Updated August 26, 2022.
HBLE, LLC ("Hubble", “we”, “our” or “us”) develops Hubble a campaign management platform (the “Platform”), used by various candidates, organizations, and community organizers to manage and engage with fellow neighbors, constituents, and volunteers in political campaigns (a “Universe”).
Hubble maintains and operates the website hubble.vote, its subdomains and its related features (collectively, the “Site”) as well as the Hubble mobile application (the “App“), and access to the Platform is made possible through both (the Platform, together with the Site and App – the “Services”).
We collect data regarding users of our Platform, as well as Visitors to our site and app.
Such data is typically collected and generated through your interaction with our Services, through automatic means, or directly from you or your Universe Owner or Manager.
Personally Identifiable Information (“PII”) is information that, when used alone or with other relevant data, can identify an individual. PII may contain direct identifiers (e.g., voter identification numbers) that can identify a person uniquely, or quasi-identifiers (e.g., sex) that can be combined with other quasi-identifiers (e.g., date of birth) to successfully recognize an individual.
DATA AUTOMATICALLY COLLECTED OR GENERATED: When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them via our Services, we may collect certain technical data about them. We collect or generate such data either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies. Such data mainly consists of technical and aggregated usage data, such as IP address, non-identifying data regarding a device, operating system and browser, and user activity on our Services. It does not enable us to learn a person’s true identity or contact details and serves mostly so we could better understand how our users typically use our Services and how we could improve their user experience, our marketing Universes and engagements, and the overall performance of our Services.
DATA RECEIVED FROM YOU: You may provide us PII when you create your account (as an Owner, Manager, Member, or Engager), such as your name, contact details (such as e-mail, phone and address), profile image, account login details (such as usernames and hashed passwords) (collectively, “Account Data”), as well as any other data you choose to provide when you visit our Services, or when you contact us. You may also provide us PII when using our Platform to engage with a Universe. Such activities include but are not limited to: registering for an event with or without public comment, signing a petition with or without public comment, or responding to a canvass or online survey.
Owners may also provide us additional Account Data in order to complete their selected transaction as well as their Universe’s information and preferences. To the extent that such information concerns a non-human entity (e.g., a company or business), we do not regard it as PII and this Notice shall not apply to it. As the Platform enables Owners and Managers to require or ask their Members to submit additional PII, and as Owners, Managers, Members and Engagers may choose to submit additional PII and share it with their Universe or certain other Members, the list above is not exhaustive. We will, however, indicate on the Platform, for each PII parameter, if it is “required” or “optional” for either the adequate performance of our Services or per the Owner’s or Manager’s requirements.
DATA RECEIVED FROM OWNERS AND MANAGERS: Owners and Managers may use the Platform to add and invite Members to their Universe. When doing so, they may already submit such Members’ PII as listed in above, in whole or in part. Any Owner and Manager doing so are solely responsible to ensure the legal basis and authority for processing such PII, its accuracy and completeness, and for providing sufficient notice and choice to their Members regarding the use of their data. The Owners are the “Data Controller” of such data, and Hubble solely acts as their “Data Processor” (as such roles are further explained below).
Certain data protection laws and regulations typically distinguish between two main roles for parties processing PII: the “Data Controller”, who determines the purposes and means of processing, and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Hubble processes certain data collected by our Services solely on each Owner’s behalf and such Owner retains ownership of their respective data. Each Owner is the “Data Controller” of their Managers’, Members’, and Engagers’ PII (excluding Account Data), when Hubble processes such data. This means that in such cases, we will only process such data in accordance with the reasonable instructions of the Owner, subject to our Terms of Service and our contractual agreements, and strictly on their behalf. The Owner will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
Hubble is the “Data Controller” of all data that’s required to operate our Services. This includes but is not limited to the Account Data of users, the geocoordinate positions of Addresses, and Voter Information and History received from public records. In addition, certain PII when it processes such data for its own purposes. This means that when processing is performed for Hubble purposes (as set forth under this Notice), namely PII which pertains to Owners, Managers, Members, and Engagers overall use of our Services, then Hubble will control such data, and assume the responsibilities of Data Controller (solely to the extent applicable under law).
We are committed to securing your data and use many security measures to better protect it. However, as we can’t guarantee absolute protection, we encourage you to be aware of the risk when using the services or providing us with your personal data.
In order to protect your PII held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of the security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
We may share your data with certain third parties, including certain service providers, law enforcement agencies and our affiliated companies – but only in accordance with this notice.
Sharing PII with Owners, Managers, Members and Engagers of your Universe: Once you join a Universe, your user profile will be made available to all Owners and their appointed Managers of such Universe. All or part of your user profile may also be made available to other Members of a Universe you join, according to the discretion of the Owners and Managers of that Universe. Please note that Hubble is not responsible nor controls any further disclosure, use or monitoring by or on behalf of your Owners, Managers or Members.
Compliance with Laws, Legal Process and Authorities: We may disclose or allow government and law enforcement officials access to certain PII, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting and server co-location services, data analytics services, marketing agencies and advertising services, data and cybersecurity services, fraud detection and prevention services, user engagement services, e-mail distribution and monitoring services, session recording, remote access services, and our business, legal, financial and privacy advisors) (collectively, “Service Providers“). These Service Providers may have access to your PII, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. Hubble remains responsible and liable for any PII processing done by Service Providers on its behalf, other than for events outside of its reasonable control.
Third Party Integrations: The Services may allow you to integrate with certain third-party services, in which case you will be bound by the terms of service and privacy notices of said third parties – so please make sure you read and accept them. We do not receive or store your passwords for any of these third-party services.
Protecting Rights and Safety: We may share your PII with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Hubble, any of our users or any members of the general public.
For the removal of doubt, Hubble may share your PII in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or we have successfully rendered such data not PII. We may transfer, share or otherwise use non-PII in our sole discretion and without the need for further approval.
Owner, Manager, and Member Account Data Retention: We retain the Account Data of Owners, Managers, and Members as reasonably necessary to preserve and expand our mutual relationship, and thereafter in accordance with our Data Retention Policy.
Member Data Retention: Manager, Member, and Engager Data Retention: We retain the PII of Managers, Members, and Engagers (to the extent that we are the “Data Processor” of such Member data) as instructed or authorized by the Owner, and thereafter in accordance with our Data Retention Policy.
Visitor Data Retention: We retain indefinitely all data collected on visitors to our Services.
If you have any questions about our Data Retention Policy, please contact us at email@example.com.
We use PII in order to provide our services and make them better and safer; in accordance with our contractual obligations towards community owners; to contact our visitors and users, and in order to comply with applicable laws.
We collect and use PII for the following purposes, in order to facilitate and perform our engagements with our users, in order to comply with the laws applicable to us, and based on our legitimate interests for maintaining and improving our Services and protecting and securing our Services, ourselves and our users:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our Owners and their Managers and Members, and allow them access to our Services;
- To provide our Owners and their Managers, Members, and Engagers with assistance and technical support;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To contact our Visitors, our Owners and their Managers, Members and Engagers, with general or personalized service-related messages (such as password-retrieval); to contact our Visitors, Owners and Managers with promotional messages (such as newsletters, webinars, new features etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
We or our partners may send promotional communications, that you can easily opt-out of receiving. We may also contact you with service-related communications. You will not be able to opt-out of receiving such communications.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, service changes, password-retrieval notices, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also send notifications about new services, events and special opportunities or any other information we think our Owners and Managers will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing Universes on any other sites or platforms.
If you wish not to receive such promotional communications, you may notify Hubble at any time by e-mailing us at firstname.lastname@example.org or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions contained in the promotional communications you receive.
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and Universes. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall PII, such as an IP address, previously indicated by the user. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
Hubble uses certain monitoring and tracking technologies, such as cookies, beacons, pixels, tags and scripts (collectively, “Cookies”). Cookies are small text files that are stored by the browser (for example, Google Chrome or Safari) on your computer or mobile device. They allow websites to store things like user preferences. You can think of Cookies as providing a ‘memory’ for the website so that it can recognize you when you come back and respond appropriately.
Performance Cookies: This type of cookie remembers your preferences for tools found on the services, so you don’t have to re-set them each time you visit.
Registration Cookies: When you register and sign in to our Services, we generate Cookies that let us know whether you are signed in or not. Our servers use these Cookies to work out which account you are signed in with and if you are allowed to access to a particular service.
Updates and amendments
While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services and to read the privacy notices of each and every website and service you visit. This Notice applies only to our Services.
Our Services are not designated to attract children under the age of 17. We do not knowingly collect PII from children and do not wish to do so. If we learn that a child is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any PII stored with us with regard to such child. If you believe that we might have any such data, please contact us at email@example.com.
Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Privacy, please contact us at:
PO Box 966
Worthington, OH 43085