Privacy Policy

This Privacy Policy (“Policy”) describes how HubAround (“HubAround”,“we”, “our”, “us”) collect, store, use, and share your personal information when you interact with us in relation to your use of the HubAround platform and its related services (“Platform”). The Policy also describes your choices regarding use, access and correction of your personal information.

Owner and Data Controller

Owner: Kabosh Digital Pty Limited

Data controller contact email: david@hubaround.com

Children Information

The Platform is intended for adults, and we do not knowingly collect data from children directly under the age specified by your local law (e.g., under 16 in many jurisdictions or under 13 in the United States under COPPA). If we discover that we have inadvertently collected personal data from a child without appropriate consent from their parents or guardians, we will promptly delete it. We will only collect or process information belonging to children under very limited circumstances. We might need to collect personal information belonging to children as part of our service if, for example, the personal information is required as part of reservation service from the platform. We will only collect personal information belonging to children if it is provided by and with consent of a parent or guardian. If we become aware that we have processed the personal information of a child without the valid consent of a parent or guardian, we will delete the personal information. Parents or guardians who believe that their child's information may have been collected should contact us immediately at support@hubaround.com.

Collection, Use and Sharing

What information do we collect

We may collect information from you directly, automatically when you visit the Platform, third parties or public domains. Some of this information may be considered "personal information" or "personal data" under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name, phone number, and email address) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as "personal information" where required by applicable law.

We collect information when you:

• participate in activities we offer, such as quizzes or surveys
• sign up to our platform or opt-in to our newsletter distribution
• contact us such as share information or give us feedback
• visit our website or use our digital services
• enquire about our platform or services
• chat to us or do business with us

Types of information we may collect

• Personal and contact details (This may include your name, email address, phone number)
• Quiz responses (to generate your personalised results)
• Usage data (This may include your IP address, search preferences and navigation on our site)
• Socio-demographic information (This may include your age, number of children and country of residency)
• Publicly available information (We may collect and handle information that is in the public domain such as from social media, public websites or public registers)

How we use your information

We may use non-personal information for any purpose, including for advertising, research, and marketing purposes. We also use information collected from or about you, including personal information and usage Information, as disclosed in this Policy, including to:

• enable you to access and use the Platform or other services we offer, such as verifying your email address is active and valid;
• communicate with you, such as responding to your questions, or feedback, and send you important notices regarding the Platform, our policies, about us as well as marketing, advertising, and promotional messages that may be of interest to you;
• contact you about administrative matters, such as changes to our Policy, or other policies
• for internal business purposes, such as improving the Platform, and to comply with legal requirements;
• tailor and target content, advertisements and offers we display to you or others on the Platform or elsewhere online;
• operate and protect the Platform from errors, misuse of the Platform, fraud, any criminal activity, and other illegal activities or activities that violate our policies, detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies; and
• as otherwise disclosed in this Policy, for other reasons that we disclose when you provide your information, or otherwise with your consent.

Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been de-identified or aggregated, as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law.

We process your personal data under the following legal grounds:

• Consent: When you voluntarily provide your information (e.g., subscribing to our updates, taking our quiz, or creating an account).
• Legitimate Interest: To enhance our platform, personalise user experience, and improve security.
• Legal Compliance: To comply with applicable laws, including those related to financial transactions and fraud prevention.

Who do we share your information with

Your privacy is important to us. We do not sell or rent your personal data. We may share your information with third parties for the reasons mentioned in “How do we use your information”section or where the law otherwise allows or requires us to. We may share your information with:

• Our Service Partners: Such as email marketing tools, analytics providers, and payment processors. These third parties are contractually bound to protect your data and only use it for the specified purposes.
• Legal Authorities: We may share information with third parties where you have authorised us to do so or where we are legally required.

Data Retention

Quiz and Account Data: We retain and process your personal data as long as required by the purpose they have been collected for.

Usage Data: Stored for analytical purposes to improve our platform and user experience.

You may request the deletion or correction of your data at any time by contacting us.

Security Measures

We implement robust technical and organisational measures, including encryption, secure servers, and access controls, to protect your personal data from unauthorised access, alteration, disclosure, or destruction. However, no system is completely foolproof, so we encourage you to maintain strong personal security practices (e.g., using strong passwords).

Your Rights and Consents

In addition to the rights and choices below, where permitted under applicable data protection laws, you may have multiple privacy rights based on your jurisdiction with respect to the Personal Information we process about you:

• Access: request confirmation that we are processing your Personal Information; request a copy of Personal Information we hold about you;
• Update: request that we update Personal Information we hold about you or correct such data that is inaccurate or incomplete;
• Delete: request that we delete the Personal Information we hold about you;
• restrict the way in which we use your Personal Information (e.g., if we have no legal right to keep using it) or limit our use of your Personal Information (e.g., if your Personal Information is inaccurate or unlawfully held);
• Restriction and Objection: object to our processing of your Personal Information on grounds relating to your particular situation or if we process your Personal Information for direct marketing purposes, you can object at any time to the processing of your Personal Information for such marketing;
• Withdraw: withdraw the consent that you have given us to process your Personal Information; and
• Complain: lodge a complaint with the relevant data protection authority regarding our processing of your Personal Information.

To exercise these rights, please contact us at support@hubaround.com. We will respond in accordance with applicable law.

Contacting You

Mailing list or newsletter from the platform: By registering on the mailing list or for the newsletter, your name and email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning the platform. Your email address might also be added to this list as a result of signing up to the platform or after making a purchase.

Cookies and Similar Technologies

Our platform may use cookies and other tracking technologies to enhance your user experience, analyse usage, and deliver personalised content. By using our platform, you consent to the use of these technologies.

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our platform, practices, services or regulatory requirements. Any changes will be posted on this page with a revised update date. We strongly recommend reviewing this Privacy Policy periodically.

Supplementary

General Data Protection Regulation Privacy Statement (“GDPR Statement”) for Europe and the UK

This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom.

This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons located in the EEA.

Your rights with respect to your own personal information include the following:

• The right to request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
• The right to request correction of your personal information if it is inaccurate or incomplete.
• The right to request deletion of your personal information if:
  • your personal information is no longer necessary for the purposes for which we collected or processed them; or
  • you withdraw your consent if the processing of your personal information is based on consent and no other legal ground exists; or
  • you object to the processing of your personal information and we do not have an overriding legitimate ground for processing; or
  • your personal information is unlawfully processed; or
  • your personal information must be deleted for compliance with a legal obligation.
• The right to object to the processing of your personal information. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal information to establish, exercise, or defend a legal claim.
• The right to restrict the processing of personal information, if:
  • the accuracy of your personal information is contested by you, for the period in which we have to verify the accuracy of the personal information; or
  • the processing is unlawful, and you oppose the deletion of your personal information and request restriction; or
  • we no longer need your personal information for the purposes of processing, but your personal information is required by you for legal claims; or
  • your personal information is unlawfully processed; or
  • you have objected to the processing for the period in which we have to verify overriding legitimate grounds.
• The right to data portability. You may request that we send this personal information to a third party, where feasible. You only have this right if it relates to personal information you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.

International Data Transfers

If you are accessing our platform from outside the EEA, please note that your personal data may be transferred to and processed in countries that may not offer the same level of data protection as your jurisdiction. We ensure that all such transfers are safeguarded by appropriate legal mechanisms, such as Standard Contractual Clauses (SCCs) or other approved methods.

Contact Us

If you have any questions, comments, or concerns regarding our policy and/or practices, please contact us at:

Email: support@hubaround.com