HubEngage Privacy Policy

Introduction

HubEngage, Inc. (“HubEngage” or “we” or “us”) has created this Privacy Policy in order to disclose its collection, use and disclosure of personal information and other data about you. This Privacy Policy is effective as of October 23, 2023. Any questions regarding this policy should be directed by email to contact@hubengage.com.  The following discloses HubEngage’s practices for its website, social media properties and digital/online services, including the HubEngage Employee Engagement Platform which includes the Employee Communications Platform, Social Engagement Platform, Employee Recognitions Platform, Employee Surveys Platform and Instant Messaging App.

If you use a website, mobile app, social networking site or an associated service displaying or referencing this Privacy Policy, you agree to this policy and the collection, use and sharing of your personal information and data as described herein and in accordance with the applicable agreements, including any applicable terms of service and/or End-User License Agreement.

Some businesses may choose to engage HubEngage in part as a “data processor” for certain services and in such case the collection, use and sharing of personal information for the engagement may be governed by the agreement between HubEngage and the business, and the business’ privacy policy, in addition to or independent of, this Privacy Policy.

Personal Information Collected and Received

HubEngage may collect or receive information about each person who visits, utilizes or interacts with the HubEngage website and services, including, but not limited to, user name, password, first and last name, email address, phone number, occupation, and employment information. HubEngage also collects other information you provide or you may volunteer.

We may collect personal information from you at various points, including but not limited to:

  • when we correspond with you;
  • when you visit the website and/or utilize or interact with our services;
  • when you register with the website or a service, including but not limited to when an account is created for you;
  • when you provide information, such as user contributed content, survey information or join our mailing list;
  • when you contact us for help;
  • when the website, an application or service sends us error reports or collect certain analytics data;
  • when engaged by a business to perform services for them or on their behalf; and
  • as described to you at or before the time of collection.

When you visit the website, we may automatically collect certain information, including information about your device such as your web browser, IP address, time zone, and other information on your device in connection with our site. Additionally, we collect information as you browse the website, including the web pages you view, the referral source (such as the page, website or search terms that brought you to the site), and other information about your interactions with our site. Such information may or may not be considered personal information.

HubEngage does not require you to include sensitive information (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic data, biometric data, data concerning health or data concerning sexual orientation). In the event that you provide such sensitive information as listed above without an express agreement covering it, you acknowledge that you have provided explicit consent concerning the collection, use and disclosure of such information. If the jurisdiction where you reside requires affirmative, opt-in consent, this paragraph does not apply to you.

Some personal information may also be collected by a third-party such as a client, service provider or other vendor. If you interact with some third-party services, such as social media companies, particularly where you have an account with the third party, they may collect additional information separate from HubEngage.

Use and Disclosure of Personal Information

HubEngage may use and share personal information that we collect or receive about you to:

  • deliver the products and services that you have requested;
  • manage your customer relationship and provide you with customer support;
  • perform analysis about your use of the website and/or services;
  • communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you;
  • enforce our terms and conditions and other agreements;
  • manage our business, including but not limited to advertising, billing; improving and expanding the services offered; deidentifying personal information, and other functions;
  • conduct a sale of all or substantially all of our, or a client’s, business or assets, which includes the sale, assignment or other transfer of your personal information in connection with such transaction.
  • respond to investigation, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or as otherwise required by law; and
  • perform functions as otherwise described to you at the time of collection.

Except as described herein, we will not disclose your personal information to any third party (i) unless directed by you; or (ii) without notifying you of our intent to share the information and giving you an opportunity to prevent your information from being shared.

From time to time, we may partner with companies based on the interests of our users. In such case, we will do so in a manner that respects your privacy and is consistent with the disclosures in this Privacy Policy.

HubEngage reserves the right to disclose information when required by law or our ethical obligations.

We use other companies to perform services necessary to our operations. In the course of providing these services, those companies may have access to your personal information. However, we will not be liable to you for any damages that may result from the misuse of your personal information by these companies.

HubEngage may use your IP address to, among other things, help diagnose problems with the HubEngage’s server and to administer the HubEngage’s website. Your IP address may also be used to help identify you and your online profile and to gather broad demographic information.

The HubEngage site registration or contact form may require users to give HubEngage contact information (such as your name and email address or mobile phone number) and may include demographic information (such as company, title, location). HubEngage may use your contact information from the registration form to send you information you request, information about HubEngage and promotional material from some of HubEngage’s partners. Your contact information may also be used to contact you when necessary.

We may also disclose statements or reviews made by our users.

Other Information

HubEngage may collect, use and share other information from your use of the website, or services, or other information, provided such information does not individually identify you or otherwise qualify as personal information (or similar) under an applicable law, including but not limited to HubEngage deidentifying personal information to create such information. HubEngage shall have the right to retain records of such data including, but not limited to, usage, activity logs, and click-throughs. HubEngage may disclose such data, whether in the form collected or a derivative form, to third parties provided it is presented in an aggregate and/or deidentified form.

Lawful Basis for Processing

Certain jurisdictions require a lawful basis for processing of personal data, and we will only collect and process your personal data there where we have lawful basis. Our lawful basis include consent (where you have given it), where processing is necessary for the performance of a contract with you, and for the purposes of our legitimate interests or the legitimate interests of our third parties, provided that such interest does not outweigh your rights and freedoms. Examples of legitimate interest include but are not limited to: (i) complying with applicable law, (ii) protecting against security or other threats, (iii) administration of our business interests, including improvements and enhancements of our business, and (iv) customer relationship issues.

How We Store and Process Your Information

The information collected by HubEngage may be processed and/or stored in the United States, European Union Member Nations, Canada, or any other country in which HubEngage or its affiliates or service providers maintain operations. HubEngage may transfer information that we collect, including personally identifiable information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction of domicile to other countries or jurisdictions. If you are located in the European Union or other regions with laws restricting transferring of data, please note that we will comply with laws applicable to us.

HubEngage may act as a Processor or Subprocessor, and not a Controller, with respect to personal information collected on behalf of customers.  If we are a Processor or Subprocessor with respect to your data, the processing of your data will be set by the Controller and there may be additional or different terms with respect to your data. If you are a customer who uses our services and you collect personal information on citizens within the European Economic Area, we ask that you contact contact@HubEngage.com to request a Data Processing Addendum (“DPA”).

Data Retention

We may choose to retain personal information for as long as necessary for the fulfillment of the purposes described herein, unless otherwise restricted by an applicable law.

Whenever applicable, HubEngage identifies the purposes for which the information is being collected before or at the time of collection. The collection of your personal data will be limited to that which is needed for the purposes identified by HubEngage. Unless you consent, or we are required or permitted by law, we will only use the personal data for the purposes for which it was collected or another purposed described to you at that time. If HubEngage will be processing your personal data for another purpose later on, our HubEngage will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose.

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal data (see Your Privacy Rights below).

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research, statistical or other permitted purposes, in which case we may use this information indefinitely without further notice to you.

Your Privacy Rights

Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws, including:

  • Access. You may have the right to access your personal data or the categories of personal data that our Company processes.
  • Correct/Update. You may have the right to correct and/or update your personal data.
  • You may have a broader right to erasure of personal data that we hold about you. For example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations, among other things.
  • Data portability. In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.
  • Transparency. You may have the right to request additional information not contained in this Privacy Policy.
  • Confirm processing. You may have the right to confirm our processing of your personal data as a controller.
  • Object to processing. You may have the right to request that we stop processing your personal data, including the right to opt in or opt out of the sale of your Personal Data to third parties, or to stop sending you marketing communications.
  • Restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances. For example, where you believe that the personal data we hold about you is inaccurate or unlawfully held. You may also be able to opt-out of targeted advertising and profiling in furtherance of decisions that produce legal or similarly significant effects as required by an applicable law.
  • Sale of Personal Data. You may have the right to opt out of the sale of personal data.
  • Cross-contextual behavioral advertising. You may have the right to opt out of the “sharing” of personal data in connection with cross-contextual behavioral advertising.
  • Withdraw your Consent to Processing Personal Data. You may have this right where we require a lawful basis for processing and we are relying on your consent. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.
  • Accessibility: You may have the right to additional assistance with your privacy rights. If you are unable to reasonably access this Privacy Policy due to a disability, please contact us via the contact information below so that we may determine how to provide you with alternate notice.

If you would like to exercise any of the above rights, please contact us by email (see our contact details in the “Contacts” Section below). We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

HubEngage will not discriminate against a data subject for exercising any of its data protection rights.

For reconsideration of our response to your request under any applicable law that provides for an appeal, please request an appeal within the time frame for the appeal notice set forth in the applicable law (or in the event no time frame is provided, then fifteen days) by utilizing the contact information published below.

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

If you are an individual in the EU / EEA, you  have the right to make a complaint to the relevant Supervisory Authority. A list of EU / EEA Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  If you are in the UK, you have a right to make a complaint to the UK Information Commissioner’s Office. You can visit their website at www.ico.org.uk.

If you live in a country, state or other jurisdiction that provides for additional rights regarding your personal information, such as the right to access or delete your personal information, and you wish to exercise those rights, please contact us using the contact information below.

International Transfer of your Personal Information

Any website, application and services may be hosted and operated in the United States and is subject to United States law. Any personal information that we collect from you may be stored and processed in the United States. If you are accessing the website, application or services outside of the U.S., to the extent not prohibited by applicable law, you consent to the transfer of your personal information to the United States. Please be advised that United States law may not offer the same privacy protections as the law in your jurisdiction.

HubEngage, Inc. (“HubEngage”) complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  HubEngage has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  HubEngage has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, HubEngage commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact HubEngageat: contact@hubengage.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, HubEngage commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolutionclaim for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

If neither HubEngage nor our dispute resolution provider resolves your complaint, you may have the possibility, under certain conditions, to invoke binding arbitration through the Data Privacy Framework Panel.

HubEngage is responsible for personal data that we receive under the Data Privacy Framework, including where we transfer such personal data to a third party acting as our agent. Please be aware that we may be required to disclose personal data that we receive under the Data Privacy Framework in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

The Federal Trade Commission has jurisdiction over HubEngage’s compliance with the Data Privacy Framework.

Your California Privacy Rights

If the California Consumer Privacy Act (“CCPA”) applies to your personal information, please also see the section titled “Your Privacy Rights” above.

HubEngage does not currently respond to browser “Do Not Track” (DNT) signals or other mechanisms, unless required by applicable law.

If you are a California resident, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by sending an e-mail to contact@HubEngage.com.

Our website and/or application are not intended to appeal to minors. However, if you are a California resident under the age of 18, and a registered user of our website and/or application, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to contact@HubEngage.com. 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.

Under California law, California residents who have an established business relationship with us may opt-out of our disclosing personal information about them to third parties for their marketing purposes. 

End Users of Customers

Most of our services are intended for use by organizations. Where the services are made available to you through an organization (e.g. your employer), that organization is the administrator of the services and is responsible for the accounts and/or service over which it has control. Please direct your data privacy questions to your administrator, as your use of the services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this policy.

Children’s Privacy

We do not knowingly collect any information from anyone who we know to be under the age of 18. If you are under the age of 18, you should use this website only with the involvement of a parent or guardian and should not submit any personal information to us. If we discover that a person under the age of 18 has provided us with any personal information, we will use commercially reasonable efforts to delete such person’s personal information from all HubEngage systems.

Global Positioning System

Global Positioning System (GPS) tracking technology may need to be enabled in connection with HubEngage products and services in order to determine the precise location (latitude and longitude) of users. We will request your permission prior to such precise geolocation tracking. Where authorized, this information is transmitted as necessary for the products and services, which may include transmission to HubEngage, its service providers (including hosting provider), and HubEngage’s users or clients. This information is only used by HubEngage in conjunction with HubEngage’s services or otherwise in connection with the reason for its collection or as permitted this Privacy Policy.

Security

HubEngage uses industry-standard technologies when transferring and receiving consumer data exchanged between HubEngage and other companies to help ensure its security. However, there is no guarantee that your personal information in any system is completely secure. 

Links

HubEngage may create links to other web sites. HubEngage will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual’s right to privacy. However, many other sites that are not associated or authorized by HubEngage may have links leading to our site. HubEngage cannot control these links and HubEngage is not responsible for any content appearing on these sites.

Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. The HubEngage site uses cookies to keep track of your session or for other functions. HubEngage may also use cookies to deliver content specific to your interests.

HubEngage may use an outside ad or marketing company in connection with the website, products and services, including, but not limited to, display of ads or ad technology or marketing technology. These ads may also contain cookies.

We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our sites, services and software. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our users to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site and/or software. HubEngage and these companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements and connect to the HubEngage website and/or services. This information allows HubEngage and these companies to deliver targeted advertisements and gauge their effectiveness.

Advertising Opt-Outs

As described above, we may use your Personal Information to provide you targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by doing so at:

FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

Do Not Track

Please note that we do not alter our data collection and use practices as a result of a Do Not Track signal from your browser, unless required by an applicable law.

Amendments

HubEngage may amend this policy at any time. If HubEngage is going to use personally identifiable information collected through the HubEngage site in a manner materially different from that stated at the time of collection, HubEngage will notify users via email and/or by posting a notice on the HubEngage site for thirty (30) days prior to such use. This Privacy Policy may not be otherwise amended except in a writing that specifically refers to this Privacy Policy and is physically signed by both parties.

Opt-Out

The HubEngage site provides users the opportunity to opt-out of receiving communications from HubEngage, except transactional correspondence. To opt-out of receiving our communications, you can send an email to contact@hubengage.com.

Successors and Assigns

This Privacy Policy inures to the benefit of successors and assigns of HubEngage.

Contacts

If you have any questions about this Privacy Policy, the practices of this site or HubEngage, or your dealings with us, you can contact us at contact@hubengage.com.

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