Privacy policy

Last Update: May 23, 2018

We recognize that your privacy is very important, and we take it seriously. Our Hulbee Privacy Policy ("Privacy Policy") describes our policies and procedures about the collection, use, disclosure, and sharing of your personal information or personal data when you use Hulbee. Hulbee Enterprise AG is the data controller for your personal information collected through the Hulbee platform. This Privacy Policy applies to activities by Hulbee and its affiliates and subsidiaries (collectively "Hulbee", "we" or "us"). For clarity, personal information or personal data means information relating to an identified or identifiable natural person.

The Information We Collect

We collect information directly from individuals, from third-parties, and automatically through the Hulbee platform. If you choose not to disclose certain personal information, it may limit your access to certain services or features, including account registration, and the ability to follow other Hulbee users or share content on other sites.

Communications: When you communicate with us (via email, phone, through Hulbee or otherwise), we may document and use this communication.

Automatically Collected Information about Your Activity. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of Hulbee. We also collect and may store information that your computer or mobile device provides to us in connection with your use of Hulbee such as your browser type, type of computer or mobile device, browser language, IP address, mobile operator, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with Hulbee. For more information, see the "Cookies, Pixels and Tracking" section below and our Cookie Policy.

Engagement: We collect browsing information – such as IP address and location, date and time stamp, user agent, Hulbee cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable), and time zone, and other information about user activities on the Hulbee platform, as well as on third party sites and services that have embedded our Hulbee pixels ("Pixels") widgets, plug-ins, buttons, or related services. See the section below about Hulbee Ads and Personalization for more detailed information about how our Pixels may be used by publishers or users of our advertising services ("Ad Services") on the Hulbee platform to enable personalization, as well as your choices related to advertising. We may also receive information about you from third parties, such as other users, partners (including ad partners), or our affiliated companies.

Purposes and Legal Bases for Our Using of Your Information

We DO NOT sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes.
Hulbee uses the information we collect for our legitimate interests which include the following:

  • Provide our Services. To provide you the services we offer on Hulbee, communicate with you about your use of Hulbee, respond to your inquiries, provide troubleshooting, and for other customer service purposes.
  • Personalization. To display interest-based advertising to you in Hulbee, to improve our advertising and measurement systems so we can show you relevant ads, and to measure the effectiveness and reach of ads and services. For more information, see the section below about Hulbee Ads and Personalization.
  • Advertising. Um Ihnen interessenbasierte Werbeanzeigen auf Hulbee anzuzeigen, um unsere Werbe- und Messsysteme zu verbessern, sodass wir Ihnen relevante Werbung zeigen können, und um die Effektivität und Reichweite von Werbung und Services zu messen. Weitere Informationen finden Sie im nachfolgenden Abschnitt zu Werbeanzeigen und Personalisierung von Hulbee.
  • Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services.
  • Analytics. To gather metrics to better understand how users access and use Hulbee; to evaluate and improve Hulbee, including the Ad Services, and to develop new products and services.
  • Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms and Conditions of Use or this Privacy Policy.

How We Share Your Information

We share information as set forth below, and where individuals have otherwise consented:

  • Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers, as well as those who assist us in providing the Ad Services.
  • Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of Hulbee Enterprise AG, whose use and disclosure of your personal information is subject to this Privacy Policy.
  • Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
  • Legally Required. We may disclose your information if we are required to do so by law.
  • Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or arrest warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of Hulbee, its users, or others.
  • Your Content and Activity. Your Content, including your name, profile picture, profile information, and certain associated activity information is available to other users of Hulbee and may be viewed publicly. Public viewing includes availability to non-registered visitors and can occur when users share Your Content across other sites or services. In addition, Your Content may be indexed by search engines. See the section below about Your Choices for information about how you may change how certain information is shared or viewed by others.
  • Metrics. We may share with the users of our advertising services aggregate statistics, metrics and other reports about the performance of their ads or content in Hulbee such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information. We do not share IP addresses or personal information. We may also allow our advertisers to use Pixels on Hulbee in order to collect information about the performance of their ads.
  • Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies, Pixels and Tracking

We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on Hulbee and across third party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary of these activities. For more detailed information about these mechanisms and how we collect activity information, see our Cookie Policy.

Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in, to understand how users navigate through and use Hulbee, and to display personalized content and targeted ads (including on third party sites and applications).

Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we use to track the online movements of users of Hulbee and the web pages of users of our Ad Services, and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.

Analytics Tools. We may use internal and third party analytics tools, including Google Analytics. The third party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

Hulbee Ads and Personalization

To show users relevant ads and other personalized content, we may use information we collect on Hulbee, including our pixels, widgets, plug-ins or buttons embedded on third-party sites. We also may report to users of our Ad Services the number of users on Hulbee that saw a particular ad, and certain aggregated demographic information about the visitors to this advertisement.

Users of our Ad Services may also provide us with information as part of their ad campaigns, including customer list information (e.g., email addresses and demographic or interest data) in order to create customized audiences for their ad campaigns; we only use this information to facilitate the particular user’s campaign (including ad metrics and reporting to that user) or for fraud detection and security purposes, and we do not disclose this information to third parties (other than our service providers) unless required by law. We also do not disclose to the users of our Ad Services the names or identities of their customers that were successfully reached as part of such campaigns.

Please see the "Your Choices" section below for information about your choices regarding targeted advertising and personalization, and how you can opt out of personalized ads from us or tracking by our Pixels.

As described in our Cookie Policy, we may also work with third parties such as network advertisers to serve ads on Hulbee and on third-party websites or other media (e.g., social networking platforms), such as Google AdSense (privacy and opt-out info here) and Facebook Audience Network (privacy and opt-out info here). You may opt out of interest-based ads from these third party ad networks. These third parties may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you.

For more information about how to opt out of interest based ads from many ad networks, see our Cookie Policy. Note, if you delete cookies or change devices, your opt-out may no longer be effective.

How We Protect Your Information

The security of your information is important to us. Hulbee has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure, except Swisscows. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using Hulbee on a shared or unsecured device.

Your Choices

You may, of course, decline to submit information through Hulbee, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within Hulbee about you, and otherwise amend certain privacy settings. Here is some further information about some of your choices:

Adult Content. In your profile’s privacy settings, you can elect whether to receive adult content.

Topics. You can change topics that you follow or that your profile lists as areas that you know about.

Credentials. You can change your credentials that are displayed in your profile or in connection with a specific answer.

Indexed Search. In your privacy settings, you can control whether your profile and name is indexed by search engines. Changes to privacy settings may only apply on a going-forward basis; for example, your name (e.g., answers and profile) that has already been indexed by search engines may remain indexed for a period of time even after you have turned off indexing, as implementing this change is outside of our control.

Personalized Advertising and Pixels

You have the opportunity to decide against receiving tailored advertising from Hulbee - with an opt-out.

This opt-out may impact our ability to personalize ads and content tailored to your interests. This setting is tied to your cookies, and, unless you are logged in to Hulbee, will only be effective on the browser for which you have performed the opt-out.

Third Party Ad Networks

For information about and to opt out of interest-based ads from many ad networks, go to:

Linked Networks. You may connect or disconnect your Linked Networks, such as Facebook, through the Account Settings tab in your profile settings.

Your Rights

As noted above, Hulbee gives users several easy-to-use ways to exercise choices about their personal information on the Hulbee platform.

Access Amendment, Deletion, Portability, Objection and Other Rights. Users may have the right to be provided certain personal information in a commonly used format where technically feasible, and, under certain conditions, to object to or restrict our use of certain personal information. You may also contact our privacy coordinator, to access or amend your personal information, to request that we rectify, delete or stop processing your personal information, to withdraw your consent to our processing, and to exercise your opt-out rights or place a data portability request.

Requests should be directed to privacy at hulbee.com (or at the Contact Us information shown below). Please keep in mind that certain services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information. We will respond to your request in accordance with applicable law.

Complaints. You also have the right to lodge a complaint with a supervisory data protection authority.

Retention of Your Data

If you wish to "be forgotten" by Hulbee (i.e., request the deletion of your personal information from Hulbee and the Hulbee Platform), please inform us of your request. Further, any questions you post, threads you start, or other Your Content that other users have responded to or interacted with may continue to appear in the Hulbee Platform, but your user name will be removed from such content.

Transferring Your Data

Hulbee is headquartered in Switzerland, and has operations, entities and service providers in Switzerland and throughout the world. We and our service providers may transfer your personal information to, or access it in, jurisdictions (including within Switzerland). We take steps to ensure that personal information is given adequate levels of protection in the countries where we process them. This includes putting in place appropriate written data processing terms and/or data transfer agreements, using contractual clauses as approved by the European Commission (the form for the standard contractual clauses can be found here), or following an adequacy decision by the EU Commission.

Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 16, or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.

Links to Other Websites

Hulbee may contain links to third-party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at privacy at hulbee.com or send mail to:

Hulbee Enterprise AG
Bucherstrasse 2
9322 Egnach
Switzerland

Changes to Our Privacy Policy

If we change our privacy policies and procedures, we will post those changes on this page. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice in Hulbee or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.

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