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Privacy Policy

1. Introduction

HUBBY to go B.V. (hereinafter referred to as "HUBBY", "HUBBY eSIM", "we", "us", or "our") is dedicated to safeguarding the privacy and security of our users' ("you", "your") information. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of your personal information as it relates to HUBBY's eSIM services accessed via our website (www.hubbyesim.com) and HUBBY mobile application. By engaging with our eSIM services, you acknowledge and consent to the practices described in this policy. We may update this policy from time to time to reflect changes in our practices, technology, legal requirements, and other factors.

Commitment to GDPR

In alignment with the General Data Protection Regulation (GDPR), HUBBY commits to:
 

  • Transparency: Clearly communicate the purposes for collecting your personal data.

  • Data Minimization: Limit the collection of data to what is directly relevant and necessary for our eSIM services.

  • Retention Limitation: Retain personal data only for as long as necessary to fulfill the specified purposes.

  • Rights Protection: Ensure your rights to access, rectify, delete, or restrict the processing of your personal data.

2. Data Collection

 

2.1. Personal Identifiable Information (PPI)

We collect PII when you voluntarily provide it to us, such as during account registration, eSIM purchase, customer service interactions, and through other user-initiated actions on our platforms. This data may include your name, email address, phone number, payment information, and other details necessary to deliver our services. We utilise this data to provide our services, operate and enhance them, offer customer service, conduct research and analysis to improve our products, services and technology, and display content tailored to your interests and preferences.

 

Certain parts of our service may not be available to you if you choose not to provide personal data. By using our services, you are agreeing to provide your personal data, and we will process it accordingly. If you do not agree with our use of your personal data in line with this policy, please do not use our services.

 

2.2. Sensitive Data

Please do not disclose sensitive data such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership. However, if you submit content containing sensitive data to our services, you consent to our processing and use of that data according to this policy. We will not store sensitive data on our side.

 

2.3 Non-Personally Identifiable Information
We automatically collect aggregated data that cannot identify you personally, such as usage statistics, device information, and access times. This information aids in improving our services and user experience.

 

2.4. Cookies, Pixels and Local Storage

We use cookies, pixels, and local storage to recognize your computer or mobile device and provide you with a personalised and interactive experience. First-party cookies are used to recognize your computer or mobile device when it revisits our site or application, and third-party cookies are used by service providers to recognize your computer or mobile device when it visits other websites. You can manage or delete cookies through your browser settings.

To disable cookies, you may use the Google AdWords Conversion Tool's Opt-Out feature. Disabling cookies can help protect user privacy and reduce the number of targeted ads they see.

 

3. Information Usage

3.1 Information Usage Policy

 

We do not share your personally identifiable information with any outside parties except as disclosed in this privacy policy. We use the information that you directly provide us for purposes such as operating and improving the services, managing accounts, responding to comments and questions, and sending technical notices and updates. With your consent, we may send marketing emails about upcoming promotions and other news. Users may opt-out of receiving such emails at any time.

 

We may share your information with service providers who perform services on our behalf, such as the B2B travel partner adopting out eSIM service, processing payments and marketing. These companies will only be allowed to obtain the personal information they need to provide the service, maintain the confidentiality of the information, and use it for the stated purpose.

 

We will only retain your personally identifiable information for as long as it is necessary to provide the services or for any longer retention periods required or permitted by law. You may contact us to opt-out of direct marketing communications, the collection of sensitive personal data, and any new processing of your personal data that we may carry out beyond the original purpose. You may also access and correct any inaccuracies in your personal data or request that we erase your data. Please note that some of the services may be ineffective upon opting out.

 

We value your privacy and will not disclose your personally identifiable information unless under the following circumstances: with your permission, as granted by your acceptance of our Privacy Policy; when required by law, such as a relevant statute, regulation, court order, decree, or subpoena; to correct false or misleading information or address manipulative and deceptive activities that violate the law; to provide you with the product or service you requested; or under confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition of our business. We may share non-personally identifiable information in aggregate form with advertisers and other partners.

3.2. International Transfers

Our service may be accessed in Europe and other countries. We are the controller and processor of data collected for data protection purposes, and information we collect may be stored, processed, accessed, and used in jurisdictions whose privacy laws may differ from those of your home jurisdiction. We have engaged third-party service providers to manage logistics and customer support for our 24/7 service. Some data must be disclosed and transferred to these providers to ensure service fulfilment. These providers have limited access to our database and have been engaged under a binding confidentiality agreement.

4. Your Rights


Under GDPR and other privacy laws, you have rights regarding your personal data, including access, correction, deletion, and portability. For requests or questions about your data, please contact us at support@hubbywifi.com.

 

5. Children's Policy

Users must be 18 or older, or 13 and older if they are an emancipated minor or have legal parental or guardian consent, as stated in our Terms of Service. We do not knowingly collect personally identifiable information from users under 13. If we discover that we have collected personal information from a user under 13, we will attempt to identify and delete that information from our database.

 

6. How to Change or Update Information

If you have questions or concerns about your privacy or would like your personally identifiable information removed from our files, please contact us at support@hubbyesim.com

 

7. Security and Encryption

We use generally accepted industry standards such as multi-layered security controls, firewalls, and SSL encryption to protect your personal information. Although we take measures to maintain the confidentiality of your online information, no method of transmission or electronic storage is entirely secure. You are responsible for your password's security, and we encourage you to protect it. Please contact us at support@hubbyesim.com if you suspect your account's security has been compromised.
 

8. Changes to This Policy

We reserve the right to revise the terms of our Privacy Policy and will update the last updated date at the top of the policy. We will notify you of material changes to our policy, such as changes in how we use your personal information, by prominently posting a notice of such changes on our home page or by sending you an email. Please review our policy each time you visit our website or use our application.

 

2023 HUBBY to go

All right reserved

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