HUBBSTER'S PRIVACY POLICY
This privacy policy takes effect on 1 February 2023. It describes what information we hold, why we hold it and how we use it. This policy applies to anyone who uses our website, www.hubbster.dk (“Site”), and our App (“Hubbster App”). We'll refer to the Site and the Hubbster App together as “The App”. In this Privacy Policy, references to the App include both free and paid (Hubbster Club) versions of the App.
We are Hubbster aps. (“we”, “our”, “us”), a company registered in USA. We're the data controller as defined by the General Data Protection. If you have any questions about this policy or want to contact our Data Protection Officer, please contact us through the App or send an email to support@hubbster.dk.
WHAT INFORMATION DO WE HOLD AND WHY?
There are three types of information we process: (1) information you provide, (2) information created when you use features in the App and (3) information from other sources.
Information you provide
When you use our App, you might provide us with (a) personal information; (b) places and preferences; and (c) direct communications.
Personal Information If you create a Hubbster account, you provide us with your name, email address and address of residence, which we use to offer you “free for locals” access and other personalisation features are synced across your multiple devices. When you log in using Facebook or Google, we receive your name and email address from them. When you book hub usage within the App without opening another app (“Native Booking”), you provide us with your name, your phone number (to verify you as a user), your email address (to provide customer service and help ensure the quality of the services), Your home address (to offer you “free for locals” access to certain hubs) and your payment details. If we are not able to verify your identity using this initial check, we will ask you to provide additional information (such as a copy of your passport ID page or drivers license, proof of address or your photograph (“Additional ID Documents”). We never use this information for any purpose other than verifying your identity so we can provide you with hubs access. You also provide us with your payment details as collateral to secure that borrowed things are returned, are in order and other fees as specified in the Hubbster Payment Terms.
Places and Preferences You may choose to provide us with information on your places and preferences, such as Home, Work, Saved Places, and other location preferences. We use this information to develop personalized play opportunity services. We also analyze this data in aggregate to improve the App (for example, by ranking certain play options more highly than others).
Direct Communications When you communicate with us (for example when you respond to in-App survey questions, report problems, raise queries etc.) we may receive information about the type of phone you're using, your service provider and, if you've enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We use this information to fix problems in the App, or with Native Booking, to reply to your communications and to help keep you safe.
Information created when you use our App
The following are the types of information created when you use our App. We associate this information with an installation ID number that is randomly generated each time you install the Hubbster App. We use this installation ID to pseudonymise the data we collect from you. We do not access any permanent device ID numbers.
Location Information We use the location data described in this “Location Information” section to improve results in the App and for the purposes identified below. Users of the Hubbster App: if you've enabled your device's location services we may collect and use your start location information when you open the App. If you disable your device's location services we collect only the locations for games played. Native Booking: If you make a Native Booking, we collect your location information when the Hubbster App is running both in the foreground and background of your device during your play. Knowing your location during your play enables inventory tracking during a use and to provide you with play opportunities in close proximity. In addition to your location data, we store your booking details, the date and time of your use, the amount charged, cancellations and no shows. We use this information for operational reasons, such as providing customer support.
Device Information We collect information about the devices you use to access our App, including the type of computer or device you use, the installation ID of the App on your device, the hardware model, operating system and versions, software, file names and versions, the preferred language, time zone settings, and device motion information. This information is necessary for us to diagnose bugs and improve the App. We do not collect any permanent device ID numbers.
Log and Usage Information Each time you open the App, we collect information about how and when you use it (such as the time and date, searches in the App features and play results you select, pages visited, app crashes and other system activity). We use this information to improve our App in multiple ways. For example, fixing bugs preventing future crashes and working out which features our users find most helpful.
Cookies The App uses cookies to store certain information. Cookies are pieces of information that a website or app transfers to your hard drive or mobile device to store and sometimes track information about you. Although they identify a user's device, cookies do not reveal the name, email address or other obvious identifiers of users. We try to make your experience of the App simple and meaningful. When you visit our App, our server sends a cookie to your computer or mobile device (depending on how you access the site or App). Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. A number of cookies we use last only for the duration of your web session and expire when you close your App. These are known as “session cookies”. Other cookies are used to remember you when you return to the App and will last for longer. These are known as “persistent cookies”. We use cookies to:
remember that you have visited us before, which allows us to identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get and to; customize elements of the promotional layout and/or content of the pages of the App; and
collect information about how you use the App so that we can improve the App and learn which parts of the App are most useful.
Some of the cookies used by our App are set by us and some are set by third-party analytics and crash/error-reporting companies as described in this policy. Most browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. By blocking or deleting cookies you may not be able to take full advantage of the App's features.
Information from Other Sources
Hubbster collects the following types of information from other sources.
Payment information In order to pay for Native Bookings or secure collateral at free use, you will need to provide payment information. Apple and Google collect credit or debit card (“Payment Card”) data with respect to in-app purchases of Hubbster Club, and our payment processor collects Payment Card data with respect to Native Booking payments. For Native Bookings, you provide your Payment Card information directly to Stripe, which processes payments on our behalf. Stripe uses this payment information in accordance with its privacy policy. Stripe provides us with some limited data related to you, such as the last four digits of your card number and expiration date, which we use in order to handle operational issues such as subscriber queries about charges.
Log-in Information If you log into your Hubbster account using Facebook or Google we receive your name and email address. We do not collect or use any other information received from those two companies.
Identity verification If you sign up for a Day Pass, we receive a due diligence report from third-party agencies that provide identity verification, in order to confirm your identity. This information is necessary to prevent fraudulent or unauthorised use of our services and to comply with our legal obligations.
Cardholder ID and transaction information for Day Pass If you are a Day Pass user, we receive a “Cardholder ID” from the third-party company that issues your Day Pass card. The Cardholder ID is your unique identifier that tells us which Day Pass card has been issued to you. When you use the Day Pass, we also receive your transaction information from this third-party company, including the date, time, amount, and the merchant details associated with the transaction. This information is necessary to provide the Day Pass service and to comply with our legal obligations.
HOW WE USE YOUR INFORMATION, SUMMARISED
In summary, we use the information we collect to:
Provide and improve our App, Native Booking services and Day Pass.
Build a profile of your preferences so we can personalize the Hubbster App and provide you with relevant play information.
Recommend play options that match your stated preferences and previous use of the App.
Administer your account with us, if you have one;
Confirm your eligibility to use Day Pass;
Verify your identity (including processing of your identity documents in order to confirm your identity and to make an automated decision as to whether or not to provide you with Day Pass services);
Enable communication between hub owner and users.
Process or facilitate payment (through third party payment processing services) for Native Booking, Day Pass and Hubbster Club.
Send you transaction receipts for your use of Native Booking and/or Day Pass.
Respond to your emails to discuss your use of the App, Native Booking, Day Pass and/or Hubbster Club and answer any support queries you may have.
Send you marketing communications by email or in-App notifications, and let you know about our policies and terms or when we launch in your neighborhood.
Identify issues with the operation of the App, and provide crash reports in order to find resolution for performance issues.
Improve the design, functionality and/or content of the pages of the App and customize them for you.
Carry out research on users' play choices to improve the App, Day Pass and Hubbster Club; and
Disclose to lawful authorities when required to do so by law, or when appropriate, in our opinion, to respond to their request.
We work hard to improve the App and add functionality, which we think will make it safer, more fun and more useful. New functionality may involve similar or incidental uses of your data to those set out above. We regularly review the way we use data and will update our privacy policy if anything changes.
WHAT THIRD PARTIES RECEIVE YOUR INFORMATION?
From time to time we may share information with third parties to improve the App and enhance user experience. To the extent possible we pseudonymise (remove information that identifies you) and minimize the data we send to them.
Search Partners: We have search partners like Google, Apple, and Foursquare so you can find the places you want to go in the App. They receive the place name you have searched for and to make your search results as relevant as possible, they receive your current location (if you have enabled location services in your device).
Deeplink Booking (i.e. any game or sports facility that you can book by clicking through the Hubbster App to open a third party app) providers: These third-party sports facility providers in the App, receive the booking request you enter in our App in order to provide availability overview and additional cost estimates and (if you choose to book a facility through their apps by clicking through the Hubbster App) to provide you with their sports facility services.
Analytics Vendors: We use third party vendors like Mixpanel, Flurry and Google Analytics to understand what you've tapped or clicked on the App. They receive information showing only that someone has tapped or used certain features in the App. They organise that information and give it back to us so that we can make improvements to the App.
Crash/Error Reporting Vendors: We use Crashlytics to report on crashes you experience with the App so we can fix those, and Sentry to report on errors with our backend.
Messaging Apps: If you decide to use certain sharing features in our App, then you may be sharing your information with those companies, depending on encryption policies used by the messaging company. For example, if you use the “Invite players nearby” feature in the App, a link with your name and location will be sent via messaging app. If the messaging app company you choose uses end-to-end encryption, your location link cannot be used or intercepted by that messaging app company.
Communication Platforms: To send you transaction receipts for your Native Bookings and/or Day Pass subscription and to send you all other emails and update about our services, we use communication platforms such as Sendgrid and Mailchimp.
Identity Verification Service Provider: If you apply for a Day Pass, we use identity verification services like Onfido and credit reference agencies to verify your identity to prevent fraudulent or unauthorised use of Day Pass. They receive your name, home address and date of birth. If we are not able to verify your identity using this initial check, they will receive the additional information that you give us in order to verify your identity such as your Additional ID Documents. Identity verification agencies and credit reference agencies also use information from a number of different public sources (for example the electoral roll) to verify your identity. Credit reference agencies may also leave a ‘soft’ footprint on your credit file for the purpose of identity verification which should not affect your credit rating.
Day Pass card issuer: If you are a Day Pass user, we use Prepaid Financial Services (PFS) to issue and deliver the Day Pass card to you and to process transactions on your Day Pass card. PFS receives your name and home address. If you choose to use a mobile payment system for your Day Pass card, PFS will also receive your phone number. PFS may also undertake quality assurance checks of our identity verification process, in which case they will have access to your information available from public sources, your date of birth and any additional information that you give us in order to verify your identity such as your Additional ID Documents.
WHAT'S OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION?
We'll only process your personal information where we have a legal basis for doing so. Our legal basis to process your personal data includes processing that is:
necessary for our legitimate interests, which are:
to research, develop, fix and provide new and tailored features for the App and Day Pass users;
to provide on-play support to users;
to accept and administer payment from users for use of Native Booking and/or Day Pass;
to verify users' identity to prevent fraudulent or unauthorised use of our services; and
to prevent breaches of our terms and policies or to prevent harmful or illegal activity;
necessary for the performance of our contract with you (e.g., so players and invited persons nearby can find each other);
necessary to comply with relevant legal and regulatory requirements; and
based on your consent (for example, where you provide us with marketing consents), which may be withdrawn at any time by contacting us at the email address specified below.
WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA WE HOLD ABOUT YOU?
Access
You have a legal right to request access to a copy of the personal information we hold about you. In order to do this, contact us at support@hubbster.dk. Please use the subject line “DSAR” and include details about what personal information you're looking for. You will need to have created an account in order for us to provide you with your information because without an account, we are not able to connect your Installation ID to a verifiable email address. You must have access to the email address that you used when you created the account so that we can verify your identity.
Deletion
We store your personal information for as long as is necessary to provide our services and products. You have the right to request we delete your personal information if you believe that we no longer need it for the purposes for which it was provided, you wish to withdraw your consent (and we have no other lawful basis to use the data), or we are not using your information in a lawful matter. For legal reasons, we may not always be able to delete your information.
If you ask us to delete your personal information by emailing us at support@hubbster.dk, please use the subject line “Account Deletion”.
Note that residual copies may take longer to be removed from our backup systems which cannot be immediately overwritten. Where residual copies are still kept on our back-up systems, they are merely held on the system and are not used for any other purpose. We will keep a record of your request in order to ensure compliance with legal obligations.
We will keep a record of your request in order to ensure compliance with legal obligations.
Marketing opt-out
You have the right at any time to prevent the use of your personal information for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to us at support@hubbster.dk or clicking on the unsubscribe button at the bottom of marketing emails and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes. Also, we may still send you non-promotional, transactional messages, or information about your account.
Notifications
We may send you information we think you may find useful (e.g., play opportunities and alerts about occupancy relevant to you) or which you have requested from us by push notification and/or by email (if provided). You can opt-out of receiving further notifications or emails if you wish.
HOW WE KEEP YOUR INFORMATION SECURE
We place great importance on the security of all information associated with our users. We use measures such as encryption, pseudonymisation, information access controls, and firewalls.
Keep in mind that submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.
HOW LONG WE KEEP YOUR INFORMATION
By providing you with products or services, we create records that contain your information, such as customer account records, payment and activity records. We manage our records to help us to serve our users well and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and are evidence of our business activities.
How long we keep records depends on the type of record, the nature of the activity, product or service and the applicable legal or regulatory requirements. How long we retain your information may change based on business or legal and regulatory requirements. If you are a Day Pass user, we keep most of your data as long as you're using Pass and for six years after that to comply with the law and if we face a legal challenge. In some circumstances, we may keep data longer if we need to (because it's in our legitimate interest and/or if the law requires it).
WHAT COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT TO?
Information that you submit via the App is sent to and stored on secure servers located in Denmark, other European Community countries and in the United States. Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (for instance in the United States).
DO YOU COLLECT CHILDREN'S INFORMATION?
We do not knowingly collect personal information from children under the age of 13. If you're under the age of 13, please do not submit any personal information through the App or email. We encourage parents and legal guardians to monitor their children's internet use and to help enforce our privacy policy by instructing their children never to provide personal information on our website without their permission. If you have reasons to believe that a child under the age of 13 has provided personal information to us, please contact us as specified below, and we will work to delete that information from our databases.
HOW WILL YOU KNOW ABOUT CHANGES TO OUR PRIVACY POLICY?
We may revise this privacy policy from time to time. Any changes and additions to this privacy policy will be posted in the App and are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal data. This privacy policy was last updated on 1 February 2021.
WHAT IF YOU HAVE A COMPLAINT?
We work hard to handle your information responsibly. If you're unhappy about the way we do this, please contact our Data Protection Officer by email to support@hubbster.dk.
However, you also have the right to lodge a complaint about the data processing activities carried out by Hubbster with our lead supervisory authority, Datatilsynet at datatilsynet.dk
HOW TO GET IN TOUCH WITH US
Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to our Data Protection Officer at support@hubbster.dk. You can also reach us at Data Protection Officer, Hubbster inc., c/o URBAN-X, 19 Morris Ave, Brooklyn Navy Yard Bldg. 128, Brooklyn, NY 11205, USA