Hubilo Privacy Policy Fingerprint Privacy

This is the privacy policy (“Policy”) that governs how we, Hubilo Technologies, Inc. and its affiliates (“Hubilo”, “we”, “our” or “us”), use and protect the Personal Information that we collect and/ or receive about natural persons in connection with the use of our website i.e., https://hubilo.com/, its sub-domains, the web applications and mobile applications (“Platform”).
Hubilo is a virtual event hosting Platform which enables hosting of events by Customer/s and connects them with attendees/ participants for providing them Services through the Platform.
In this document, you/your refers to the “User” and/ or the “Customer”. “User/s” as used herein refers to any individual/s and/or entities added to the Platform by the Customer and/ or an individual permitted by the Customer to register, access and/ or use the Platform; the word “Customer” as used herein refers to anyone, subscribing to, registering, accessing or using the Platform as an event organizer/ administrator and who is able to add users/ attendees/ participants to the Platform. Please note that the term “you” under this Policy, shall mean the Customer and hosts/ attendee/ participant etc. individually and collectively, when the context requires.
This Policy applies to all the visitor/s to the Platform. This policy does not apply to any third-party organizations that collect the personal data, including through any third-party application or content that links to or is accessible from our Platform.
Please, read the Policy carefully prior to using or registering or accessing the Platform or availing any Services. By visiting the Platform or setting up an Account on the Platform and clicking on the “I accept” button, You accept and agree to be bound by the terms and conditions of this Policy and consent to our collecting, storing, processing, transferring, sharing and using Your information including the Personal Information in accordance with this Policy. If you do not agree with the Policy please leave the Platform, with no obligation on us.
“Personal Information” means any information about an individual/ natural person from which that person can be identified, directly or indirectly, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. It does not include data where the identity has been removed or anonymous data and this Policy does not apply to such anonymized data or de-identified or aggregated data.

Index

1.

Introduction

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a) Our Statement of Privacy Practice: The Policy describes the commitment of Hubilo to protect and safeguard the privacy of the Customer and the User/s whose data is being collected/ stored/ processed on the Platform by us. This Policy holds great significance to us in terms of protecting your privacy. We are not in the business of selling the Personal Information collected by us from you. We use your Personal Information to provide Services, service your requests, process payments for the Services, communicate with you regarding the Services, to promote our Platform and Services to you, generally maintain the Account with us, and enhance and customize your overall experience on the Platform.
b) This Policy applies to our Platform as well as to of any of our products, services, content, features, technologies, or functions offered on our Website and all related sites, services and applications (if any) (collectively referred to as the “Services”), whether such Services are currently provided or will be provided to our Customers in the future.
c) This Policy aims to help you understand how we protect your Personal Information. By visiting, registering, subscribing to and/ or using our Services, (i) you are expressly consenting to our collection, processing, storing, disclosing and handling of your information as set forth in this Policy, as amended by us from time to time; and (ii) you are accepting the processes and methods utilized as described in this Policy.
d) This Policy is incorporated into and subject to our Terms of Use. Unless otherwise specifically defined in this Policy, the terms defined in the Terms of Use shall apply to this Policy. Terms not defined in the Policy or the Terms of Use shall be deemed defined as per the applicable Agreements or applicable law, as the case may be.
e) The Policy shall apply only with respect to the collection and processing of any Personal Information by us. We are not obligated to render the same level of protection with respect to any Non-Personal and/ or anonymized information or other information provided by you.
f) If You are a resident of the European Economic Area (EEA) and you use the Platform and/ or the Services, for the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”)), with respect to the Personal Information of the Users, the Customer acts as the Data Controller. A data controller determines the purposes for which and the means by which your Personal Information is processed. The Customer has collected/ will be collecting certain information of the User during the registration/ subscription process and access/ use of our Platform by the User. The Customer will be fully accountable for the protection of User’s Personal Information and is mandated by law to take all necessary steps to stay compliant in this respect in accordance with the applicable laws.
g) Please, read this Policy thoroughly to learn the details of what information of yours requires protection, what rights you may have on your Personal Information and how to exercise these rights, what Personal Information of yours is being collected by the Customer, the means by which your Personal Information is processed and the purpose for which it’s collected, how your Personal Information will be used/ stored/ protected/ disclosed/ transferred etc., how you can exercise your rights over your Personal Information, whether your Personal Information will be shared with third parties and the purpose for which it will be shared, where your Personal Information is being stored and how long we intend to keep it, and other related information/ details you may find useful.
h) Any policies in place between you and the Customer with regard to any Personal or Non-Personal information shared shall stand separate from this Policy.
i) With respect to the data of the Customers, collected, stored, processed for registration/ subscription process and access/ use of our Platform, Hubilo shall act as both the ‘data controller’ and the ‘data processor’, in accordance with the GDPR. This document explains how the personal data is collected, the purposes of collection, and how is it used.
2.

Terms of Use

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The Policy is developed as a part of Terms of Use which can be viewed on the Hubilo website. The Terms of Use have been accepted prior to using the Service for the first time.
3.

System for Consent

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a. By agreeing to use our Services, and going through our Policy, Customer/s provide their consent for us to collect, store and process their data as required and the User/s give us their consent to process the data that is collected by the Customer.
b. In case you are an individual who is accessing the Platform as a representative of and on behalf of a legal entity hosting an event, (a) you represent and warrant that you have the full authority to represent the legal entity and have power to bind them; and (b) you understand that the Policy, upon acceptance by you, is applicable to and binds all other persons co-hosting an event and accessing or using the Platform and the Services on behalf of the same legal entity for this purpose.
c. If you are hosting an event, you hereby provide your consent and authorize us to record all events hosted by you, for and on your behalf. If you do not wish any event to be recorded, please communicate such request to us at privacy@hubilo.com at least 15 days in advance and accordingly, we will disable the recording feature of the relevant event. You may, at any time, also instruct us to delete copies of any previously recorded event hosted by you. Upon receipt of such instruction from you, we shall promptly delete all recordings of the relevant event.
d. After updating our policies if the Customer or User continues to access our Platform/Services, then it will be deduced they have readily accepted the revised policies.
e. You have the option to change or withdraw consent with respect to the collection, use, disclosure, processing or storage of Personal Information belonging to you, subject to the rights and exceptions that are applicable to you.
f. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed by you shall lie on Hubilo, nor will we in any way be responsible to verify any information obtained from you.
g. You hereby confirm and shall ensure that all the information provided by you is current, complete, and accurate. If you provide any information that is false, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or if we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we reserve the right to suspend or terminate your Account and refuse any and all current or future use of the Platform (or any portion thereof) at our discretion and/ or the Services, in addition to any right that we may have against you at law or in equity, for any misrepresentation of information provided by you.
4.

What data is collected and/ or stored by Hubilo?

a. Information collected and processed by Hubilo may be classified into Personal Information and Non-Personal Information. Personal Information relates to any personally identifiable information such as your name, email ID, address, contact number, etc. Non-Personal Information can be any information that may not be directly linked and identified as being related to you. Non-Personal Information may be collected when you visit our Website, however, Personal Information is collected only when you provide it to us.
b. We collect and/ or process the following types of Personal Information when you register, subscribe to, access or use our Platform, in order to facilitate your access to our Platform and/or Services and to help improve your experience.
1) We collect a variety of Personal Information including name, e-mail address, contact number; social media account ID from the given sources.
2) Hubilo’s use of Personal Information collected through the Platform shall be limited to the purpose of providing the Services to the Customer/s that have bought our subscription and are currently engaged in using our Services.If you do not agree with our policies at any point, you may choose not to use our Platform and Services.
3) Hubilo Website
For marketing purposes, Hubilo collects the following data: username, job profile, company name, type of the company, e-mail id, contact number, how many events does the Customer conducts per year and if you are interested in our product demo.
4) Hubilo Products
These are the following products that Hubilo provides to the Customer from where attendees’ data is collected by the Customer and stored on our servers:-
• Event Website
• Event App
• Event Marketing
• Event Networking Community
• Event Registrations and Ticketing
5) Customer account
In order for the Customer to use our Services, they may have to create an Account which uses the basic details i.e. name, e-mail id etc.
6) Attendee account
For attendee account, we provide Facebook and LinkedIn social logins which take User’s e-mail id, first name, last name and profile data of LinkedIn.
7) Registration and Ticketing
Users might be buying tickets for an event or registering for the same. Information that you provide while creating an attendee account or registering for that event or using any of its services i.e., buying tickets or attending certain sessions will ask for your Personal Information including name, e-mail id, contact number, and so on. All these information fields are customizable by the sole entity i.e., event organiser/ Customer. In this case, event organizer is solely liable for undertaking the protection of User’s Personal Information.
If you wish to opt out of the registration and ticketing process or stop receiving any e-mails from the event organizer after the event is over, you can unsubscribe to the services.
In case of any doubt or query, please, feel free to contact us or send an email at mydata@hubilo.com.
While registering and buying tickets of an event, the User might be asked to enter the transaction and financial information (credit/ debit card details etc.), used with the services of the third-party organization i.e., Stripe and Razorpay.
Both these third-parties alone are responsible for any financial information of the Customer or User being collected and processed.
Hubilo DOES NOT store any payment related, financial or transactional details of any User.
8) Event Website
Event website may contain “Contact Us” section added by the Customer/ event organizer. The Personal Information collected by them may include name, e-mail id, phone number, designation and so on which are totally customizable by the event organizer.
The event websites also have an option for the User to opt-in for subscriptions such as newsletters from the event organizer through the ‘Subscribe’ box. By opting in for the services, your e-mail id will be used to send you e-mails from the event organizer.
Some event websites may also include an embedded registration form where the User’s Personal Information may be asked viz. name, e-mail id, contact number etc. All these fields are customizable by the Customer alone.
9) Networking Community
While logging into the networking community, the User will have the option to log in through their Facebook and LinkedIn social profiles and only their email id and names will be taken. Hubilo uses cookies in Event Networking Community. To know more please refer to our Cookie Policy given herein below.
Also, the Networking Community Platform has a messaging feature, newsfeed and view profiles for which the Personal Information is used. Customer/ User may create a new post, share content on the newsfeed which may include text, images and videos on the Networking Community Platform.
10) Event App
The App may require a login which will also be from social profiles of Facebook and LinkedIn. While installing an App, certain permissions are required such as access to media files, storage, contacts etc. In case you wish to not provide such access, please, select the option “No”.
11) Analytics
We use the third-party analytics provider i.e., Google Analytics to collect information about the usage of our applications and to help improvise on those applications as required. The information collected is put to use in further developing the application so the User doesn’t have to face any difficulty.
Google Analytics uses cookies and various other technologies to collect information about the usage of the applications and also reports website trends, without storing any Personal Information.
12) Information automatically collected
Certain Personal Information is automatically collected by our systems, in connection with your use of our Services and/ or visit to our Platform through cookies, third-party tools, server logs and other similar technologies. This includes your internet protocol (IP) address, third party tools, browser type and version, software and hardware attributes and information, time zone setting and location, browser plug-in types and versions, internet service provider, cookie information, type of camera, microphone or speakers, device information, operating system and website, browser actions and patterns and other technology on the devices you use to access the Platform and/ or the Services.
5.

How do we use the collected information?

Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience on the Platform. We process your Personal Information and non-Personal Information to create, develop, operate, deliver, and improve the Platform and the Services.
We will not collect any additional categories of Personal Information or use the Personal Information collected by us for materially different, unrelated, or incompatible purposes without seeking your express consent.
a. The Personal Information collected from https://hubilo.com, https://blog.hubilo.com, https://ebook.hubilo.com is used by Hubilo for the following purposes:
i. to send newsletters,
ii. to personalize Platform content and communications based on your preferences, including targeted offers and ads served through the Services;
iii. updates regarding the new product launch,
iv. to provide support and assistance for the Services, to communicate with you about the Services, including Service announcements, notices, updates, changes or offers;
v. marketing and promotional purposes,
vi. to share the Personal Information with any third-party service providers engaged by us, in the course of providing or enabling provision of the Services through the Platform;
vii. to respond to “Contact Us” or any request, inquiries, grievances initiated by you, in providing you with the required feedback, support and assistance in order for you to effectively use our Platform and avail our Service,
viii. to send any notice to You as specified in the Terms of Use or this Policy;
ix. process transactions including purchase of tickets or availing of Subscription Plans, as may be applicable,
x. enable you to create profiles, register for third-party services, participate in discussion groups or online surveys;
xi. to provide, maintain, develop, protect, and improve the Services including testing, research, analysis, and development of new features or products on the Platform or Website by understanding the manner in which you use our Services and the preferences shown by such usage,
xii. to understand your preferences and to enhance and customize your experience of using the Platform;
xiii. to perform data analysis, analyze trends, internal research for technological development;
xiv. to protect against or deter fraudulent, illegal, or harmful actions and maintain safety, security and integrity of the Platform and/ or the Services;
xv. to comply with our legal or contractual obligations, seek professional advice, resolve disputes, and enforce our Terms of Use or this Policy;
xvi. to respond to law enforcement requests as required by applicable law, court order, or governmental regulations; and
b. The information collected by the Customers may be used for advertisements or promotional purposes.
6.

Data Storage

Your Personal Information is stored securely in our servers situated in the European Union within which the processing of your Personal Information takes place.
7.

Your Rights

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a. Customers/ Users have certain statutory rights “Rights”), under GDPR in terms of their Personal Information. You may have a right to:
i. request for access to your Personal Information; ii. request for copies of the Personal Information, subject to a minimal fee as applicable; iii. ensure the Personal Information provided to us is up to date and to request for correction of the Personal Information if found to be inaccurate; iv. withdraw consent or opt-out of certain Services. v. restrict or object to the processing of your Personal Information; vi. get the Personal Information transmitted/ ported to another controller (data portability; vii. delete or erase your Personal Information under certain conditions; viii. not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects/ significant effects on you; ix. lodge a complaint with the relevant data protection authority; and any other right as available to you under the relevant law.
b. The User may contact the Customer at privacy@hubilo.com with respect to any of their Rights as a Data Subject under this Policy.
c. The Customer may contact Hubilo at mydata@hubilo.com with respect to any of your Rights as Data Subject under this Policy. We request a period of one month, to respond to any requests made which can be extended upto two more months depending on the complexity of the request.
d. Hubilio is committed to resolving all disputes in a fair, effective and cost-efficient manner. We seek to resolve any customer concerns through our Grievance cell. All Grievances related to your use of our Services shall be addressed to Mr. Yuvraj Saxena, email: yuvraj@hubilo.com (Grievance officer). Please write us on privacy@hubilo.com The officer will get back to the customer within 36 hours of the receipt of Complaint. Every grievance will be provided with a complaint/ticket no. which can used to track the status of the grievance. Redress or closure to a grievance might take around one month from the date of receipt of complaint. However, if you are dissatisfied with our Grievance redressal mechanism, our privacy policy provide that disputes will be resolved in binding arbitration.
8. Information Shared by Attendee Directly with Host
If the host of an event requests for certain information from the attendee, in addition to the information obtained by the Platform, such information shared by attendee with hosts may include certain special categories of information eg. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning a person’s sexual orientation etc. Please, note that any such information is being provided directly by the attendee to the host and you hereby also consent that you are sharing such information willingly. Hubilo and/ or Platform is in no manner involved in such sharing of information nor shall they in any manner be responsible and/ or liable for the use, misuse, or treatment of such information and this Policy does not govern any such information.
In case you are an attendee and/ or a host, you agree that you are solely responsible for the content displayed/ uploaded by you in using the Services and for complying with all applicable laws pertaining to such content, including, but not limited to, laws requiring you to obtain consent or permission of any third party to use any such content or portion thereof and to provide appropriate notices of third party rights including in respect of any name, identity, likeness or voice, submitted by you during an event. You further represent and warrant that you have the right to upload/ share such content and that such use or reproduction thereof, does not violate or infringe on any rights of any third party, including intellectual property rights.
Further, the host may use the content of the relevant event in any manner as they may deem fit. In case you are an attendee, you hereby grant the host of the relevant event, the right to record, use, reproduce, download, distribute, adapt, publish, display (including recording thereof), globally, any content submitted, displayed, posted or communicated by you while participating in that event, forming part of the content, in any manner and form as may be determined by the host. If you do not wish to provide such right to the host, please, refrain from using the Platform and/ or any Services provided therein.
Your Personal Information is stored securely in our servers situated in the European Union within which the processing of your Personal Information takes place.
8.

Information Shared by Attendee Directly with Host

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If the host of an event requests for certain information from the attendee, in addition to the information obtained by the Platform, such information shared by attendee with hosts may include certain special categories of information eg. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning a person’s sexual orientation etc. Please, note that any such information is being provided directly by the attendee to the host and you hereby also consent that you are sharing such information willingly. Hubilo and/ or Platform is in no manner involved in such sharing of information nor shall they in any manner be responsible and/ or liable for the use, misuse, or treatment of such information and this Policy does not govern any such information.
In case you are an attendee and/ or a host, you agree that you are solely responsible for the content displayed/ uploaded by you in using the Services and for complying with all applicable laws pertaining to such content, including, but not limited to, laws requiring you to obtain consent or permission of any third party to use any such content or portion thereof and to provide appropriate notices of third party rights including in respect of any name, identity, likeness or voice, submitted by you during an event. You further represent and warrant that you have the right to upload/ share such content and that such use or reproduction thereof, does not violate or infringe on any rights of any third party, including intellectual property rights.
Further, the host may use the content of the relevant event in any manner as they may deem fit. In case you are an attendee, you hereby grant the host of the relevant event, the right to record, use, reproduce, download, distribute, adapt, publish, display (including recording thereof), globally, any content submitted, displayed, posted or communicated by you while participating in that event, forming part of the content, in any manner and form as may be determined by the host. If you do not wish to provide such right to the host, please, refrain from using the Platform and/ or any Services provided therein.
9.

Opting Out

Existing Users and Customers have been provided with an option to opt out from our services-related emails, newsletters that are used for marketing purposes. You can choose not to receive such emails by unsubscribing and opt-out of our services, in case of which your data will be deleted from our servers. Please note that for any queries, or in case you want to opt-in to use our services again, or opt out of any event related services, you may contact us on mydata@hubilo.com. However, you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services.
10.

Information sharing with Third Party Organizations

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a. Hubilo may provide your Personal Information to the organizations that provide services and help us in carrying out certain business activities. These activities include mass messaging and e-mailing to the list of Customers, payment processing gateways and sales and marketing software. We will share the Personal Information with the companies in a secure and proper manner as described in the Policy.
These organizations are authorized to use your Personal Information only as and when required so as to provide us with necessary services. We do not permit our third-party service providers to use the Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us. We contractually mandate these Third-Party Organizations to keep such Personal Information confidential and use it only for the purposes for which we disclose it to them.
b. Solely at our discretion, we may share your aggregated anonymized (and de- identified) information with third parties either through the Platform or otherwise, We may also provide Platform level recommendations on matters relating to Services, which may be conducted by us or any Third-Party Service Provider engaged by us for this purpose.
11.

Disclosure of your Personal Information

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We may need to disclose your Personal Information, if required to do so by law or in the good faith belief that such disclosure is reasonably necessary in order to: (a) comply with a legal obligation or legal process; (b) protect and defend our legal rights or property, including to enforce our contracts, policies, this Policy, and Terms of Use; (c) protect the safety of Hubilo, including its employees, representatives, agents, Users, or any person, in an emergency. In such an event, we shall be under no obligation to inform you or seek your approval or consent.
12.

Children’s Privacy

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The services of Hubilo are purely intended to be used and accessed by adults. These services are not to be accessed by children below 16 years of age. If by any chance, such information exists in our systems, we’ll make sure to delete those details at the earliest. If you want to know further details on this clause please contact us on mydata@hubilo.com.
13.

Zoom Data Retention

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For Delivering zoom enabled services such as Live streaming, Breakout rooms and Meetings, Hubilo, shall use some Personally Identifiable Information such as name and email for the Hosts and Speakers which shall be retained in zoom environment for the period of the event and shall be removed manually by your ‘Client Success Manager’ after the event is completed. Creation of a zoom account within Hubilo’s enterprise zoom account does not impact the existing zoom accounts for the hosts and speakers in any manner.
14.

Security

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a. The safety of Personal Information of the users is quite important for us. We ensure that proper measures are taken to safeguard our database of Customer’s and User’s Personal Information.
b. With all the latest physical and technical integrations and methodologies, we tend to to reduce the risks such as loss, misuse, unauthorized access, disclosure. alteration of data and tend to secure the data which also includes encryption of data over the internet.
c. We restrict access to Personal Information of Customers and Users to employees, third party contractors, and other relevant personnel (“Personnel”) on a strictly- need-to-know-basis and ensure such Personnel are subjected to confidentiality and privacy obligations.
d. We review our collection, storage and processing practices from time to time to guard against unauthorized access, processing or use;
e. Please note, however, the transmission of information or Personal Information via the internet is not completely secure. While we make our best efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted on our Platform or Website; and any such transmission is at your own risk.
f. For more details about our security of Services, you can drop a mail at mydata@hubilo.com.
15.

Retention of Data

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a. We will retain your Personal Information for as long as it is necessary to provide you access to the Platform and/or Services. Further, we may also be obligated to retain certain Personal Information under the applicable laws and/or as part of our contractual obligations with third-parties; and accordingly, such Personal Information shall be retained as prescribed under applicable laws or as part of our contractual obligations.
b. We may also retain (i) Personal Information even after the Customer’s account on the Platform is closed, if reasonably necessary to comply with our obligations including law enforcement requests, to meet regulatory requirements, resolve disputes, investigate security incidents, prevent fraud and abuse, enforce our Agreements, or to fulfil your request to “unsubscribe” from further messages from us and/or (ii) anonymized information after your account has been closed and may continue to use your anonymized information aggregated or in combination with anonymized data of other Customers or Users.
16.

Cookie Policy

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Our website uses “cookies” which is a small text file that is mostly used to collect information. In our case, we use cookies as tokens to authorize Users for iframe compatibility. But if the visitor wants to disable cookies, it is possible to so from the browser settings. Most browsers allow the users to control cookies, including whether or not to accept them and how to remove them. However, many of Our Services may not function properly if your cookies are disabled.
17.

Control of the data

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The data being processed by Hubilo remains under the control of the Customer unless the control is shared by a duly signed contract. The liability for the data is limited to the owner of the data.
18.

Data Access and Accuracy

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The Personal Information provided to us is maintained securely and accurately in the database.
19.

Data Deletion

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If you, at any point in time, would like to delete or correct any of your Personal Information that we have stored, you can request access to the same by emailing us at mydata@hubilo.com. You should mention specifically with all the details in a plain, clear format about your request to access your personal information.
20.

Links to Third Party Sites

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Our Platform may link you to other third-party platforms (“Third-Party Sites”) that may collect your Personal Information including your IP address, browser specification, or operating system. We are not in any manner responsible for the security of such information or the privacy practices or content of those Third- Party Sites. Further, You may also encounter “cookies” or other similar devices on certain pages of the Third Party Sites. Please note that the Platform does not control the use of cookies by these Third-Party Sites. These Third-Party Sites may have their own privacy policies governing the storage, processing, and retention of your information that you may be subject to. This Policy does not govern any information provided to, stored on, or used by these Third-Party Sites. When you enter a Third-Party Site, you may review the Third-Party Site’s privacy policy as it relates to safeguarding of your information.
21.

Public Posts and Content Uploaded:

You may share your thoughts, feedback, reviews, appreciation, information critique, testimonials, etc. on the Platform during an event or on use of the Services (“Posts”). Any content that you upload or Personal Information (viz, Your name, designation, name of the company, etc.) and Posts shared by you on the publicly viewable portion of the Platform (eg, lounges, etc.) are viewed by other Users/ visitors on the Platform. Your Posts and other content uploaded by you shall have to comply with the terms and conditions given in the Terms of Use.
Your Posts/ other content may be deleted, partly or fully, if it is found to be not complying with the Terms. Your Posts may be used, reproduced and shared for any purpose and in any manner as may be determined by the Customer in its sole discretion and responsibility. If Posts are deleted by you from the Platform, please note that copies of such Posts may remain viewable in archived pages, or such Posts may already have been copied or stored by other Users.
22.

Governing Law

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This Policy is published and shall be governed by and construed in accordance with the applicable laws of Delaware as amended from time to time, without reference to conflict of laws principles. The courts in Dover, Delaware, shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Policy.
23.

Amendment

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We’ll keep updating the Policy as and when required by applicable laws, or when we adopt new regulations or when there are changes in the Hubilo Platform.
Amendments may be made to this Policy without prior notification to you. To make sure that you are aware of any amendments, kindly review this Policy periodically.
For any queries or concerns, and to exercise any of the data subject rights, email us at privacy@hubilo.com or reach out to our Data Protection Officer (DPO).
DPO Name: Yuvraj Saxena
DPO Email Address: mydata@hubilo.com

California Consumer Privacy Act (“CCPA”) Addendum

If the Personal Data of California citizens are involved the following addendum shall apply to the aforesaid Data Protection Agreement.

This Addendum sets forth the terms and conditions relating to compliance with the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq., (“CCPA”) and related regulations, as may be amended from time to time. Except as otherwise modified by this CCPA Addendum, all provisions of the MSA and DPA shall remain in full force and effect.
1.

Definitions

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The terms used in this Addendum, including without limitation consumer, personal information, collect, and process, shall have the same definition as set forth in the California Consumer Privacy Act, as amended (CCPA), except as otherwise defined in this Addendum.

1.1 “CCPA” means the California Consumer Privacy Act of 2018, including amendments and final regulations.
1.2 “Personal Information” has the same meaning given to such term under section 1798.140 the CCPA and is limited to information that identifies relates to describes is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular California consumer or household and that is disclosed to Hubilo by the Customer to provide Services under the MSA
1.3 “Commercial Purposes,” “Sell,” and “Service Provider” have the meanings assigned to them in section 1798.140 of the CCPA.
2.

Relationships of the Parties

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2.1 Subject to the terms of this CCPA Addendum, Hubilo will act as Customer’s Service Provider solely with respect to Personal Information.
2.2 Hubilo agrees it is a “service provider” as that term is defined under the CCPA. Hubilo shall ensure any and all Personal Information in any format accessed, collected, created, processed, and/or disclosed in connection with or related in any way with its performance of the services, including without limitation collecting such information on the Customer’s behalf, is of a confidential nature, and that Hubilo shall safeguard and hold all such Personal Information in confidence as described in this Addendum, and shall not be disclosed except when disclosure is required by law, is required in order to perform the services, or where the Customer has authorized Hubilo in writing to disclose it.
2.3 Hubilo represents and warrants it will, and cause any and all of its agents and subcontractors to, comply with all of the following duties and obligations as they relate to such Personal Information.
3.

Restrictions

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3.1 Hubilo will not: (i) Sell Personal Information or (ii) collect, retain, use, or disclose Personal Information for any purpose other than for the specific purpose of performing the services specified in the MSA, including collecting, retaining, using, or disclosing Personal Information for any Commercial Purpose other than providing the services specified in the MSA unless otherwise permitted under the CCPA.
4.

Security and Breach

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4.1 Hubilo shall implement and maintain security procedures and practices to ensure protection of Personal Information from unauthorized access, destruction, use, modification or disclosure.
4.2 Hubilo shall notify the Customer without undue delay upon discovering an actual or suspected breach of the security of its systems affecting Customer Personal Data, as defined in Cal. Civ. Code Sec. 1798.81.5(d)(1)(A), and provide the Customer with sufficient information to allow the Customer to assess the nature and scope of the incident or breach, and meet its obligations, if any, to report the breach under applicable data protection laws.
4.3 In cooperation with Customer, Hubilo shall investigate such incident or breach and take all necessary, appropriate, and commercially reasonable corrective action to remedy such incident or breach and prevent a recurrence of same.
5.

Return and Deletion

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5.1 Hubilo shall promptly delete and procure the deletion of all copies of Customer Personal Data per the terms mentioned in the DPA.
6.

Consumer Requests

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6.1 Hubilo agrees to provide commercially reasonable assistance to enable the Customer respond to and comply with verifiable Consumer requests concerning such Personal Information pursuant to the CCPA.
6.2 Hubilo shall notify the Customer without undue delay of any request from a person seeking to exercise any rights under the CCPA and shall not act on such request unless Hubilo has received written authorization from the Customer.