Hubcap Privacy Policy

Effective: January 23, 2025

1. Introduction

Hubcap ("we," "us," or "our") respects your privacy. This Privacy Policy ("Policy") describes how we collect, use, and disclose your information when you interact with us, including but not limited to information provided when you use our websites, mobile apps, widgets, and other online products and services (collectively, the "Services") or when you otherwise interact with us or receive a communication from us. We also describe the rights and choices you have regarding our use of your information.

Your use of the Services is subject to this Privacy Policy and our Terms of Use. If you do not agree with this Privacy Policy, please do not use our Services.

2. What Information We Collect

Information You Provide to Us. We collect information you provide to us directly when you use the Services, including:

Information We Collect Automatically. When you access or use our Services, we may also automatically collect information about you. This includes:

Information Obtained from Other Sources. We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, we may receive demographic or interest information about you from third parties, including advertisers (such as the fact that an advertiser is interested in showing you an ad), and combine it with data you have provided to Hubcap, using a common account identifier such as a hash of an email address or a mobile-device ID.

Information Collected by Third Parties.

3. How We Use Information

We use information about you for the following legitimate business purposes:

4. Hubcap Is a Public Platform

Much of the information on the Services is public and accessible to everyone, even without an account. By using the Services, you are knowingly sharing this information publicly and freely through the Services. When you submit content (e.g., a post, comment, or chat message) to a public part of the Services, any visitors to and users of our Services will be able to see that content, the username associated with the content, and the date and time you originally submitted the content. That content and information may also be available in search results on Internet search engines like Google. You should take the public nature of the Services into consideration before posting. We offer social sharing features that let you share content or actions you take on our Services with other media. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features (e.g., TikTok, YouTube, Instagram, and X).

Hubcap allows moderators to access Hubcap content using moderator tools. Hubcap also allows other third parties to access public Hubcap content using Hubcap's developer services.

5. How We Share Information

In addition to the information that is displayed publicly as described above, we may share information in the following ways:

6. How We Protect Your Information

We take reasonable and appropriate measures intended to protect information collected under this Policy from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We also employ technical and administrative access controls to limit which of our employees have access to non-public personal information.

We store the information we collect for as long as it is necessary to satisfy the purpose(s) for which such information was collected. We may retain certain information for legitimate business purposes and/or if we believe doing so is in accordance with, or as required by, any applicable law. For example, if you violate our policies and your account is suspended or banned, we may store the identifiers used to create the account (such as an e-mail address or phone number) to prevent you from creating new accounts.

7. Your Rights and Choices

You have choices about how to protect and limit the collection, use, and sharing of information about you when you use the Services. Depending on where you live, you may also have the right to correction/rectification of your personal information, to opt out of certain advertising practices, or to withdraw consent for processing where you have previously provided consent. Below we explain how to exercise each of these rights. Hubcap does not discriminate against users for exercising their rights under data protection laws. You may exercise your rights by contacting Hubcap using the contact information below.

Before we process a request from you about your personal information, we will need to verify the request via your access to your Hubcap account or to a verified email address associated with your Hubcap account. If we deny your request, you may appeal our decision by contacting us.

8. International Data Transfers

Hubcap, Inc. is based in the United States and we process and store information on servers located in the United States. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the United States and other countries, where you may not have the same rights as you do under local law.

When we transfer the personal data of users in the EEA, UK and/or Switzerland, we rely on the Standard Contractual Clauses approved by the European Commission for such transfers or other transfer mechanisms deemed 'adequate' under applicable laws.

9. Additional Information for EEA and UK Users

Users in the EEA and UK have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. These rights can be exercised as described in the "Your Rights and Choices" section above. EEA users also have the right to lodge a complaint with their local supervisory authority. As required by applicable law, we collect and process information about individuals in the EEA and UK only where we have a legal basis for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:

10. Additional Information for California Users

The California Consumer Privacy Act ("CCPA"), as amended, requires us to provide California residents with some additional information, which we address in this section. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

You can find more information about (a) what we collect and sources of that information in the "Information We Collect" section of this notice, (b) the business and commercial purposes for collecting that information in the "How We Use Your Information" section, and (c) the categories of third parties with whom we share that information in the "How We Share Information" section.

If you are a California resident, you have additional rights under the CCPA, including the right to opt out of any sales or sharing of your personal information, to request access to and information about our data practices, and to request deletion or correction of your personal information, as well as the right not to be discriminated against for exercising your privacy rights. Hubcap does not "sell" or "share" personal information as those terms are defined under the CCPA. We do not use or disclose sensitive personal information except to provide you the Services or as otherwise permitted by the CCPA.

You may exercise your rights to access, delete, or correct your personal information as described in the "Your Rights and Choices" section of this notice. When you make a request, we will verify your identity by asking you to sign into your account or if necessary, by requesting additional information from you. You may also make a rights request using an authorized agent. If you submit a rights request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you have any questions or concerns, you may reach us using the methods described under "Your Rights and Choices" or by emailing us at privacy@hubcap.ai.

11. Children

Persons under the age of 18 are not allowed to create an account or otherwise use the Services. Additionally, if you are located outside the United States, you must be over the age required by the laws of your country to create an account or otherwise use the Services, or we need to have obtained verifiable consent from your parent or legal guardian.

12. Changes to This Policy

We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date at the top of the policy. If the changes, in our sole discretion, are material, we may also notify you by sending an email to the address associated with your account (if you have chosen to provide an email address) or by otherwise providing notice through our Services. We encourage you to review the Privacy Policy regularly to stay informed about our information practices and the ways you can help protect your privacy. By continuing to use our Services after Privacy Policy changes go into effect, you agree to be bound by the revised policy.

13. Contact Us

If you have any questions about this Privacy Policy or wish to exercise any of your rights outlined above, please email us privacy@hubcap.ai or write to us at Hubcap, Inc., PO Box 623, Burlingame, CA 94011-0623.