Privacy Policy

1. Summary

• We collect the information you give us, information from the accounts you connect (Shopify, Meta), information we gather automatically when you use the Services, and public signals from third-party sources such as Reddit and TikTok.
• We use this information to build your Brand DNA, mine signals, generate advertising creative, publish ads to your Meta account with your authorization, provide support, and improve the Services.
• We request administrator access to your Shopify store so we can see which products actually sell. We do not read your customers' emails, we do not sell your personal information, and we do not train shared AI models on your account data.
• We keep a full audit log of what Hubble does in your connected accounts, available to you in your dashboard.
• You can access, correct, export, or delete your information at any time. You can disconnect any integration, and you can wipe your Hubble data with a single action in your dashboard.
• Depending on where you live, you may have additional rights under the GDPR or United States state laws, set out in the "Regional disclosures" section.

2. Information we collect

We collect information about you when you provide it to us, when you use the Services, and from other sources, as described below.

2.1 Information you provide

• Account and profile information. When you register, we collect your name, email address, brand name, and website. You may add further profile details and set preferences within the Services.
• Billing information. If you subscribe to a paid plan, our payment processor collects your billing details, such as your billing name, address, and payment card information. We do not store full payment card numbers ourselves.
• Content and communications. Information you submit when you contact support, respond to a survey, provide feedback, participate in a promotion, or otherwise communicate with us, including any files or screenshots you send to support.

2.2 Information from accounts you connect

Hubble only accesses connected accounts after you authorize the connection, and only to the extent needed to provide the Services. You can revoke access at any time.

• Shopify. With administrator access, we read your product catalog, order and sales data, and store configuration. This tells Hubble which products sell and which deserve ad spend. We do not access your customers' email inboxes or message content.
• Meta. We read your ad account structure, campaigns, ad sets, creative, and performance metrics, and we publish new ads to your account when you activate them. Publishing only happens on your instruction.
• Store and website content. During onboarding, Hubble crawls your public website and store to learn your brand voice, differentiators, and proof points.

2.3 Information we collect automatically

• Usage information. The features you use, the actions you take, the content you interact with, and how you navigate the Services.
• Device and connection information. Your device type, operating system, browser type, IP address, device identifiers, referring and exit URLs, and diagnostic and crash data. We use your IP address to approximate your location to provide a better and more secure experience.
• Cookies and similar technologies. See the "Cookies and tracking technologies" section.

2.4 Information from third-party sources

To surface the signals that inform your creative, Hubble collects publicly available information from sources such as Reddit, TikTok, competitor ad libraries, and review platforms. This is public content about products, categories, and trends, not private information about you. We may also receive information about you from our partners and service providers, such as billing and analytics providers, to operate and improve the Services.

2.5 Sensitive information

We do not seek to collect sensitive information (such as information about health, race, religion, or political views) and ask that you do not provide it through the Services. Where we do handle sensitive information, we do so only with your consent or as otherwise permitted by law.

3. How we use information

How we use information depends on which Services you use and how you use them. We use information for the following purposes:

• To provide the Services. Building your Brand DNA, mining signals, generating creative, and publishing ads to your Meta account when you activate them.
• To personalize output. Everything Hubble produces is shaped by your brand, your buyers, and your category, so the creative sounds like you.
• To process transactions. Setting up and managing your subscription, processing payments, and sending you related information.
• To communicate with you. Sending transactional messages about your account, subscription, and support requests, and, where you have opted in or where permitted, product updates and marketing.
• To provide support. Resolving issues you raise, and using what we learn to improve the Services.
• To maintain safety and security. Verifying accounts, detecting and preventing fraud, abuse, and security incidents, and protecting the Services and their users.
• To improve and develop the Services. Understanding how the Services are used so we can fix problems, build features, and improve performance. We do not use your account data to train AI models that are shared across other customers.
• To meet legal obligations and protect rights. Complying with applicable law, responding to lawful requests, and enforcing our agreements and rights.
• With your consent. For any other purpose we describe to you and to which you consent.

4. Legal bases for processing

Where the GDPR or similar laws apply to you, we rely on the following legal bases to process your personal information:

• Performance of a contract. To provide the Services you have signed up for, process payments, and provide support.
• Legitimate interests. To develop, improve, and secure the Services, to conduct direct marketing, and to protect our legal rights, where those interests are not overridden by your rights.
• Consent. For certain marketing, for non-essential cookies, and for any other processing where we ask for your consent. You can withdraw consent at any time, without affecting processing already carried out.
• Legal obligation. Where we must process your information to comply with a legal or regulatory obligation.

5. How we disclose information

We do not sell your personal information. We disclose information only in these circumstances:

• Service providers and sub-processors. We work with providers for hosting, storage, payment processing, analytics, communications, and support. They may access information only to perform services for us, under contractual confidentiality and security obligations.
• AI providers. Hubble uses third-party AI models to generate creative. Content sent for generation is processed to produce your ads and, where the provider's terms allow us to prevent it, is not used by those providers to train shared models.
• Connected platforms. When you publish an ad, the ad and its associated data are sent to Meta. When you connect a platform, information flows between Hubble and that platform according to your authorization and that platform's own terms.
• Legal and safety. We may disclose information where reasonably necessary to comply with law, respond to a lawful request from a public authority, enforce our terms, or protect the rights, safety, and property of Hubble, our users, or the public.
• Business transfers. If Hubble is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction. We will notify you of any change in ownership or control of your personal information.
• With your consent. Where you ask us to share information or agree to us doing so.

6. Our sub-processors and AI providers

To provide the Services, we rely on a small number of trusted third parties who process personal information on our behalf. These include:

• Cloud hosting and storage providers, who host the Services and store data.
• Payment processors, who handle billing and payment information for paid plans.
• AI model providers, who process content we send to generate advertising creative.
• Analytics and product-monitoring providers, who help us understand and improve how the Services are used.
• Communications providers, who help us send transactional and marketing messages.

We enter into data protection terms with each sub-processor that require them to protect personal information and to process it only on our instructions. We can provide our current list of sub-processors on request.

7. Cookies and tracking technologies

We and our providers use cookies and similar technologies (such as pixels, tags, and local storage) to operate and improve the Services.

• Essential cookies keep you signed in, remember your preferences, and keep the Services secure. The Services do not work properly without them.
• Analytics cookies help us understand how the Services are used so we can improve them.
• Marketing cookies, where used, help us measure and deliver relevant advertising.

You can control cookies through your browser settings, and, where required by law, we ask for your consent to non-essential cookies and honor recognized opt-out signals such as Global Privacy Control (GPC). Blocking some cookies may affect how the Services work.

8. How we store and secure information

We use technical and organizational measures designed to protect your information, including encryption in transit, access controls, environment separation, and a full audit log of the actions Hubble takes in your connected accounts. We restrict access to personal information to people who need it to do their jobs.

No system is perfectly secure, and we cannot guarantee absolute security, but we work to protect your information and to respond promptly if something goes wrong.

9. International data transfers

Hubble is based in Australia and may store and process information in Australia, the United States, the European Union, and other countries where we or our service providers operate. These countries may have data protection laws different from those in your country.

Where we transfer personal information across borders, we take steps to protect it as required by applicable law. For transfers from the EEA, the United Kingdom, or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum where relevant), or another lawful transfer mechanism.

10. How long we keep information

How long we keep information depends on the type of information, the purpose for which it was collected, applicable legal requirements, and your preferences.

• Account information is kept while your account is active and for a reasonable period afterward in case you reactivate, and as needed to meet legal obligations, resolve disputes, and enforce our agreements.
• Connected-account data is processed while your integration is active. When you disconnect an integration or wipe your data, we delete the associated data, except where we must retain limited records to meet a legal obligation.
• Billing records are kept as required by tax and accounting law.
• Marketing information is kept until you unsubscribe or a reasonable period after your last engagement with us.

When we no longer need information, we delete or de-identify it. Where immediate deletion is not possible because information sits in backups, we isolate it from further use until deletion is possible. You can wipe your Hubble data at any time using the wipe action in your dashboard.

11. Data breach notification

We maintain procedures to detect, investigate, and respond to security incidents. If a data breach is likely to result in serious harm (or otherwise where notification is required by applicable law, such as the Notifiable Data Breaches scheme under the Australian Privacy Act or the GDPR), we will notify the relevant regulator and affected individuals as required, and describe the steps we are taking in response.

12. How to access and control your information

• Access and correct. You can view and update your account and profile information in your dashboard, and you can request access to other information we hold about you.
• Export. You can request a copy of your information in a portable, machine-readable format.
• Delete. You can delete your Hubble data or close your account at any time. Some information may be retained where required by law.
• Disconnect integrations. You can revoke Hubble's access to any connected account (Shopify, Meta) at any time, from within Hubble or from the platform itself.
• Object and restrict. Where applicable law gives you the right, you can object to or ask us to restrict certain processing.
• Opt out of marketing. You can unsubscribe from marketing emails using the link in any such email. You will still receive transactional messages about your account.
• Withdraw consent. Where we rely on consent, you can withdraw it at any time.
• Cookies. You can control cookies through your browser settings.

To make any request, contact us at admin@gethubble.ai. We may need to verify your identity before acting on a request. Where an authorized agent makes a request on your behalf, we may ask for proof of authorization. We respond within the timeframes required by applicable law, and we will not discriminate against you for exercising your rights.

13. Children

The Services are not intended for anyone under the age of 18, and we do not knowingly collect personal information from anyone under 18. If we learn that we have collected such information, we will delete it. If you believe a child has provided us with personal information, please contact us.

14. Regional disclosures

14.1 Australia

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. If you have a concern about how we handle your personal information, contact us first at admin@gethubble.ai. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

14.2 European Economic Area and United Kingdom

If you are in the EEA or the UK, we process your personal information on the legal bases set out in the "Legal bases for processing" section, and you have the right to:

• request access to and a copy of your personal information;
• ask us to correct or update your personal information;
• ask us to delete your personal information;
• object to, or request that we restrict, certain processing;
• request that we transfer your information to another provider (data portability);
• withdraw consent where we rely on it; and
• lodge a complaint with your local data protection authority.

We are the controller of the personal information described in this policy. Where we process content on behalf of our customers to provide the Services, we act as a processor and handle that content under our agreement with the customer.

14.3 United States

If you are a resident of a US state with a comprehensive privacy law (such as California, Virginia, Colorado, Connecticut, or Utah), you may have the right to:

• confirm whether we process your personal information and access it;
• request a copy of your personal information in a portable format;
• correct inaccurate personal information;
• request deletion of your personal information;
• opt out of the "sale" or "sharing" of personal information and of targeted advertising; and
• not be discriminated against for exercising your rights.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising in a way that requires an opt out beyond the cookie controls described above. Where required, we honor recognized opt-out preference signals such as Global Privacy Control. To exercise your rights, contact us at admin@gethubble.ai. You may use an authorized agent, and you may appeal a decision by replying to our response.

15. Changes to this policy

We may update this policy from time to time. If we make significant changes, we will provide notice through the Services or by email, and we will update the effective date at the top. Your continued use of the Services after a change takes effect means you accept the updated policy. We keep prior versions available on request.

16. How to contact us

Hubble App Pty Ltd (ABN 37 684 401 732)

Email: admin@gethubble.ai

If you have a question or concern about how we handle your information, contact us first and we will work to resolve it.