hubub, Inc. (“hubub”, “we”, “our” or “us”) provides its users (“User(s)” or “you”) with a mobile
application platform and web services to plan and
optimize entertainment and transportation (the “Services”). hubub is committed to your privacy. This
Privacy Notice is intended to inform you of our
collection, use, disclosure, retention, and protection of your personal information when using our
Services.
Our Services include our websites at Hubub.me, and/or Hubub Developers and any additional websites owned and operated
by hubub or its affiliates (the “Site(s)”), our downloadable mobile application(s) (the “App”) and
related services.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms
of Use available at Terms of Use
which this Privacy Notice is incorporated thereto by reference (together, the “Terms”).
Please read carefully this Privacy Notice before accessing and using our Services. By Accessing or
using our service you are accepting the practices described in this Privacy Notice.
1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect and process the following
categories and types of information:
Information You Provide to Us. When you use our Services, we collect the following categories of
personal information about you:
Contact Details such as your name, email address, phone number, and mailing address.
Account Data such as your username, password, and profile preferences.
Travel Itinerary Details such as planned trip destinations, trip dates, preferred
accommodations, flights, transportation, and booked activities.
Payment Information needed to complete your transactions with us, including name, payment
card information, and billing information. This information is processed
by our payment service providers, EpicPay, BrainTree, and Zooz, which handled your payment
information in accordance with its own privacy policies. We do not have access to your full
payment card information.
Communication Records such as messages exchanged with our support team, feedback
submissions, and inquiries regarding bookings.
Group Travel Data such as shared itineraries, participant details, and group
communication within the app.
Marketing Information such as your preferences for receiving our marketing communications
and details about your engagement with them.
Other Information not specifically listed here, which we will use as described in this
Privacy Notice or as otherwise disclosed at the time of collection.
Where you provide us with the personal information of third parties, such as your friends or other
contacts, it is your responsibility to inform them about the processing of
their personal information in accordance with this Privacy Notice, and to confirm that they have
given their permission.
Automatic Data Collection We and our service providers may automatically log and combine
information about you, your computer or mobile device, and your interactions over time with
the Services, online resources, and our communications, such as:
Information collected at account creation
After account creation, we will collect and
process your information, including the User ID, Metro area and certain
device information which includes your device ID or other unique identifier, advertising ID,
unique device token, device type, operating system (including version and settings),
as well as your device screen resolution and keyboard language, all in accordance with this
Privacy Notice.
Usage Information
(a) We receive information from you when you access and use our
Services, as follows: your IP address, tokens of social networks you choose to connect to your
account
(as described below), information regarding your clicks, views and engagement with the Services
and with advertisements we may display on the Service, information concerning your traffic to
and from
the Services, your referral URL, our communications with you, your entertainment and transit
historical searches on the Services, information about your use and your interaction with our
Services,
including the duration of such use; your in-app settings; and your in-app scores.
(b) If you are using our Services as a developer of an online product or service connecting your
online product or service to the hubub Services, and have elected to open a developer account,
hubub will provide you and store your Developer ID and any information with respect to the
traffic directed through your online product or service.
Geo-Location information and other sensors data(a) hubub automatically collects
location information such as your geo- location and your route and travel
information (for example, routes and times of travel from one destination to another) in order to
provide you with our Services. When using the App we collect detailed location including
GPS signals and other device sensors data such as gyro/oscilloscope sent by your mobile device for
which the Service is installed and activated.
(b) Depending on your in-App choices and device system setting, hubub may collect your location data
even when you are not using the app to personalize the services and maximize your
user experience and to develop and enhance our entertainment and transit information services. You
may choose to disable and opt- out from this background collection of data under
the app’s privacy settings screen or from your device’s general privacy settings.
Cookies & Similar Technologies(a) We perform some of the automatic collection
described above through use of cookies, web beacons, unique identifiers, and similar technologies
which allow us to collect information about the pages and screens you view, the links or ads you
click, and other actions you take when using our Services.
(b) Please take into consideration that certain portions of such above mentioned information may
also be collected from your device or software, when the Services are running
in the background, i.e. when they have been launched but are not actively used.
(c) For more information about our use of these technologies, and how you may exercise control over
them, see our Cookie Policy at
Hubub Cookie Policy
(d) Please keep in mind that most mobile devices and operating systems allow you to control or
disable the use of certain collectable information including location services by applications, in
the device’s settings menu.
Personal information collected from other sources.
Third Parties We may also collect personal information concerning you, from
third parties who have assured us that they have obtained your consent for such provision of
information or that you have freely and publicly provided. For example, we may collect and use
demographic and other information that is publicly available in an applicable jurisdiction,
additional contact information, credit check information, and information from credit bureaus, as
allowed by applicable national laws.
Social Media you elected to connect to your account We allow you to share
information with social platforms, or use social platforms to create
your hubub account. These social platforms give us automatic access to certain personal information
retained by these social networks about you. This includes your Facebook Access
Token, Google Sign-In Token, advertiser ID and information from your public profile, which may
include your name, gender, profile picture, age group and residency. You control the personal
information you allow us to have access to through the privacy settings on the applicable social
platforms and the permissions you give us when you grant us access to the personal information
retained by the respective social platforms about you.
Other Sources We may obtain personal information from other third parties, such
as marketing partners, publicly-available sources, and data providers.
2. HOW DO WE USE YOUR INFORMATION?
Legal basis for use. We collect, process and use your information for the purposes described in this
Privacy Notice or as otherwise described at the time of collection, based at least on one of the
following legal grounds:
When Performing this Agreement:
We collect and process your personal information in
order to provide you with the Service, following your acceptance of these Terms; to maintain and
improve our Services;
to develop new services and features for our Users; and to personalize the Service in order to
deliver better user experience. For example, we collect your location information in order to
provide you with recommended
entertainment and transport means and routes to your destination.
With your consent
We ask for your agreement to process your information for additional specific purposes and you
have the right to withdraw your consent at any time. For example, we ask for your
consent to provide you with personalized content through the use of cookies.
Legitimate Interests
We process your information for our, or our third parties,
legitimate interests while applying appropriate safeguards that protect your privacy.
This means that we process your information for things like detecting, preventing, or otherwise
addressing fraud, abuse, security, usability, functionality or technical issues with our
services; protecting against harm to the rights, property or safety of our properties, our users
or the public as required or permitted by law; for the development and enhancement of our
Services; for enforcing legal claims, including investigation of potential violations of this
Privacy Notice; in order to comply and/or fulfil our obligation under applicable laws,
regulation,
guidelines, industry standards and contractual requirements, legal process, subpoena or
governmental request, as well as our Terms.
Purpose of Use: We may use information that we collect about you for the following
purposes:
To provide you with and to operate the ServiceWe use your personal information to perform
our contractual obligation towards you to provide you with the Services. This includes:
(a) to personalize the Service and content provided to you, to customize your experience with
the Services, to suggest you with entertainment and transport recommendations based
on your preferences and to enable you to retrieve your information;
(b) to be able to contact Users for the purpose of providing them with technical assistance,
support, handle requests and complaints, and collect feedback in
connection with our performance of the Services and in connection with entertainment and
transportation needs;
(c) to send you updates, notices, announcements, and additional information related to the
Service;
(d) to be able to reply to User online queries in connection with performance of the Services;
and
(e) for customization and improvement of the Service’s accuracy and interface.
For research, development, benchmarking, and improving our Services. We may use
information where it is in our legitimate interests to analyze and improve the
Services, identify trends, and operate and expand our business activities. We may also create
aggregated, anonymized, or other de-identified statistics, which we may use and disclose
for lawful business purposes, including for analytics, forecasting, and strategic planning.
For marketing and advertising We and our advertising partners may collect and use your
personal information for marketing and advertising purposes, including:
(a) Email: We or our advertising partners may from time-to-time send you direct marketing
emails as permitted by law, including, but not limited to, notifying you of
special promotions, offers and events via email. You may opt out of our marketing emails as
described in the “Communications from hubub” section below.
(b) Interest-based advertising We engage our advertising partners, including third party
advertising companies and social media companies, to display ads around the web.
These companies may use cookies and similar technologies to collect information about your
interaction over time across our Services, our communications, and other online services,
and use that information to serve online ads that they think will interest you. We may also share
information about our users with these companies to facilitate interest-based
advertising to those or similar users on other online platforms. You can learn more about your
choices for limiting interest-based advertising in our
Cookie
Policy.
Except where consent is required, we carry out marketing and advertising where it is in our
legitimate business interests.
For compliance and protection We may use personal information to comply with legal
obligations, including to enforce any applicable terms and conditions, and where we have a
legitimate interest to
defend against legal claims or disputes, protect the security and integrity of our Services, and
identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.
3. TO WHOM WE MAY SHARE PERSONAL INFORMATION
We may share your personal information with third parties (or otherwise allow them access to it) in
the following manners and instances:
Other Hubub Users
(a) Our Services are social by design, and we enable our Users to share information with each
other. When you share information with other Users by forming a group or
inviting other Users to your events, we may share data with those Users necessary to the
Service. Please be careful with what you choose to share through the Services.
Service Providers
hubub has partnered with a number of service providers, whose services and solutions complement,
facilitate and enhance our own. These include hosting, database and server co-location
services (such as AWS, Google Cloud Product), data and cyber security services (such as
Reblaze), Payment Processors (such as EpicPay, BrainTree, Zooz), fraud detection and prevention
services (such as Reblaze), data analytics services (such as Facebook Analytics, Google
Analytics), App analytics tools including session replay records for usability and functionality
monitoring and analysis (such as: Appsee, Crashlytics), services of measuring our Services
attribution and effectivity of our publication and marketing efforts (such as: Appsflyer),
e-mail distribution and monitoring services (such as Mailchimp, Mandrill), and other service
providers (collectively, "Service Providers")
Governmental/Law Enforcement Agencies and Legal Requests or Duties
We may disclose or otherwise allow access to your personal information pursuant to a legal
request, such as a subpoena, search warrant or court order, or in compliance with
applicable laws, with or without notice to you, if we have a good faith belief that we are
legally required to do so, or that disclosure is appropriate in connection with
efforts to investigate, prevent, or take action regarding actual or suspected illegal activity,
counter terrorist financing verification requirements, fraud, or other wrongdoing.
Protecting Rights and Safety
We may share your personal information with others, with or without notice to you, if we believe
in good faith that this will help protect the rights, property or
personal safety of hubub, any of our Users, or any member of the general public.
Hubub Subsidiaries and Affiliated Companies
We may share personal information internally within our family of companies, for the purposes
described in this Privacy Notice.
Professional Advisors
We may share personal information with professional advisors such as lawyers, auditors, bankers,
and insurers, where necessary in the course of the professional services that they render to us.
Business Transferees
Should hubub or any of its affiliates undergo any change in control, including by means of
merger, acquisition or purchase of substantially all of its assets, your personal
information may be shared with the parties involved in such event.
4. INTERNATIONAL DATA TRANSFERS
You will provide personal information directly to us in the United States, which may not the
same protections as the data protection laws in your home country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in
place to afford adequate protection for personal information and we will comply with applicable
data protection laws,
in particular by relying on an EU Commission or UK government adequacy decision or on
contractual protections for the transfer of personal information. For more information about how
we transfer personal information internationally,
please contact us as set out in the “Contact Us” section below.
5. SECURITY
We take great care in implementing and maintaining the security of hubub’s Service and its
User’s personal information. hubub employs industry standard procedures and policies to ensure
the safety of its Users’ personal information
and prevent unauthorized access, disclosure and alteration of any such information. Some of the
safeguards we use are firewalls and data encryption, physical access controls to our data
centers, and information access authorization controls.
We cannot, however, guarantee that unauthorized access will never occur.
6. COMMUNICATIONS FROM HUBUB
Service Messages
hubub may contact you with information regarding our Services, or
your use thereof. For example, we may notify you (through any of the means available to us) of
changes or updates
to our Services, including changes to these Terms, transactions performed, payment issues,
service maintenance, etc. You will not be able to opt-out of receiving such service messages.
Promotional and Surveys Messages
(a) In addition to communications that are an inherent part of our Services, occasionally we may
also use your contact information to contact and notify you about new services and special
opportunities or promotions we think
you will find valuable and may also contact you in connection with surveys we conduct with
respect to our services or in connection with public transportation issues either on our own
behalf or on behalf of our partners. We may
contact you through e-mail, phone (including text messages), push notifications, through the
Services, or any other contact methods available to us, including with the help of our Service
Providers. Accordingly, we shall be entitled to
call you or send you promotional content or messages by e-mail, SMS, direct text messages, web
chat, marketing calls, and similar forms of communication.
(b) If you wish not to receive such promotional messages or calls, you may notify hubub at any time
by e-mailing us at info@hubub.me, or by following the “unsubscribe” or “stop” instructions contained
in the promotional
communications you receive. As for messages we send through push notifications you may opt-out of
receiving such notification by changing your device or App settings.
7. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
Depending on your location you may contact us to exercise your right to access personal
information, to request us to make corrections to your personal information that you have stored
with us, to object to any
form of processing, or to have such personal information deleted or exported in a portable copy.
Where we rely on your consent, you may withdraw your consent at any time. You may also appeal
our denial of your
personal information request. For any of these requests, please send us an e-mail to
info@hubub.me, or mail your request to the EU representative with a copy to hubub, 450 E
Waterside Dr., Unit 2308, Chicago, IL 60601,
and we will respond within a reasonable timeframe and in accordance with applicable laws and
regulations.
You may also be entitled to information about how we have collected and used personal
information. By default, we have made this information available to you without having to
request it by including it in this Privacy Notice.
In some instances, your choices may be limited, such as where fulfilling your request would
impair the rights of others, our ability to provide a service you have requested, or our ability
to comply with our legal obligations and enforce
our legal rights. If you are not satisfied with how we address your request, you may submit a
complaint by contacting us as provided in the “Contact Us” section below. Depending on your
location, such as if you reside in the European
Economic Area or United Kingdom, you may have the right to complain to a data protection
regulator where you live or work, or where you feel a violation has occurred.
Additionally, you can opt out of third-party cookies as described in our Cookie Policy.
8. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
We will retain your personal information for as long as you maintain an account or as otherwise
necessary to provide you the Services. We will also retain your personal information as
necessary to comply with our
legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements
and/or protect our legitimate interests.
Where we no longer need to process your personal information for the purposes set out in this
Privacy Notice, or following your request to delete your Personal Information, we will delete or
anonymize your personal information from our systems.
9. MINORS
To use our Services, you must be over the age of sixteen (16). Therefore, we do not knowingly
collect personal information from minors under the age of sixteen
(16) and do not wish to do so. We reserve the right to request proof of age at any stage so that
we can verify that minors under the age of sixteen (16) are not using the Services.
10. OTHER SITES AND SERVICES
Our Services may contain links to websites and other online services operated by third parties.
In addition, our content may be integrated into web pages or other online services that are not
associated with us. These links and integrations are not an
endorsement of, or representation that we are affiliated with, any third party. We do not
control websites or online services operated by third parties, and we are not responsible for
their actions. This Privacy Notice does not apply to such third-party sites or services.
11. CHANGES TO THE PRIVACY NOTICE
The terms of this Privacy Notice will govern the use of the Service and any information
collected therein. hubub reserves the right to change this notice at any time, so we encourage
you to re-visit this page frequently. In the event of any substantial
change of this notice, we will provide you with prior notice via any of the communication means
available to us, or by posting notice of the change on the Site. After the specified notice
period, all amendments to this Privacy Notice shall be effective.
12. CONTACT US; DATA PROTECTION OFFICER; EU REPRESENTATIVE
If you have any questions about this Privacy Notice or hubub’s privacy practices, please contact us
at info@hubub.me:
hubub has appointed a Data Protection Officer, for monitoring and advising on its ongoing
privacy compliance and serving as a point of contact on privacy matters for data subjects and
supervisory authorities.
To contact the Data Protection Officer, send your email to info@hubub.me.
By contacting hubub, you represent that you are free to do so and that you will not knowingly
provide hubub with information that infringes upon third parties’ rights, including any
intellectual property rights. You further acknowledge that notwithstanding
anything herein to the contrary, any and all rights, including intellectual property rights in
such information provided, shall belong exclusively to hubub, and we may use or refrain from
using any such information at our sole discretion.
