Last updated: December 07, 2022 The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will. This policy applies to all products built and maintained by SocialHubs UG (haftungsbeschränkt). What we collect and why Our guiding principle is to collect only what we need. Here’s what that means in practice: Identity & access When you sign up for a SocialHubs UG (haftungsbeschränkt) product, we ask for information such as your name, email address. That’s so you can personalize your new account. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We also give you the option to add a profile picture that displays in our products. We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either. Billing information If you sign up for a paid SocialHubs UG (haftungsbeschränkt) product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit SocialHubs UG (haftungsbeschränkt). We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts. Product interactions We store on our servers the content that you upload or receive or maintain in your SocialHubs UG (haftungsbeschränkt) product accounts. This is so you can use our products as intended. Geolocation data For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active. Website interactions We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section. Anti-bot assessments We use third-party CAPTCHA services across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. The CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. We retain these data via our subprocessor indefinitely for use in spam mitigation. Advertising and Cookies SocialHubs UG (haftungsbeschränkt) runs contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to our site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form. We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics. A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off. Correspondence When you email SocialHubs UG (haftungsbeschränkt) with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future. How we approach mobile app permissions We offer mobile apps for some of our products. Because of how the platforms are designed, our apps typically must request your consent before accessing contacts, calendar, camera, and other privacy-sensitive features of your device. Consent is always optional and our apps will function without it, though some features may be unavailable. When we access or share your information To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you. You can view the third-party subprocessors we use for each of our products. We also use third-party processors for other business functions such as managing newsletter subscriptions and sending customer surveys. No SocialHubs UG (haftungsbeschränkt) human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see “When required under applicable law” below). To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding. To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted. When required under applicable law. Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to share data, we must comply. It is our policy to notify affected users before we share data unless we are legally prohibited from doing so, and except in some emergency cases. Preservation requests. Similarly, we do not share preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period. If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we will share only the minimum needed, such as billing addresses and tax exemption information. Finally, if SocialHubs UG (haftungsbeschränkt) is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy. Your rights with respect to your information At SocialHubs UG (haftungsbeschränkt), we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include: Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy. Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information. Right to Correction. You have the right to request correction of your personal information. Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using SocialHubs UG (haftungsbeschränkt) services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account. Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.) Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed. Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent. Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services. Many of these rights can be exercised by signing in and updating your account information. If you have questions about exercising these rights or need assistance, please contact us at app.hub.app@gmail.com. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws. How we secure your data All data is encrypted when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. Location of site and data Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer. When transferring personal data from the EU The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK. Accordingly, SocialHubs UG (haftungsbeschränkt) has adopted a data processing guideline to help ensure this protection. There are also a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with SocialHubs UG (haftungsbeschränkt) operations, for instance, if an EU user signs up for our newsletter or participates in one of our surveys. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR. We use third party services that declare their own Terms and Conditions and Privacy Policy. Link to Terms and Conditions of third party service providers used by the app Google Play Services, AdMob, Google Analytics, Appodeal, IronSource, AppLovinChanges & questions We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users. Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at app.hub.app@gmail.com and we’ll be happy to try to answer them!