Privacy Policy

(Last updated: June 2022)

If you are a resident of the State of California,USA, you are entitled to certain privacy rights. Those can be found here

Thanks for using “HUBLIX”, our virtual world and social space where you can meet people, party and hang out. 

We, HUBLIX LIMITED, a New Zealand corporation with its registered office at Level 5, 129 Hurstmere Road, Takapuna, Auckland 0622 (“we”), need to process certain personal data in order to be able to provide HUBLIX for your use via our mobile app (the “App”). We are the controller for such processing, highly value the protection of your personal data, and observe applicable data protection provisions, especially those of the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act ("CCPA"), as well as the data privacy laws in all the jurisdictions in which we operate and have users.

We have appointed a HUBLIX representative contact in the Republic of Ireland, whom you can contact at MYTONA LIMITED, 1 Grant’s Row, Dublin 2, Ireland.

This privacy policy describes how we process personal data while providing and operating the App, irrespective of the device you are using, and why we collect it, how and based on which legal bases we use it, and how you can exercise your privacy rights.

1.GDPR Definitions

Personal data” means any information relating to an identified or identifiable natural person. This includes your email address, name, user behavior, etc.

"Processing" or "process" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means (such as collection or storage).

Where we use other terms defined in Art. 4 GDPR, we use these terms in accordance with the respective definitions.

Similar terms appear in other data privacy laws and where those terms differ in meaning, we will indicate any other applicable meaning.

2.Processing operations and purposes

This section describes the processing operations carried out by us in connection with HUBLIX.

We may from time to time ask you for your consent to collect other personal data from you or your device. If we do this, we will tell you separately what personal data we would like to collect, why we need it and for what we will use it.

2.1 Accessing HUBLIX via the App

Whenever you visit HUBLIX via the App we automatically collect the following personal data from your device:

  • Your device’s type and model,
  • your operating system,
  • language or other technical data like your device settings,
  • your screen size or processor,
  • your IP address,
  • your internet status,
  • broad information on your geographic location (e.g. country or city-level location),
  • cookie identifiers,
  • information of how you use the App (such as date and time of the visit, access status or https status code, your amount of visits, accessed subpages, time spent in the App, IP address).

We process the above personal data to provide HUBLIX to you, i.e., where necessary for the performance of the agreement between you and us to use HUBLIX (“User Agreement”) or in order to take steps at your request prior to entering into a User Agreement with us. Hence, the processing is based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.2 Cookies

Some personal data is collected using cookies, small files that store information on your device to help us optimize the use of HUBLIX, and/or similar technologies. Some of the cookies are “1st party”, hence our own ones, and others are “3rd party”, hence belonging to advertising and analytics entities or social networks. Cookies are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You may enable or disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use HUBLIX.

For more information on our use of cookies please click here.

2.3 Contact and support

We generally create a support ID and allocate it to you, which helps us identify you for supporting purposes when you use HUBLIX.

If you contact us (e.g., our support) or otherwise provide us with any feedback in connection with HUBLIX, we additionally process the personal data you disclose to us:

  • Your email address (if provided),
  • your telephone number (if provided),
  • your specific concern, along with all information submitted to our support via HUBLIX or email,
  • any additional information our support staff may request from you to be able to help you with your query.

If you reach out to us in connection with your User Agreement, we process your personal data in order to address your concern or answer your questions as necessary to fulfil our contractual obligations towards you. The legal basis for this processing is Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

We also use what we have learnt from your request in order to develop and improve HUBLIX and overall user experience and to customize your experience in HUBLIX (legitimate interests). The legal basis for this processing is Art. 6 (1) (f) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

If you contact us as a third party (e.g., to complain that a user of HUBLIX infringes your rights), we process your personal data to remedy your complaint or otherwise deal with your request (legitimate interests). The legal basis for this processing is Art. 6 (1) (f) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.4 Creation of an account

If you register for HUBLIX and thereby, which is necessary to use HUBLIX, create an account, you must provide the following personal data:

  • Your age,
  • the nickname you choose.

It is not our policy to allow anyone under the age of 16 to provide personal data and we do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use our HUBLIX. In some countries, you must be older than 16 years old to use HUBLIX. We do not want anyone under the relevant age in their country to provide any personal data.

We may verify if you are of the required age. In these cases, we will process information about your age so we may ascertain whether you are using HUBLIX in compliance with our age requirements. If we discover that we have collected personal data about a child under the relevant age, we will delete that personal data as quickly as possible. If you become aware we have collected personal data of a child under age 16, please immediately notify us at privacy@hublix.com.

In addition to the above mandatory personal data, you can add the following personal data to your account’s profile voluntarily:

  • your real name,
  • a description of your profession,
  • your biography,
  • your email address,
  • your phone number,
  • other contact information,
  • a profile photo and/or profile avatar.

We process the above personal data to provide HUBLIX to you, manage your account and improve or customize your user experience, i.e., where necessary for the performance of the User Agreement or in order to take steps at your request prior to entering into a User Agreement with us. Such processing is based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.5 Creation of your unique 3D avatar and furnishing of your virtual home

When you create your unique 3D avatar and/or furnish your virtual home, we process and store your choices and connect them to your account.

We process the related personal data to operate the requested (social) features in HUBLIX for you, customize your experience when using HUBLIX, and send you requested information (such as security alerts), i.e., where necessary for the performance of the User Agreement. Such processing is within the scope of the User Agreement and thus based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.6 Use of particular (social) features

When you use particular (social) features of HUBLIX, such as the “follow” feature, the creation of a hub or meeting with other users of HUBLIX in a hub, we use particular personal data in order to operate these features for you. We process the following personal data, which we collect automatically from you and/or your device:

  • Information about which feature you use,
  • as applicable, whom you follow,
  • as applicable, information about how you interact with the respective feature in HUBLIX (such as progress, session length, preferred settings; which in-App adverts you may have viewed, in-App references or just preferences, what friends you connect with),
  • your IP address, internet status, broad geographic location (e.g. country or city-level location), cookie identifiers,
  • device information, including type of device, device model, device operating system, device settings, its language or other technical data like device settings, screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application, application IDs, device ID, advertising ID (unique identifiers associated with your device that advertisers use for interest based advertising), vendor ID. These technologies allow us and third parties (including marketers and advertisers) to recognise your device when you use websites and applications. They are consistent across all apps and thus allow cross-app tracking.

Whether we collect some or all of this personal data often depends on the type of device used and its settings as well as on the particular feature of HUBLIX.

We process the above personal data to operate the requested (social) features in HUBLIX for you, customize your experience when using HUBLIX and send you requested information (such as security alerts), i.e., where necessary for the performance of the User Agreement. Such processing is within the scope of the User Agreement and thus based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.7 Local events

With your consent, we may process your GPS location to show you local events. Such processing is based on your consent under Art. 6 (1) (a) GDPR and other relevant data privacy laws, such as the CCPA.

2.8 In-App purchases and payment processing

When you make an in-App purchase, we process the following personal data from you:

  • Your User ID and nickname to allocate the in-App purchase to your account,
  • details of the order (such as the item, date, amount, status, description, broad geographic location (e.g., country or city-level location)), and
  • payment status, as provided by the respective app store.

We process the above personal data to provide you the purchased item in HUBLIX, i.e., where necessary for the performance of the User Agreement and the respective purchase agreement. Such processing is within the scope of the User Agreement and necessary for the performance of the respective purchase agreement and thus based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

Please note we do not collect or store any payment information from you when you purchase items via our mobile Apps (such as those you purchase in the App Store, Google Play or other platform). For more information, you may check the privacy policy of the platform you have used.

2.9 Use of HUBLIX chat and messaging system

When you use HUBLIX chat or messaging system, we receive the following information:

  • Your nickname,
  • information on the date and time you use the chat,
  • information on the recipient or sender of messages sent or received by you,
  • the content of messages sent using our chat and messaging systems.

We process the above personal data to provide you with the chat and messaging system (i.e., to enable you to communicate with other HUBLIX users) as part of HUBLIX and to moderate chats either automatically or manually where required. Such processing is within the scope of the User Agreement and thus based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.10 UCG tools

We also provide particular UCG tools for you, as a content creator, to have a more advanced editor, more possibilities to create different hubs and more powerful options for managing your avatar.

When you use such UCG tools, we process the following personal data from you:

  • Your User ID;
  • information on the particular UCG tool you use and when,
  • information on the hubs you created,
  • and information on how you manage your avatar with the UCG tool.

We process the related personal data to operate the requested (social) features in HUBLIX for you, customize your experience when using HUBLIX, and send you requested information (such as security alerts), i.e., where necessary for the performance of the User Agreement. Such processing is within the scope of the User Agreement and thus based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.11 Integrated third-party tools/features

We have integrated and will integrate in the future particular third-party tools or features. Personal data we receive if you link to such third party tools or features with your account in HUBLIX depend on the respective third party and includes several bits of personal data you have provided to that third party.

For example, in the event you use another third-party social network or platform to access HUBLIX, this third party may provide your personal data to us if you so allow. These websites or applications are created by a third party that is not affiliated with or controlled by us. Please be sure to carefully read their terms of service and privacy policy so that you understand how they use your personal data and what might be shared.

You may, at any time, make changes to the personal data that these third-party social networks or platforms share with us by changing your settings for that provider, or stop allowing HUBLIX to interact with that provider. In doing so you may not experience HUBLIX’ special features to the fullest extent.

Facebook login

You can use the Facebook login in order to create an account instead of setting an account up from scratch as described above. If you do so, Facebook is providing us with the following of your personal data:

  • Your full name,
  • Your email address,
  • Device information and unique identifiers.

The processing for the use of the Facebook login is necessary for the performance of the User Agreement and thus can be based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

Google login

You can use the Google login in order to create an account instead of setting an account up from scratch as described above. If you do so, Google is providing us with the following of your personal data:

  • Your full name,
  • Your email address,
  • Device information and unique identifiers.

The processing for the use of the Google login is necessary for the performance of the User Agreement and thus can be based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

Apple Sign In

You can use the Apple Sign In in order to create an account instead of setting an account up from scratch as described above. If you do so, Apple is providing us with the following of your personal data:

  • Your full name,
  • Your email address,
  • Device information and unique identifiers.

The processing for the use of the Apple Sign In is necessary for the performance of the User Agreement and thus can be based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.12 Lost account

If you do not remember your account details, we will ask you for details connected with your account (e.g., your real name, nickname, your email address, support ID) to identify your account and ensure you are the true account holder.

We process such personal data to provide you with access to HUBLIX under the User Agreement. Such processing is based on Art. 6 (1) (b) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

2.13 Surveys, analysis, research and advertising

We may use your email address, HUBLIX activities and interests and/or preferences to send you surveys or involve you in research, or to provide you our offers via email.

For surveys, analyses and research purposes, we also may process personal data, which we may receive from other group companies or third party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregator). This may include your IP address, advertising IDs, device model, operating system, postal code and city of use, your mobile provider, attributes about you and your interests, as well as games and services you use, demographic and general location information. We will use this personal data as described in this privacy policy and subject to the extent of your consent. Such processing is based on your consent under Art. 6 (1) (a) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

We also may track the content you access in connection with HUBLIX and your online behaviour, use the above personal data when processing is necessary and pursued by us for research or surveys or to analyze, profile, and segment, so we constantly can improve our advertising and HUBLIX. In all of the above cases and purposes, we may analyze, profile and segment all collected data (e.g., create reports, analyses or similar for our own research or market purposes, for example to track trends or problems using HUBLIX).

We process this personal data based on Art. 6 (1) (f) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA, thus our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data, in particular where you are a child under the relevant age.

2.14 Fighting fraud

We also process your above personal data (e.g., chat conversations in hubs to detect prohibited content like hate speech or adult content) to fight fraud (such as refund abuse or click fraud in advertising), in order to keep HUBLIX and its social features safe and fair, to prevent crime or cheating and ensure acceptable use otherwise, and to take action against fraudulent or misbehaving HUBLIX users.

We process this personal data based on Art. 6 (1) (f) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA, thus our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data.

2.15 Compliance

We also may use your above personal data when processing is necessary for compliance with legal obligations to which we are subject.

This processing is based on Art. 6 (1) (c) GDPR or, as applicable, other relevant data privacy laws, such as the CCPA.

3. Automated decision-making

We do not use automated decision-making (including profiling).

4. Recipients of your personal data

In this section, we inform you about the recipients of your personal data.

4.1 Other HUBLIX users

Whenever you connect or interact with other users in HUBLIX, we share the following personal data from you with these other users:

  • Your nickname,
  • your real name,
  • your bio, and
  • information about your action (content, date, time).

4.2 Public (account) information

If you decide to make particular information in your account public, or to post in comments, or make otherwise visible to others in chats, forums, and/or blogs where you can post your content in HUBLIX, we share this particular information or content along with your nickname with all other users of HUBLIX.

4.3 Other third-party recipients

When you allow any interaction between HUBLIX and any social network or platform that belongs to a third party, we also share your personal data with your contacts for you to enjoy interacting with others (your name, your profile avatar and particular other information you request to be shared) as requested.

There may be other third-party recipients, such as professional advisers, consultants, tax advisors, auditors and insurance brokers, if required to fulfil our legal obligations and/or to defend our rights.

We may share your personal data with public authorities, courts, government representatives and/or other third parties as necessary in accordance with applicable law and regulations.

We may provide your personal data to third parties when there is a corporate restructuring or sale of assets involving us, or as a result of a change in control, or to prepare for any of these events.

We also may provide third parties with anonymous and statistical data which contains no personal data.

4.4 Processors

We may share your personal data with third party providers and partners who provide data processing services to us and with whom we have relevant signed agreements in accordance with Art. 28 GDPR or, as applicable, other relevant data privacy laws, such as the CCPA, such as technical support providers, software providers, advertising and marketing partners

5. Non-EU/EEA recipients of your personal data

HUBLIX is global by nature and your personal data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your personal data as required by European Union data protection laws and those of other countries with jurisdiction, as applicable. These safeguards include implementing the European Commission’s Standard Contractual Clauses and other measures recognized in other jurisdictions for transfers of personal data between our group companies and third party service providers and partners, which require all group companies to protect personal data they process from the European Economic Area (EEA), plus the United Kingdom and in accordance with European Union data protection law.

6. Retention periods

Your personal data will be stored as long as is necessary for you to provide to HUBLIX or for HUBLIX to provide to you or to complete whatever purpose it was originally provided for. But please note even after you have closed your account or have stopped using HUBLIX, we may continue to store your personal data if doing so is necessary for us to fulfil our legal obligations. 7. Your privacy rights

7. Your privacy rights

If you are in the European Economic Area, the United Kingdom and Switzerland you have the following data protection rights:

7.1 Art. 15 GDPR

You have a right to know what personal data we hold about you, how and why we handle your personal data. You can ask us for a copy of your personal data and to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any personal data. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal data about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.

7.2 Art. 16 GDPR

You have a right to request an update or correction to any of your personal data, which is out of date, incomplete or incorrect.

7.3 Art. 17 GDPR

You have a right to ask us to delete your personal data, which we are holding about you. We will pass your request onto other recipients of your personal data unless that is impossible for us. Please note some things can only be deleted when you delete the App from your mobile devices and clear our cookies from any device that you have used for HUBLIX. In that case, you will permanently lose all your progress in HUBLIX, virtual currency and virtual goods (if any). Where we delete personal data about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your personal data in an anonymised form. In some instances, personal data about you that is visible through your use of HUBLIX such as username, avatar and any chat messages may be cached on other HUBLIX users’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a network.

7.4 7.4 Art. 18 GDPR

You have a right to object to the processing of personal data about you, which is processed on the grounds of legitimate interests. You can ask us for further information on the specific circumstances.

7.5 Art. 20 GDPR

You have the right to request that personal data, which you have provided to us is provided to you in a commonly readable format, so you can transfer it to another data controller.

7.6 Art. 21 GDPR

You have the right to object at any time to processing of your personal data when processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where you are a child.

You also can opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”.

7.7 Art. 7 (3) GDPR

The right to withdraw at any time your consent on which a processing of your personal data is based under the GDPR. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You can assert any or all of these rights and contact us for further information by sending an email to privacy@hublix.com or by post to HUBLIX LIMITED, a New Zealand corporation with its registered office at Level 5, 129 Hurstmere Road, Takapuna, Auckland 0622, and letting us know what personal data in particular you are referring to and what you wish us to do with it.

You also have the right to file a complaint with a data protection supervisory authority about our processing of your personal data if you are in the European Economic Area, the United Kingdom or Switzerland.