Privacy Policy

HubLink (“HubLink”, “we”, “our” or “us”) respects your privacy. This Privacy Policy explains, in plain language, how we collect, use, share, retain and protect information when you use our website, our online platform, and the Hx1 Home-Station.

We've written this policy to be readable end-to-end. If a term is not defined here, it has the meaning given to it in our Cookie Policy or the Terms & Conditions applicable to your account.

By using our website or services, you agree to the practices described here. If you do not agree, please do not use our services.

This Privacy Policy applies to:

• hublink.tech and related HubLink websites;
• the HubLink customer portal and web applications;
• the Hx1 Home-Station and its software;
• HubLink support and communications channels;
• marketing communications you receive from us;
• any future HubLink service, unless a separate notice specifies otherwise.

It does not apply to third-party websites, products or services that may be linked from our pages. Their practices are governed by their own privacy policies.

• Personal information means any information relating to an identified or identifiable individual.
• Processing means any operation performed on personal information (collection, storage, use, disclosure, deletion, etc.).
• Hx1 or Hx1 Home-Station means the HubLink hardware device installed at a participant's premises.
• Operational telemetry means the technical information the Hx1 and our platform transmit in order to run, maintain and secure the network (see the dedicated section below).
• Network means the distributed infrastructure operated by HubLink and its participants.
• Participant or you means the person using our services or operating an Hx1.

We collect only the information we need to operate the service, keep it secure, and comply with our legal obligations. The categories below describe what we may collect.

Information you provide

• Name and email address;
• Country and, where relevant, region or address;
• Account credentials and authentication factors;
• Marketing and communication preferences;
• Content of support requests, feedback and other communications you send us;
• Where required, identity and verification information (for example to receive rewards).

Account information

• Account identifiers and unique user IDs;
• Account status, verification status and role;
• Referral information, where applicable;
• Preferences and dashboard configuration.

Website usage information

• Pages visited, referring URLs and session duration;
• Aggregate interaction metrics needed to improve the site;
• Information stored via cookies and similar technologies as described in our Cookie Policy.

Device information

• Browser type and version, operating system and language;
• IP address and approximate location derived from it;
• Device identifiers used for security and abuse prevention.

Operational network telemetry (Hx1)

If you operate an Hx1, the device transmits operational information required to maintain and secure the network. This is covered in detail in “Operational Telemetry” below.

We use the information we collect to:

• Create and manage your account;
• Provide, operate and maintain the HubLink platform and network;
• Authenticate you and secure access to your account;
• Ship and support your Hx1 Home-Station;
• Monitor the health, performance and reliability of the network;
• Prevent, detect and respond to fraud, abuse and security incidents;
• Process rewards, invoices, taxes and other transactional items;
• Respond to your questions and support requests;
• Improve our products, documentation and user experience;
• Send you service and operational notifications, and — with your consent where required — marketing communications;
• Comply with applicable law and enforce our Terms.

Where the EU General Data Protection Regulation, the UK GDPR or a similar framework applies, we process personal information under one or more of the following legal bases:

• Contract — to enter into or perform a contract with you (for example, to create your account, ship an Hx1, or deliver the service).
• Legal obligation — to comply with obligations to which we are subject (tax, accounting, regulatory requests).
• Legitimate interests — for example to keep the network and our systems secure, to prevent fraud, and to improve our services. We balance these interests against your rights.
• Consent — where required, for example for certain marketing communications or non-essential cookies. You can withdraw consent at any time.

Running a distributed network requires each Hx1 Home-Station to share basic operational information with HubLink. This is what keeps the network reliable, secure and up to date.

Operational telemetry may include:

• Uptime and connectivity status;
• Software and firmware versions;
• Hardware diagnostics and health signals;
• Performance metrics needed to operate the network;
• Error reports needed to identify and fix issues.

HubLink does not inspect, monitor or log your personal browsing activity. The Hx1 is designed to contribute unused capacity and to report operational health only. Where a specific service that you knowingly enable requires additional processing, that will be disclosed at the point you enable it.

For more on the risks and characteristics of participating in a distributed network, please see the Risk Disclosure provided with your account.

We do not sell your personal information. We share it only when needed to run the service, comply with the law, or with your instruction.

Information may be shared with:

• Service providers we engage under contract — including cloud infrastructure, payment processors, identity verification providers, email and support platforms, analytics providers, and shipping partners;
• Professional advisers such as auditors, lawyers and accountants, under appropriate confidentiality obligations;
• Authorities and regulators when we are legally required to do so, or to protect rights, safety and property;
• Parties involved in a corporate transaction — for example, in the context of a merger, acquisition or asset transfer, subject to appropriate protections.

Service providers are bound by contract to protect your information and use it only for the purposes we specify.

HubLink operates internationally. Your information may be processed in countries other than the one where you live, including in jurisdictions whose data protection laws differ from yours.

Where required, we implement appropriate safeguards for international transfers, such as the European Commission's Standard Contractual Clauses, equivalent transfer mechanisms, and supplementary technical and organizational measures.

We keep personal information only for as long as we need it, taking into account:

• the duration of your relationship with HubLink;
• legal, tax, accounting and regulatory obligations;
• the need to resolve disputes and enforce our agreements;
• security, fraud prevention and network integrity requirements.

When we no longer need your information, we delete it or anonymize it. Retention periods vary by category of information and applicable law.

We apply technical and organizational measures designed to protect your information against unauthorized access, alteration, disclosure and destruction. These include:

• Encryption of communications in transit;
• Encryption of sensitive data at rest, where appropriate;
• Signed firmware and secure update mechanisms for the Hx1;
• Access controls and least-privilege internal access;
• Monitoring, logging and abuse detection;
• Vulnerability management and regular software updates;
• Vendor security due diligence.

No system is perfectly secure. While we work hard to protect your information, we cannot guarantee absolute security. You are also responsible for keeping your credentials safe.

Depending on where you live, you may have the following rights in relation to your personal information:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Request deletion of your information;
• Request restriction or object to certain processing;
• Request portability of information you provided to us;
• Withdraw consent where processing is based on consent;
• Lodge a complaint with your local data protection supervisory authority.

To exercise these rights, contact us at hello@hublink.tech. We may need to verify your identity before we can respond, and we may decline requests where an exception applies under the law.

If you have opted in — or where permitted by law — we may send you product news, updates and offers. You can unsubscribe at any time using the unsubscribe link in the email, or by contacting us.

Even if you unsubscribe from marketing, we will continue to send operational and service-related communications (for example, order updates, security notices or important changes to our terms).

HubLink is not directed to children and is intended for individuals who have reached the age of majority in their jurisdiction — and, in any case, at least 16 years old.

We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

Our website and platform may link to, or integrate with, third-party services (for example, payment providers, analytics tools, identity verification providers, or external documentation). These services are governed by their own privacy policies. We recommend reviewing them.

HubLink is not responsible for the content, security or privacy practices of third-party services.

We use cookies and similar technologies to operate the site, remember your preferences, keep your session secure, and measure how our services are used.

A detailed description of the cookies we use, their purpose and how to control them is available in our Cookie Policy.

We may update this Privacy Policy from time to time to reflect changes in our services, applicable law, or industry practice.

When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, notify you through the platform or by email. We encourage you to review this page periodically.

If you have questions about this Privacy Policy or about how we handle your information, please contact us:

• Email: hello@hublink.tech

Related documents: Cookie Policy. The Terms & Conditions and Risk Disclosure applicable to your account are provided when you register and are also available on request.