made in accordance with applicable data protection laws and will be limited to the extent necessary. These third parties are prohibited from using your Personal Data any other purposes than those described herein.
We may be required to disclose your information to government or law enforcement officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements according to Art. 6 (1)(c) GDPR. We can also disclose your information in order to pursue our legitimate interest in applying or enforcing our terms and conditions or in responding to any claims, in protecting our rights or the rights of a third party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction) according to Art. 6 (1)(f) GDPR. If you have any further questions regarding the balancing test in connection with Art. 6(1)(f) GDPR, please contact us at the contact details set out in Section 16 below.

7. Your Choices
HUBI provides you with a number of choices with respect to the information we collect and use as discussed throughout this Policy. Some of your choices include:
• Marketing Communications. If you purchase a product but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form by leaving the “Opt-In” checkbox blank. If you have opted-in, but no longer wish to receive our newsletters, social media campaigns and promotional emails, you may opt out of receiving them by following the instructions included in each newsletter or email or by contacting customer support at http://HUBI.com/support/.
• HUBI Personalization Services. As discussed in depth in Section 5, HUBI may use the information we have collected from and about you to personalize your HUBI experience. If you do not want HUBI to provide such personalized services, you may opt out through your HUBI account settings by disabling the Send Personalization Data tab.
• Tailored Online Advertising Opt-Out. HUBI strives to provide the public with relevant, value-added content in the form of online advertisements. However, we respect the wishes of anyone who does not want to be tracked by third party advertising companies online. For information on how to opt out of cookie-based online advertising and analytics programs, please refer to our Cookie Policy.

8. Customer Testimonials
At times, we may post customer testimonials on our website. You should not include personal information into such testimonials and in particular use a "nick name" instead of your real name.

9. User-Generated Content
You may be able to disclose information about yourself in the course of contributing user generated content on publicly-available areas of the Services. This includes, but is not limited to: your uploaded photos or videos, full name, email address, phone number, address, date of birth, interests and content that you have created and favorited. Your photo or video files may also contain your narrations and captions, as well as data regarding your precise geo-location or information from the uploading device. Your content will also be shared with users of your HUBI project or other social media services to which you have chosen to share, consistent with your privacy settings on those services. Such information is unencrypted, public information, may be accessed or recorded by us, and there is no expectation of privacy or confidentiality in such information. Any information, including your Personal Data you submit in the course of such activities can be read, collected, or used by other users. We cannot control how other users of our Services might use your information. We especially cannot prevent you receiving unwanted messages from other users. If you wish that a specific content generated by you shall be removed from publicly-available areas of our Services, please contact us at privacy@hubilation.com.
All Personal Data posted on publicly-available areas of our Services are processed in order to provide you with the respective Service according to Art. 6 (1)(b) GDPR.
If you submit your video or other content to HUBI, we may publish it on the HUBI website, or sub-website or applications along with certain Personal Data identifying you, e.g., your first and last name or your username provided that you have given us permission to do so. For more information relating to the terms governing your user generated content, please see our Terms of Use.
The legal basis for such processing of your Personal Data is therefore your consent (Art. 6(1)(a) GDPR). Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to attribute the submitted content to you described above. Also, please note that this might have the effect that you cannot use some or any of HUBI’s services.

10. Information About Your Rights
You have the following rights:
• Right of access (Art. 15 GDPR): You have the right to request confirmation as to whether or not your Personal Data is being processed, and, where that is the case, to request access to the Personal Data and information such as the purposes of the processing or the categories of Personal Data concerned.
• Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate Personal Data.
• Right to erasure (Art. 17 GDPR): You have the right to request erasure of Personal Data without undue delay under certain circumstances, e.g. if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which processing is based according to Art. 6 (1)(a) GDPR and where there is no other legal ground for processing.
• Right to restriction of processing (Art. 18 GDPR): You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the Personal Data we process about you is incorrect or unlawful.
• Right to data portability (Art. 20 GDPR): Under certain circumstances, you have the right to receive your Personal Data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
• Right to object (Art. 21 GDPR):
You have the right to object to the processing of your Personal Data under certain circumstances in particular if we process your Personal Data on the basis on legitimate interest (Art. 6 (1)(b) GDPR) or if we use your personal data for marketing purposes.
You may assert those rights at any time by logging into your HUBI account and accessing features such as Edit Profile and Account Info. You may also email us to correct or change any information or request which Personal Data (e.g. name, address) we have stored or to assert any other of your rights as mentioned above by emailing us at privacy@hubilation.com 

11. Right to Lodge a Complaint Before the Data Protection Authority
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at privacy@hubilation.com and we will provide you with detailed information as regards the contact details of the respective competent supervisory authority.

12. Third Party Website Links and Features
HUBI’s Services may contain links to or features from other websites. This Privacy Policy covers the privacy practices by HUBI, and does not cover the privacy practices of third party websites or features. HUBI is not responsible for the privacy policies and/or practices of third parties. When linking to another Site or using a third party service, you should read the privacy policy on that site or service.
In case you use the option to register or login to HUBI through a Social Networking Service, we will ask you for your permission to access your data on the Social Networking Service to create an account and Profile at HUBI. In addition, we may use this data for several purposes, including:
Account and profile fields - When you access HUBI through a Social Networking Service, we will pre-fill and update your account and profile fields with data from the Social Networking Service that you gave us permission to access. Via your account and you can update this information at any time.
Profile personalizing: When you access HUBI through a Social Networking Service, we may personalize the HUBI services experience by showing your name (first name and last name) and profile picture, “nick-name” or avatar (optional) on your public profile page, next to your reports and sharing posts, or on other areas of the site where your content is displayed. We may additionally use information from your social media profile or your social media activities on HUBI services to personalize content for you and offer features and opportunities tailored to your interests.
Aggregate Reporting: When you access HUBI through a Social Networking Service, we may use data from the Social Networking Service that you give us to access to, to learn more about the demographic information of our users.
You may disconnect from a linked Social Networking Service at any time by visiting your HUBI account in the HUBI mobile application, the HUBI Desktop application or in your HUBI account.
No information about you that we collected on HUBI with a linked Social Networking Service will be shared without your approval. HUBI will not post anything to your Google account, Facebook wall, or Twitter feed unless you give us specific allowance to do so. HUBI will not of own accord contact your friends or followers at any time, but provide the option that you can initiate such process at any time (e.g. “invite a friend”). We do not store or utilize the names of your friends or followers even if they are passed to us by a social sign-on service in the initial registration process.
Social Networking Services provide varying levels of control over the extent to which content or information you submit to the Services is also made public and shared on linked Social Networking Services. When you use a Social Networking Service to log into the Services:
You share your information with it and its privacy policy applies to the Social Networking Service's collection, use, and disclosure of such information.
In addition, the Social Networking Service may be able to collect information about you, including your activity on the Services, and it may notify your connections on the Social Networking Service about your use of the Services.
Such services may also employ unique identifiers which allow your activity to be monitored across multiple websites for purposes of delivering targeted advertising to you.
Please note that the privacy policies and terms of use of linked Social Networking Services may be different from our own and we encourage you to read them. We also encourage you to familiarize yourself with the privacy controls and account settings on linked Social Networking Services for information on how to customize your privacy settings with respect to content or information submitted to the Services.

13. Privacy Shield - EU – US Data Transfers and Swiss – US Data Transfers
HUBI is also an international business with multi-national operations, systems, and processes. If you are located outside the United States and provide Personal Data to us, HUBI will transfer your Personal Data to the United States and process it in the United States in accordance with this Privacy Policy.
Our Obligations to you under the Privacy Shield
HUBI has applied for self-certification with the EU-U.S and Swiss U.S. Privacy Shield Frameworks.
HUBI complies with the EU-U.S. and Swiss – U.S. Privacy Shield Frameworks (“Privacy Shield”) as set forth by the U.S. Department of Commerce and approved by the European Commission and Swiss Federal Counsel regarding the collection, use, and retention of Personal Data HUBI receives from European Union member countries and Switzerland.
HUBI has certified that it adheres to the following Privacy Shield Principles of (1) Notice; (2) Choice; (3) Accountability for Onward Transfer; (4) Security; (5) Data Integrity and Purpose Limitation; (6) Access; and (7) Recourse, Enforcement and Liability in respect of any Personal Data received from the European Union and Switzerland.
We collect and process data in accordance with this Privacy Policy. Please see Section 2 for further details of the types of data which we collect from you and the purposes for which we collect it in Section 4.
If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page on the Privacy Shield List, please visit https://www.privacyshield.gov/
The following any subsidiaries or associated entities of HWI Holding OÜ, also adhere to the Privacy Shield and collect data in accordance with the terms of this Privacy Policy.
Accountability and Liability for Onward Transfer
HUBI is required to take certain steps when transferring Personal Data received from the European Union and Switzerland to third parties (such as including necessary contractual provisions in our third party contracts). HUBI may be potentially liable in cases of onward transfer of EU and Swiss individuals' data received pursuant to the Privacy Shield to third parties.
Privacy Complaints Handling, Recourse and Enforcement
In compliance with the Privacy Shield Principles, HUBI commits to resolve complaints about your privacy and our collection or use of your Personal Data (without charge to you). European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at:
Email address – info.HUBI.com
We will respond to any complaints as soon as possible and within 45 days.
We encourage EU and Swiss individuals who have questions or complaints about how we process their Personal Data under Privacy Shield to contact us at info.HUBI@gmail.com. We will work to resolve your issue as quickly as possible, but in any event within 45 days of receipt. If you are an EU or Swiss individual and unable to resolve any complaints through direct contact, you may be able to invoke binding arbitration through a Privacy Shield panel, in accordance with the Privacy Shield Framework at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
Please note that if your complaint is not resolved through these channels, in certain limited circumstances, a binding arbitration option may be available.
HUBI is subject to the investigatory and enforcement powers of the Federal Trade Commission in the case of any failure to comply with the Privacy Shield.

14. How we Protect Your Personal Information
The security of your Personal Data is important to us. We have implemented state of the art administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. This includes encrypting our Services using Secure Sockets Layer (SSL) and restricting access to Personal Data to HUBI employees, contractors, customers, partners and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations. Despite our best efforts, however, no security measures are completely impenetrable.

15. Data Retention
We delete or anonymize your Personal Data as soon as it is no longer required for the purposes we have collected your Personal Data as outlined in this Privacy Policy, unless further processing or storage of your Personal Data is necessary in order to comply with a respective legal obligation. For more information on the different categories of Personal Data and their respective retention periods, please contact privacy@ hubilation.com.

16. HUBI Contact Info
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:
HWI Holding OÜ
J. Kunderi tn. 8a,
10121 Tallinn
Email: info@hubilation.com 

 

 

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