Privacy Policy - Hub Analytics

HUB Analytics, LLC’s Privacy Policy

This Privacy Policy (“Privacy Policy” or “Policy”) explains how HUB Analytics, LLC (“Company” , “We” , “Us” or “Our”) may gather, collect, record, hold, distribute, share, disclose, or otherwise use any information or data about any user (“User” or “You” or “Your”) of the Company’s website at https://hub-analytics.com/ (“Company Website”) or through any other site, program, activity, technology platform, technology application, or service offered by Company (the Company Website and these other programs, activities, platform, applications, and services are collectively referred to as “Company Program(s)”).

BY CONTINUING TO USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM OFFERED BY THE COMPANY, YOU HEREBY AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AS IT IS PRESENTED TO YOU AS OF THE DATE OF YOUR FIRST USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM.

NO CHANGES (ADDITIONS OR DELETIONS) BY YOU TO THIS PRIVACY POLICY WILL BE ACCEPTED BY THE COMPANY. IF YOU DO NOT AGREE TO ALL THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, OR YOU DO NOT WISH YOUR PERSONAL INFORMATION TO BE USED PURSUANT TO THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE ANY OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM, AND YOU SHOULD NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO THE COMPANY.

THIS IS A BINDING CONTRACT BETWEEN YOU AND THE COMPANY, AND YOU SHOULD DOWNLOAD AND PRINT THIS PRIVACY POLICY FOR YOUR RECORDS.

This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline (collectively, the “Services,” including of Our website at https://hub-analytics.com/ all corresponding webpages, software applications or mobile applications that link to this Privacy Policy (collectively, the “Site”), and when you interact with our advertising and applications on third-party websites and services, if the advertising and applications include links to this Privacy Policy.

By using this Site or our Services, you agree to the collection and use of your personal information in accordance with this Privacy Policy and our Terms of Use. If you do not agree to all of the terms of this Privacy Policy or the Terms of Use, then you should not use or access our Site or Services.

We may update this Privacy Policy from time to time and make changes to information previously collected, as permitted by law. If we make material changes, we will post the updated Privacy Policy on this page with an “Updated” effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our Services.

Please note that our Site may contain links to third-party websites, such as delivery services and social media pages. These links are intended for your convenience only. These third-party websites and services are not related to Company and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage users to read the privacy policies of all websites they visit.

1. Information We Collect

When you access or use Our Services, We may, either directly or by using Our service providers, gather, collect, record, hold, distribute, share, disclose or otherwise use personal information about you which you provide to Us. Personal information is any information that relates to you, identifies you personally, or could be used to identify you including, but not limited to: your name, mailing address, email address, telephone number, or any other information. Personal information does not include anonymized or aggregated information. The types of personal information that we may collect about you are described below.

1.1. INFORMATION YOU VOLUNTARILY PROVIDE TO US.

We collect personal information that you voluntarily provide to Us when you:

complete forms on the Site, or in relation to our Services, or you contact Us via telephone;
create an account with Us;
purchase or otherwise request any of the Company’s products or services;
request any customer support;
request any exchange or return of any of the Company’s products or services;
request any information from or about the Company, such as a newsletter, e-alert, or any other information about Our products, services, events or business partners;
communicate with any other representative of our Company;
communicate with Us via third-party social media sites;
participate in any contest, promotion or sweepstakes offered by Us;
maintain employment with the Company;
apply for a job with the Company; or
otherwise communicate with Us in any other way.

In these instances, the types of personal information that We may collect from You may include:

Your name;
Alias;
Unique personal identifier;
Online identifier;
IP address;
Account name;
Mailing address and/or billing address;
E-mail address;
Phone (or mobile) number;
Date of birth or age;
Gender;
Information you provide when you purchase any of our goods or services, including product or service parameters or preferences you provided when making a purchase;
Information regarding products or services purchased, obtained or considered;
Information you provide when you report a problem with our Site or a purchase or other transaction with Us by email, Our Site, telephone, in writing or through other means.
Records and copies of your correspondence (including email addresses), if you contact Us;
Transaction history with Us;
Browsing history, search history and information regarding interactions with our website; or
Inferences regarding which products, services or business partners that customers may be interested in.

1.2. INFORMATION WE COLLECT BY OTHER MEANS

1.2.1. INFORMATION AUTOMATICALLY COLLECTED

When you access or otherwise use Our Site or Services, We automatically collect certain personal information about you, including:

Device Information. We (or our service providers) may collect information about the computer, tablet, phone or other device you use to access any of the Services, including the Internet Protocol address, hardware models, operating system and version, mobile network information and other unique device identifiers.
Interaction with Website. We (or our service providers) may collect information about your browsing history and interaction with Our Site.
Cookies and other Web-based Tracking Technologies: We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by your web browser on your computer or mobile device (hard drive) that helps Us to improve the way We deliver our Services to you, helps Us improve your overall experience using Our Services, and/or helps Us analyze the areas and features of our Services that are most popular or to detect fraud. Web beacons are electronic images that may be used in Our Services or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or our service providers) during your visit to the Sites or other Services in order to improve your individual experience as a user of Our Site and Services, or to generally improve or enhance the overall functionality of the Services.
Geo-location Data: Subject to your device permissions, We (or Our service providers) may be able to collect information about the location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”), to customize our Services based on your location. You can prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data, at any time through your device’s operating system settings.
Social Media Information. If any of Our Services offer any social media features, such as the Facebook Like buttons or similar social media interactive mini-programs, these features may collect your Internet Protocol address, which page you are visiting on Our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third-party or hosted directly on Our Services. Your interactions with these features maybe governed by the privacy policies of the company providing it.

1.2.2. INFORMATION WE RECEIVE FROM THIRD PARTIES IF APPLICABLE TO FURTHER INFORMATION

We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of Our Services to you, and prevent or detect fraud.

We may also collect personal information about you that we receive from our partners, group members or other third parties. For example, if you intend to, or make, a purchase from Us, we may receive information about your creditworthiness from Our financial service providers; or if you visit one of Our social media accounts, the respective provider may provide Us with statistical information regarding your use of Our account. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.

1.2.3 THIRD PARTY COLLECTION VIA WEBSITE

A number of third-party companies may collect personal information about you during your use of Our Site, through the use of pixels. These third parties are generally advertising / marketing partners, social media partners or analytics providers. The following is a non-exhaustive list of these third parties, along with links to their specific privacy policies:

______________________

Privacy policies for these third-parties can be obtained via the specified links. The type of personal information gathered directly by these third parties includes IP address, unique personal identifier, online ID, consumer history / tendency, geolocation, interaction with the website and preferences, characteristics, and behavioral information.

THIS PRIVACY POLICY ONLY APPLIES TO THE COMPANY WEBSITE AND THE OTHER COMPANY PROGRAMS DIRECTLY OWNED BY THE COMPANY. THEREFORE, THIS PRIVACY POLICY: (A) DOES NOT DESCRIBE THE PRIVACY POLICIES OF ANY OF THESE THIRD PARTY SITES; AND (B) DOES NOT GOVERN THE COLLECTION OR USE OF YOUR PERSONAL INFORMATION BY THE THIRD PARTY SITES. THE COMPANY IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF THESE THIRD PARTY SITES. IF A USER CLICKS ON A LINK TO, OR IS SENT TO A LINK OF, OR OTHERWISE GAINS ACCESS TO, A THIRD PARTY SITE, THE USER SHOULD REVIEW THE PRIVACY STATEMENTS OR POLICIES OF SUCH THIRD PARTY SITES (IF ANY) TO DETERMINE THAT PARTICULAR THIRD PARTY SITES’ PRACTICES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION.

WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, EACH USER AGREES THAT IF THE USER USES ANY THIRD PARTY SITES IN ANY WAY, THE USER IS AWARE THAT ANY OF THE USER’S PERSONAL INFORMATION THAT THE USER PROVIDES TO THAT THIRD PARTY SITE MIGHT BE READ, COLLECTED, SHARED, DISTRIBUTED, OR OTHERWISE USED BY OTHER USERS OF THAT THIRD PARTY SITE OR BY ANY OTHER THIRD PARTIES, AND COULD BE USED TO SEND THE USER UNSOLICITED MESSAGES. THE COMPANY IS NOT RESPONSIBLE FOR ANY PERSONAL INFORMATION THAT THE USER ELECTS TO SUBMIT IN, OR OTHERWISE MAKE AVAILABLE TO, THESE THIRD PARTY SITES.

1.2.4. Exclusions from personal information subject to this privacy policy

Personal information for purposes of this privacy policy does not include any of the following types of information: (i) publicly available information from government records; (ii) de-identified or aggregated consumer information; or (iii) any information that, pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), is excluded from CCPA’s governance.

2. How We Use Your Information

2.1. PRIMARY WAYS WE USE YOUR INFORMATION.

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use or share your personal information include to:

Service delivery and operations. We may use your personal information to:

Provide you with the Company Product, create your account and manage our relationship with you
Run and manage our business, including resolving billing and financial disputes
Evaluate your eligibility for marketing offers, products and services
Provide features to you, such as your free credit reports and scores
Provide a product or service that you have requested through the Company Product
Connect you with experts and other users
Communicate with you, such as sending you electronic notifications concerning your financial privacy
Understand your needs and interests, and personalize your experience with the Services and our communications.
Provide you with support and resolve disputes
Authenticate your identity
Manage event registrations and attendance, including sending related communications to you
Register visitors to our offices for security reasons and manage non-disclosure agreements that visitors may be required to sign

Research and development. We may use your personal information to:

Improve and develop our products and services by analyzing how they are used and interacted with, by training our artificial intelligence models and other machine learning models, as well as by assessing the use of and interactions with our Platform and certain content our customers send or display through the Platform, including by conducting data analytics to develop insights about you, your needs, and your preferences, so we can make more informed predictions, recommendations, and products for our customers
Combine and anonymize information about your interactions with Us or Our Products to create aggregate, anonymized statistics for use in research (including by contracting with academic institutions) and for marketing, promoting, improving, and developing our platform

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes to:

Market services, products and experiences, including to deliver gifts and promotional materials, product recommendations and other non-transactional communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences.
Personalize your experience and tailor recommendations, advertising, and offers presented to you, including through the development of insights about you and your needs based on your interactions with the Company Products, services, and offerings. These advertisements may be displayed to you on Our digital properties, including our websites and mobile apps, media platforms, connected devices, or other third-party platforms and channels.

Whistleblower Reporting. When you report any concern of non-compliance, unethical conduct, or other alleged violation of our Code of Conduct and Ethics personal information you provide will be processed as a part of the investigation of the allegations and retained in accordance with our internal policies until the investigation is complete. While we make every effort to maintain confidentiality, depending on the investigation, disclosing your identity to other individuals may be necessary.

Compliance and protection. We may use your personal information to:

Protect against misuse or abuse of our Services and ensure compliance with our Terms of Service, including in relation to content our customers send or display through the Platform
Comply with legal and regulatory requirements
Protect the rights, property, safety or security of the Company Product, our customers, employees or others and prevent fraudulent or illegal activity
Exercise our rights in the course of judicial, administrative, or arbitration proceedings
Enforce, remedy, or apply our Terms of Service or other agreements

With your consent. In some cases, we may specifically ask for your consent to use your personal information, such as when required by law.

We may process your personal information for other purposes that are compatible with the above purposes where permitted by applicable law.

Automated processing. To provide you with valuable personalized advice, recommendations and experiences, and to improve and develop our products and services, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the Company Product.

Inferences. We may make inferences about you based on other personal information we have collected or otherwise received about you.

Connect consumers with companies and customer offers for relevant products or services;
Send support and administrative messages, and respond to your comments, questions, and customer service requests;
Communicate with you about products, services, offers, and events offered by Us and others, and provide news and information We think will be of interest to you, subject to the applicable law;
Monitor and analyze trends, usage, and activities in connection with Our Services;
Personalize your experience and the advertisements and content you see when you use any Services based on your preferences, interests, and browsing and purchasing behavior;
Comply with applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting), or as may be requested under any subpoena;
Keep you secure and safe while using Our Services, which requires Us to process your personal information to combat spam, malware, malicious activities or security risks;
Improve and enforce Our security measures;
Carry out any other purpose described to you at the time your personal information is collected; or
Use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law or regulation (including without limitation tax reporting).

3. Sharing And Disclosure Of Information

We may share or disclose your personal information in the following circumstances, and in all countries mentioned within this Policy:

Affiliates and Subsidiaries. We may disclose your information with Our affiliates or subsidiaries for any of the purposes described herein.
Business Partners. We may disclose your information with Our Business Partners to connect interested consumers with the Business Partners for offers relating to relevant products or services.
Service Providers and Contractors. We may share or disclose your personal information with Our service providers, Our contractors or other third-party vendors that We retain in connection with the provision of the Services, including without limitation the following types of service providers that We may engage:
- Email, internet or other telecommunication service providers;
- Cloud, other data storage, or other hosting service providers;
- Third-party payment service providers, including without limitation third-party credit card processors (see Third-Party Application Providers below);
- Analytics companies who assist Us with various types of data analytics (see Analytics Partners below);
- Third party shippers; or
- Other third-party contractors we engage to assist Us in providing Our Services.
Third Party Application Providers. If a third-party application is used to support Our Services We may share or disclose your information to such third-party application providers, including without limitation third-party credit card processors or other third-party payment service providers.
Analytics Partners. We may use analytics services provided by a third-party analytics service provider or by using one of their tools, such as but not limited to Google Analytics, to collect and process certain analytics data. These services may also collect data about your use of other websites, apps, and online resources. Google Analytics is a web analytics service offered by Google LLC, a corporation domiciled in the USA (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com/privacy. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: tools.google.com/dlpage/gaoptout.
Advertising Partners. We may work with third-party advertising companies (collectively, “Advertising Partners”) to provide you with advertisements or other information that We think may interest you. These Advertising Partners may set or access their own cookies, pixel tags or similar technologies on Our Site and Services or they may otherwise collect or have access to data about you which they may collect over time and across different online services. These Advertising Partners may also provide Us with their own independent data about potential customers and such data could include data about you previously collected by the Advertising Partner.
Social Media Features. Our Services may offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let you share actions that you take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings you establish with the entity that provides the social sharing feature.
Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer your personal information to the Company’s professional advisors such as attorneys or accountants (“Outside Professionals”), other advisors, potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another company or We sell, liquidate, or transfer all or a portion of Our assets. The use of your personal information following any of these events will be governed by this Privacy Policy.
As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose your personal information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to your requests; or (iv) protect your, Our, or others’ rights, property, or safety. We may be required to disclose your information to (a) taxing authorities as part of our tax reporting requirements, or (b) law enforcement authorities or other governmental agencies or via subpoena;
Company’s Outside Professional Advisors. We may share or disclose your personal information with any of the Company’s Outside Professionals to facilitate the professional advice from those Outside Professionals;
Consent. We may also share or disclose your personal information with your permission.

4. Your Choices

4.1. COMMUNICATION PREFERENCES

To provide Our Services to you We may send you communications related to your transactions, security, or the administration of the Site. From time to time We may also send you other messages or updates about Company, our Site, and promotions or other activities. If you do not wish to receive non-transaction/non-security related communications from Us, you may opt-out by clicking the “unsubscribe” link in the communication you received from Us, or send an email message to privacy@hub-analytics.com stating that you no longer want to receive these communications directly from Us (“Opt-Out”). Please note that Opt-Out and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior Company Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to Opt-Out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

4.2. CORRECTION

You have the right to correct your personal information that you shared with Us on our Site or Services. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You are solely responsible for correcting, updating, or modifying any and all of your personal information as it appears in, and as otherwise stored by Our Services.

4.3. DO NOT TRACK: SPECIAL ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

Some Internet browsers, such as Internet Explorer, Firefox, and Safari include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, Our Site does not currently process or respond to “DNT” signals.

5. Children

5.1 COPPA Notice.

This Company Website and other Company Programs are not directed to children under the age of 13. We adhere to the U.S. federal Children’s Online Privacy Protection Act (“COPPA“) and will not knowingly register or otherwise collect any Personal Information from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Information to the Company. If You have reason to believe a child under the age of 13 has provided the Company with any Personal Information, please contact the Company at privacy@hub-analytics.com and request that such information be deleted from Our records.

5.2 User Age Confirmation

By using the Company Website or any other Company Program, You represent that You are at least the age of majority in Your state or province of residence, or that You are the age of majority in Your state or province of residence and You have given Us your consent to allow any of Your minor dependents to use Our Company Website or other Company Program.

6. Data Security

We have implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to Us is stored on Our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of Our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although We do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted to Our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

7. International Transfers Of Personal Information

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to Us, please note that We transfer the data, including personal information, to the United States, the UK and/or the EEA and process it there.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws and ensuring the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Services.

8. Additional Notices And Disclosures Under Specific Laws To California Residents

NOTICE TO CALIFORNIA RESIDENTS: Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), residents of the State of California (“California Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all California Residents as set forth in Appendix 1 of this Privacy Policy.

NOTICE TO COLORADO RESIDENTS: Under the Colorado Privacy Act (the “CPA”), residents of the State of Colorado (“Colorado Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Colorado Residents as set forth in Appendix 2 of this Privacy Policy.

NOTICE TO CONNECTICUT RESIDENTS: Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”), residents of the State of Connecticut (“Connecticut Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Connecticut Residents as set forth in Appendix 3 of this Privacy Policy.

NOTICE TO NEVADA RESIDENTS: Under Nevada Revised Statues Section 603A., et. seq., residents of the State of Nevada (“Nevada Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Nevada Residents as set forth in Appendix 4 of this Privacy Policy.

NOTICE TO UTAH RESIDENTS: Under the Utah Consumer Privacy Act (the “UCPA”), residents of the State of Utah (“Utah Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Utah Residents as set forth in Appendix 5 of this Privacy Policy.

NOTICE TO VIRGINIA RESIDENTS: Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”), residents of the State of Virginia (“Virginia Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Virginia Residents as set forth in Appendix 6 of this Privacy Policy.

9. Communicating With The Company

We welcome your questions and comments about this Privacy Policy. You can contact HUB Analytics by emailing us at: privacy@hub-analytics.com.

Appendix 1

CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if You are a resident of California You have the following rights with respect to Your Personal Information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.

Personal Information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to You, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of Personal Information We have collected about You; the categories of sources from which We collect Personal Information; Our business or commercial purpose for collecting, disclosing, sharing, or selling Personal Information; the categories of third parties to whom We disclose, share, or sell Personal Information, if any; and the specific pieces of Personal Information We have collected about You. Personal Information includes “sensitive” Personal Information as described below.

1.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.

“Sensitive” Personal Information as defined in the CCPA is Personal Information that reveals: (a) Your Social Security, driver’s license, state identification card, or passport number; (b) Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) Your precise geolocation; (d) Your racial or ethnic origin, religious, or philosophical beliefs, or union membership; (e) the contents of Your mail, email, and text messages unless We are the intended recipient of the communication; and (f) Your genetic data. “Sensitive” Personal Information also includes biometric information that is processed for the purpose of identifying You, information that is collected and analyzed concerning Your health; or Your sex life or sexual orientation.

You have the right to know the categories of “sensitive” Personal Information We have collected about You, the categories of sources from which We collect Personal Information, Our business or commercial purpose for collecting, selling, or sharing “sensitive” Personal Information, the categories of third parties with whom We sell or share “sensitive” Personal Information, if any, and the specific pieces of “sensitive” Personal Information We have collected about You.

1.3 Right to Delete Your Personal Information

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to deletion of Your Personal Information from Our records, and to have Us direct Our Service Providers/Contractors and third parties to delete Your Personal Information from their records.

We are not required to, and reserve Our right to not delete Your Personal Information if it is necessary to: (i) complete the transaction for which the Personal Information was collected, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us; (ii) help to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent; (vii) enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us and compatible with the context in which You provided the information; and (viii) comply with a legal obligation.

1.4 Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to correct any inaccurate Personal Information in Our records, and to have Us direct Our Service Providers/Contractors and third parties to correct any inaccurate Personal Information from their records.

If We cannot verify Your identity pursuant to the CCPA and its regulations, We may deny a request to correct. In such event, We shall inform You that Your identity cannot be verified.

In determining the accuracy of the Personal Information that is the subject of Your request to correct, We shall consider the totality of the circumstances relating to the contested Personal Information. We may deny Your request to correct if We determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination

You have the right to not be discriminated against by Us because You exercised any of Your rights under the CCPA. This means We cannot, on the basis of the exercise of Your rights thereunder, among other things, deny goods or services to You, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to You; or suggest that You will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against You as an employee, applicant for employment, or independent contractor.

1.6 Right to Opt-Out of the Sharing of Personal Information

We may disclose Your Personal Information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). This means the targeting of advertising to You based on Your Personal Information that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may Share Personal Information with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the Sharing of Your Personal Information and You may exercise Your right by clicking the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the Sharing of Your personal information, We will refrain from Sharing Your Personal Information, unless You subsequently provide express authorization for the sharing of Your Personal Information.

1.7 Right to Opt-Out of the Sale of Personal Information

We may disclose Your Personal Information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sales” under the CCPA. We may Sell Personal Information to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or any other Company Programs and/or to recommend Our products/services to You based on Your activity on other websites or apps. You have the right to opt-out of the Sale of Your Personal Information and You may exercise Your right by clicking on the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the Sale of Your Personal Information, We will refrain from Selling Your Personal Information, unless You subsequently provide express authorization for the Sale of Your Personal Information.

1.8 Right to Limit the Use of “Sensitive” Personal Information[OPTION No.1: We use Your “sensitive” Personal Information only to the extent that it is necessary to provide Our products/services as reasonably expected by You. If We were to use Your “sensitive” Personal Information other than is necessary to provide Our products/services, You would have the right to limit Our use of Your “sensitive” Personal Information to that which is necessary to provide Our products/services to You.] [OPTION No. 2 We may use Your “sensitive” Personal Information for purposes other than is necessary to provide Our products/services as reasonably expected by You. For example, We may share Your “sensitive” Personal Information with Advertising Networks that may use such information to target advertising to You. You have the right to limit Our use of Your “sensitive” Personal Information to that which is necessary to provide Our goods and services to You by clicking on the following link: https://hub-analytics.com/do-not-sell-my-personal-info/.]

1.9 Right of Children to Opt-In to the Sale of Personal Information

We do not knowingly collect or sell the Personal Information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their Personal Information, We have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, We require the consumer to affirmatively authorize the sale of the consumer’s Personal Information. In order to opt-in minors in this age range, as part of the account registration process for Our products which may be targeted toward minors, We require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which We have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, We require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for Our products/services s which may be targeted toward minors, We require that the consumer’s parent or guardian verify the consumer’s identity, which We have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete Your request if We cannot verify Your identity. If You are a parent or guardian seeking to opt-out on behalf of their child, please email Us at privacy@hub-analytics.com with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix A, please submit Your request to Us at privacy@hub-analytics.com with the subject “CCPA Consumer Request.”

In order to verify Your request, We will need You to provide Us with enough information to identify You (e.g., Your full name, address, and customer or matter reference number), proof of Your identity and address (e.g., a copy of Your driver’s license or passport and a recent utility or credit card bill), and a description of what right You wish to exercise along with any information to which Your requests relates. If feasible, We will match the identifying information provided by You with the personal information that We already maintain about You.

You may designate an authorized agent to make a request under the CCPA on Your behalf. In order to fulfill Your request to know or delete submitted by an authorized agent, You must provide the authorized agent written permission to do so, and We may require that You verify Your own identity with Us directly.

We reserve Our right not to grant a consumer request if We cannot verify that the person making the request is the person about whom We have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of Personal Information twice within a 12-month period. Any Personal Information We collect from You to verify Your identity in connection with Your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES

A description of the Personal Information that We collect online and off-line is provided in Section 1 of the main Policy.

The purposes for which We collect and use Personal Information are described in Sections 1, 2, 3 and 5 of the main Policy.

Sources from which We receive Personal Information are described in Section 1 of the main Policy.

Our Personal Information disclosure practices are described in Section 1, 2, 3, and 5 of the main Policy.

Our Personal Information retention practices are described in Section 10 of the main Policy.

3.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

Category of Personal Information.	Collected	“Sold” or Shared in the Past 12 Months?	*Categories of Third Parties to Whom Sold or Shared (as such terms are defined in this Privacy Policy)*	Disclosed for a Business Purpose in Past 12 Months?	*Categories of Third Parties to Whom Disclosed (as such terms are defined in this Privacy Policy)*
Individual Identifiers.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Categories Described in California Consumer Records Act, CA Civil Code §1798.81.5.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Characteristics of protected classifications under California or federal law.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Commercial information.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Biometric information.	No	No	Not Applicable	No	Not Applicable
Internet or other electronic network activity.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Geolocation data.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Professional or employment-related information.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Education information.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Inferences drawn from any of the information identified above.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals

3.2 Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

Category of Sensitive Personal Information.	Collected	Shared or Sold in the Past 12 Months?	Categories of Third Parties to Whom Shared or Sold (as such terms are defined in this Privacy Policy)	Disclosed for a Business Purpose in Past 12 Months?	*Categories of Third Parties to Whom Disclosed (as such terms are defined in this Privacy Policy)*
Social Security, Driver’s License,State ID, or Passport Number.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Account Log-in and Password	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Financial Account, Debit Card, Credit Card Number and account access information.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Precise Geolocation.	Yes	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals	Yes	Affiliates;Related Parties; Service Providers/Contractors (as such term is fully defined in Section 3 of the main Privacy Policy);Government Entities;andOutside Professionals
Racial or ethnic origin, religious or philosophical beliefs or union membership.	Yes	Yes	Not Applicable	No	Not Applicable??
Contents of email, text messages unless We are intended recipient.	Yes	Yes	Not Applicable	No	Not Applicable??
Genetic Data	No	No	Not Applicable	No	Not Applicable??
Biometric Information for purpose of identification.	No	No	Not Applicable	No	Not Applicable??
Health information collected and analyzed.	No	No	Not Applicable	No	Not Applicable??
Sex life or sexual orientation collected and analyzed.	Yes	Yes	Not Applicable	No	Not Applicable??

4. OTHER CALIFORNIA PRIVACY RIGHTS

4.1 Shine the Light Request.

Individual consumers who reside in California and have provided Us with their Personal Information may request information about Our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must include Your name, street address, city, state, and zip code, and be submitted to Us at: privacy@hub-analytics.com with the subject “California Shine The Light Request.” Within thirty (30) days of receiving such a request, We will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve Our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2 Minor’s Right to Remove Posted Content.

If You are a California resident under the age of 18, and a registered User of any website where this Policy is posted, California Business and Professions Code Section 22581 permits You to request and obtain removal of content or information that You have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@hub-analytics.com with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Appendix 2

COLORADO PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

5. YOUR COLORADO PRIVACY RIGHTS

Under the Colorado Privacy Act (the “CPA”) if You are a resident of Colorado, acting only in an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the CPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

the categories of Personal Data that We collect or process (Section 1);
the purposes for processing the Personal Data (Sections 1,2 and 3);
the categories of Personal Data shared with third parties (Sections 1, 2 and 3 in Appendix 1))
the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 in Appendix 1)
Our sale of Personal Data to third parties or targeted advertising (Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising, (b) sale of Personal Data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by clicking the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our products/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by clicking on the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their Personal Data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; (b) the processing of genetic or biometric data for identification purposes and (c) Personal Data from a known child. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

6. HOW TO EXERCISE YOUR CPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 2, please submit Your request to Us at privacy@hub-analytics.com with the subject “CPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Colorado Attorney General at https://complaints.coag.gov/s/?varCFT=2 or (720) 508-6000.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

You may designate another person to serve as Your authorized agent and act on Your behalf. We will comply with an opt-out request received from an authorized agent if We are able to verify, with commercially reasonable effort, Your identity and the authorized agent’s authority to act on Your behalf.

Appendix 3

CONNECTICUT PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

1. YOUR CONNECTICUT PRIVACY RIGHTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if You are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, nonprofit or governmental entity), Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the CDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix A describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

the categories of Personal Data that We collect or process (Section 1);
the purposes for processing the Personal Data (Sections 1, 2 and 3);
the categories of Personal Data shared with third parties (Sections 1, 2 and 3 in Appendix 1))
the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 in Appendix 1 )
Our sale of Personal Data to third parties or targeted advertising (Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data, except if doing so would require Us to reveal a trade secret.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

1.6 Right to Opt Out.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our services/products to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status; (b) the processing of genetic or biometric data for identification purposes; (c) Personal Data from a known child (individual under the age of 13); precise geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

2. HOW TO EXERCISE YOUR CDPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 3, please submit Your request to Us at privacy@hub-analytics.com with the subject “CDPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Connecticut Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page or (860) 808-5318.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CDPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

Appendix 4

NEVADA PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

Under Nevada Revised Statues Section 603A., et. seq., residents of Nevada have certain rights with respect to the Personal Information that We collect on the Company Website.

The categories of Personal Information that We collect and the categories of third parties with whom We share Personal Information are described in the chart in the above Appendix 1 under the California Privacy Rights Notice.
You may review and request changes to the Personal Information that We collect or process on the Company Website by sending an e-mail to privacy@hub-analytics.com
Any material changes to this notice shall be posted in this Appendix 4 to this Privacy Policy.
When You use the Company Website, We may share Personal Information about Your online activities over time and across different internet sites or online services with third parties.

Appendix 5

UTAH PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

1. YOUR UTAH PRIVACY RIGHTS UNDER THE UTAH CONSUMER PRIVACY ACT

Under the Utah Consumer Privacy Act (the “UCPA”) if You are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the UCPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix A describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices in general, including:

the categories of Personal Data that We collect or process (Section 1);
the purposes for processing the Personal Data (Sections 1,2 and 3);
the categories of Personal Data shared with third parties (Sections 1, 2 and 3 in Appendix 1)
the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 in Appendix 1)
Our sale of Personal Data to third parties and processing of Personal Data for targeted advertising (Section 3 in Appendix 1 , therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising” )

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising or (b) sale of Personal Data.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising and You may exercise Your right by clicking the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising, We will refrain from processing Your Personal Data for targeted advertising, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our products/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin; religious beliefs; sexual orientation; citizenship or immigration status; or medical history, mental or physical health condition, or medical treatment or diagnosis by a health care professional; (b) the processing of genetic or biometric data for identification purposes and (c) specific geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or guardian.

2. HOW TO EXERCISE YOUR UCPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 5, please submit Your request to Us at [email address] with the subject “UCPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within 45 days of receipt of Your request.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the UCPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

Appendix 6

VIRGINIA PRIVACY RIGHTS NOTICE

Effective Date: 20 oct, 2023

1. YOUR VIRGINIA PRIVACY RIGHTS UNDER THE VCDPA

Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”) if You are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), You have the following rights with respect to Your Personal Data.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the VCDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix A describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

the categories of Personal Data that We collect or process (Section 1);
the purposes for processing the Personal Data (Sections 1,2 and 3);
the categories of Personal Data shared with third parties (Sections 1, 2 and 3 in Appendix 1)
the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 in Appendix 1)
Our sale of Personal Data to third parties or targeted advertising (Section 3 in Appendix 1, therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our products/services to You based on Your activity on other websites or apps. We may share Your Personal Data with Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by clicking on the following link: https://hub-analytics.com/do-not-sell-my-personal-info/. If You exercise Your right to opt-out of the sale of Your personal data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) Personal Data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (b) the processing genetic or biometric data for the purpose of uniquely identifying You; (c) the Personal Data from a known child; or (d) precise geolocation. We do not process “Sensitive Data” If We intend to do so, We will obtain Your consent or in the case of a known child, the consent as required by the federal Children’s Online Privacy Protection Act.

2. HOW TO EXERCISE YOUR VCDPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 6, please submit Your request to Us at privacy@hub-analytics.com with the subject “VCPDA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

We shall provide information in response to Your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

Within a reasonable time, not to exceed sixty (60) days, after You have received a notice that We have declined to take action on Your request, You may appeal by sending Your appeal to privacy@hub-analytics.com with the subject “VCPDA Appeal.” We shall respond to You within sixty (60) days of receipt of the appeal in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If We deny Your appeal, You may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint or call (804) 786-2042.

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