1. Who is responsible
Hubly Technologies Ltd is the controller of the personal information described in this notice.
Company number: 12199897
Registered office: 2 Cranmer Road, Riverhead, Sevenoaks, England, TN13 2AT
Privacy contact: [email protected]
If you contact us about privacy, please write “Privacy request” in the subject line. We may ask for information reasonably needed to confirm your identity before acting on a rights request.
2. Information we collect
Depending on how you use the site, we may collect:
- Contact information: your name, email address and any organisation you represent.
- Hub name information: the name you request, a suggested @handle, account or community category, request status, email verification status and relevant correspondence.
- Enquiry information: the enquiry category, message content, attachments you choose to send and our response.
- Verification or subscription interest: the service you are interested in and information needed to respond. This website does not currently collect payment details.
- Safety information: the outcome of initial name screening, potential policy matches, reports, complaints, evidence and review outcomes.
- Technical information: IP address, device and browser information, requested pages, timestamps, diagnostic and security logs. Our hosting and security providers may generate this information when serving the site.
- Preference information: your browser storage and analytics choice and whether you snooze the investor notice.
Your email address and the information marked as required on a form are needed to handle that request. You do not have a legal duty to provide them, but without them we may be unable to respond, verify contact details or maintain a Hub name request.
Please do not send sensitive personal information unless we ask for it and explain why it is needed. If a safety or rights complaint requires sensitive information, we will limit its use to handling that matter and meeting our legal obligations.
3. Where information comes from
Most information comes directly from you. We may also receive or confirm information from:
- a person acting for a business, organisation, family or rights holder;
- public sources, such as official registers, an organisation's website, public social profiles, trade mark records or news sources, where needed to assess a Hub name or verification claim;
- service providers that help us host, secure or operate the website and email communications; and
- people who report impersonation, infringement, misuse or a safety concern.
If we obtain your information from another person, we will provide this notice where required and will not use it for an unrelated purpose.
4. Why we use information and our lawful bases
| Purpose | Information | Lawful basis |
|---|---|---|
| Respond to enquiries and requested information | Contact and enquiry information | Steps at your request before a contract, and our legitimate interest in communicating with people interested in Hubly |
| Receive and assess Hub name requests | Contact, Hub name, safety and request information | Steps at your request before a contract, and our legitimate interests in allocating names fairly and protecting the service |
| Operate name screening and prevent abuse, fraud, impersonation or infringement | Hub name, technical, safety and public-source information | Our legitimate interests in keeping Hubly safe, trustworthy and available; legal obligations where applicable |
| Manage Beta, verification and subscription interest | Contact, enquiry and interest information | Steps at your request before a contract and our legitimate interest in planning and communicating about launch |
| Operate, secure, diagnose and improve the website | Technical, security and limited usage information | Our legitimate interests in running a secure and effective website; consent where non-essential storage or analytics requires it |
| Keep records, establish legal rights and comply with law | Relevant contact, request, technical, safety and correspondence records | Legal obligations and our legitimate interests in defending claims and demonstrating compliance |
Where we rely on legitimate interests, we consider the need for the use, its likely effect on you and the safeguards available. You may object to processing based on legitimate interests. We will stop unless we have compelling grounds to continue or the information is needed for legal claims.
We do not currently send general marketing solely because you submit a Hub name or enquiry. If we introduce optional marketing, we will ask for any consent required and every message will explain how to unsubscribe.
5. Name screening and human review
Before we ask for your email, the site sends the proposed Hub name to the reservation service for a non-mutating availability probe. The probe runs the same normalisation, reserved-prefix, Hub-uniqueness, active-reservation and Shield / OpenAI safety rules that the reservation step uses, without storing a record, sending an email or minting a verification token. A passing probe means only that no rule rejected the name at that moment. It does not grant ownership, suitability or final approval, and the reservation step that follows still re-checks the name before persisting anything.
A flag from the probe does not produce a legal or similarly significant decision about you. A person can review disputed, sensitive or higher-risk cases before a final name decision. You can ask for review or appeal a name decision using the process in the Hub Name Policy.
7. International transfers
Some service providers may process information outside the United Kingdom. Where UK data protection law requires a safeguard, we use an adequacy regulation, the UK International Data Transfer Agreement or UK Addendum, or another lawful transfer mechanism. We also consider technical and organisational protections. You may contact us for more information about the safeguard used for a particular transfer.
8. How long we keep information
We keep information only while it is needed for the relevant purpose, taking account of the status of a request, safety and dispute risks, legal limitation periods and regulatory duties. Our current guide is:
| Record | Typical period or criterion |
|---|---|
| General enquiries and Beta interest | Up to 24 months after the last meaningful contact, unless an active relationship, complaint or legal reason requires longer |
| Hub name request records | While the request or reservation remains active, then normally up to 24 months to resolve ownership, release, safety or dispute issues |
| Rights, safety and legal complaints | For the life of the matter and then for the period reasonably needed to evidence the outcome or deal with legal claims, normally no longer than six years |
| Security and diagnostic logs | Normally up to 12 months, unless needed to investigate an incident or comply with law |
| Cookie or browser-storage preference | Up to 12 months, unless you clear it sooner or a new choice is required |
| Investor notice snooze | 14 days |
We may keep a minimal suppression or decision record for longer where it is needed to respect an objection, prevent repeated abuse or demonstrate that a matter was resolved. We securely delete or anonymise information when it is no longer needed.
9. Security
We use measures designed for the nature of the information and the risks involved, including access controls, secure hosting, encryption in transit, logging, provider review and restricted internal access. No online service can promise absolute security. If you believe information connected with Hubly is at risk, contact [email protected] promptly with “Security report” in the subject line and avoid sending exploit code or sensitive data unless requested.
10. Your rights
Depending on the circumstances, UK data protection law gives you the right to:
- be informed about how your information is used;
- ask for a copy of your personal information;
- correct information that is inaccurate or incomplete;
- ask us to erase information;
- ask us to restrict its use;
- object to use based on legitimate interests or for direct marketing;
- receive certain information in a portable format; and
- withdraw consent at any time where consent is the lawful basis.
These rights are not absolute. We will explain if a legal exception applies. There is normally no fee, and we aim to respond within one month, although the law permits an extension for a complex request. Where the law allows, the response period may pause while we wait for information reasonably needed to clarify or handle the request. To exercise a right, email [email protected].
11. Children and families
The pre-launch website does not offer live accounts. People aged 13 or over may submit a personal Hub name request or general enquiry. A parent or guardian must submit for someone under 13. If you believe a person under 13 has sent us information without a parent or guardian, please tell us so we can review and delete it where appropriate.
Planned child, teen and family services will not be activated solely on the basis of this notice. Before launch, we will provide age-appropriate information and safeguards designed around the best interests of children. See Young People and Families.
12. Questions and complaints
To make a data protection complaint, email [email protected] with “Data protection complaint” in the subject line. Explain what happened, the information or activity concerned and the outcome you seek.
We will acknowledge a data protection complaint within 30 days, investigate it without undue delay, keep you informed if the response is delayed, and tell you the outcome and your right to raise the matter with the Information Commissioner's Office.
You may complain to the ICO through ico.org.uk/make-a-complaint. We would appreciate the opportunity to address the concern first, but you do not lose the right to contact the ICO.
13. Changes to this notice
We will update this notice as the website and Beta service develop. We will change the date above and, where a change materially affects people, provide a prominent notice or contact affected people when appropriate. Earlier versions may be requested from our privacy contact.