Privacy Policy

This Privacy Policy applies to:

• Visitors to Hubbly’s websites, including hubbly.io and hubblyvoice.io.
• Customers and authorized users of the Services.
• Individuals who request a demonstration, contact us, or otherwise communicate with Hubbly.
• Individuals who receive or participate in telephone calls, text messages, or other communications made through the Services on behalf of a Hubbly customer.

Hubbly is primarily a business-to-business service.

Hubbly may process personal information in different capacities depending on the circumstances.

When you interact directly with Hubbly. When you visit our websites, create an account, request a demonstration, purchase our Services, communicate with our team, or otherwise interact directly with Hubbly, Hubbly generally acts as the controller (or “business” under U.S. state law) and determines how and why your personal information is processed.

When a Hubbly customer contacts you. When a business uses the Services to call, message, follow up with, qualify, or otherwise communicate with you, that business generally determines the purpose of the communication and the personal information submitted to Hubbly. In those circumstances, Hubbly generally acts as a processor (or “service provider” under U.S. state law) on behalf of that business.

If you were contacted by a Hubbly customer and have questions regarding why you were contacted, the customer’s privacy practices, or the source of your information, you should contact that business directly. Hubbly may assist in routing privacy or opt-out requests to the appropriate customer when reasonably possible.

We collect personal information from the following categories of sources:

• Directly from you, when you use our websites, request a demo, or communicate with us.
• From your device and browser, automatically, when you interact with our websites or platform.
• From our customers, when they submit contact lists, campaign data, scripts, or other information for use with the Services.
• From individuals communicating with our customers, during calls, messages, or other communications processed through the Services.
• From service providers and integrations selected by our customers, such as CRM, calendar, or telecommunications providers.
• From publicly available sources and data-enrichment providers, where used to support the Services.

We may use personal information to:

• Provide and operate the Services.
• Create and administer accounts.
• Authenticate users.
• Process telephone calls and messages.
• Operate AI voice agents.
• Generate transcripts, summaries, and analytics.
• Route calls to customer representatives.
• Schedule requested appointments.
• Maintain consent, suppression, and compliance records.
• Process payments and billing.
• Provide technical and customer support.
• Detect fraud, abuse, security incidents, and unauthorized activity.
• Maintain and improve reliability and performance.
• Enforce our Terms of Service and Acceptable Use Policy.
• Comply with legal obligations.
• Respond to legal requests.
• Establish, exercise, or defend legal claims.
• Communicate with customers regarding the Services.
• Send marketing communications where permitted by applicable law.

The Services use artificial intelligence, automated speech recognition, text-to-speech technology, language models, and related technologies to provide their functionality.

AI systems may be used to: understand spoken language; generate conversational responses; generate synthetic speech; transcribe conversations; summarize calls; classify call outcomes; identify requested actions; route calls; assist with follow-up communications; and analyze communication activity.

AI voice disclosure. AI-generated voices may sound similar to natural human voices. Where required by applicable law or Hubbly policy, recipients will be informed that they are communicating with an AI-powered assistant. Hubbly does not authorize customers to use the Services for unlawful or deceptive impersonation.

Call recording and transcription. The Services may allow customers to record and transcribe telephone calls. Recording and transcription laws vary by jurisdiction, including federal and state one-party and two-party consent statutes. Customers using the Services are responsible for determining whether recording or transcription is permitted, providing any required notice, and obtaining any required consent. Where Hubbly provides a recording disclosure or consent feature, that feature is designed to assist customers with compliance but does not replace the customer’s obligation to determine the legal requirements applicable to its communications.

Hubbly’s compliance controls. Hubbly maintains commercially reasonable technical controls, including consent-status enforcement, do-not-call suppression, calling-time restrictions where configured, and AI-disclosure functionality. Ultimate compliance with the Telephone Consumer Protection Act, state mini-TCPA statutes, applicable recording laws, and other communications laws is the customer’s responsibility under the Terms of Service and Acceptable Use Policy.

Recordings and transcripts may be processed and stored so that Hubbly can provide the requested Services, maintain security and compliance records, provide customer access to call history, and resolve disputes or complaints.

Information processed during AI interactions may be transmitted to technology providers that help Hubbly provide speech recognition, synthetic voice, telecommunications, language-model, hosting, or related functionality. See Section 8 for our subprocessor practices.

Customers retain their rights in Customer Data submitted to or generated through the Services.

Hubbly does not use Customer call recordings, transcripts, contact lists, or Customer Data to train general-purpose artificial intelligence models made available to unrelated customers, unless expressly agreed with the Customer or otherwise disclosed.

Third-party AI or speech providers used to provide requested functionality may process information subject to their agreements with Hubbly. Hubbly contracts with material AI subprocessors to prohibit the use of Customer Data for training their general-purpose models unless the Customer has authorized it.

We may disclose personal information to service providers and subprocessors that help us operate the Services, including providers of:

• Cloud infrastructure and hosting.
• Telecommunications services.
• Telephone numbers and carrier connectivity.
• Speech recognition.
• Synthetic voice and text-to-speech technology.
• Artificial intelligence and language models.
• Databases and data storage.
• Email and messaging.
• Authentication and security.
• Analytics.
• Payment processing.
• Customer support.
• CRM and calendar integrations selected by customers.

These providers are permitted to process information as necessary to provide their services to Hubbly, subject to applicable contractual and legal requirements.

Subprocessor list. A current list of our material subprocessors is available on request to privacy@hubblyvoice.io. We will provide reasonable advance notice of new subprocessors to customers who have subscribed to updates.

We may also disclose personal information:

• To the Hubbly customer responsible for a communication.
• When directed by a customer through an authorized integration.
• In response to valid legal process.
• To investigate fraud, abuse, security incidents, or violations of our agreements.
• To protect the rights, safety, property, or security of Hubbly, our customers, or others.
• In connection with a merger, financing, acquisition, reorganization, or sale of some or all of our business or assets.

Hubbly does not sell personal information for monetary consideration.

Hubbly does not sell Customer call recordings, transcripts, contact lists, or communication data.

Hubbly does not disclose SMS opt-in consent for third-party marketing.

Certain state privacy laws — including the California Consumer Privacy Act — use the terms “sale” and “sharing” more broadly than their ordinary meanings, including certain disclosures made through advertising or analytics cookies for targeted or cross-context behavioral advertising.

Hubbly does not share personal information for cross-context behavioral advertising.

If you provide your telephone number and consent to receive text messages directly from Hubbly, we may send messages relating to demonstrations, account activity, requested information, support, appointments, product information, or marketing where you have provided the required consent.

Consent to receive marketing text messages is not a condition of purchasing the Services.

Message frequency may vary. Message and data rates may apply.

You may opt out of marketing text messages at any time by replying STOP. You may request assistance by replying HELP.

Consent to receive text messages from Hubbly is collected through the demo request form on hubblyvoice.io.

SMS consent information. We do not sell, rent, or share your SMS opt-in consent with third parties or affiliates for their own marketing or promotional purposes. SMS consent information and telephone numbers may be disclosed to telecommunications carriers, messaging providers, and other service providers only as reasonably necessary to deliver messages, operate the Services, prevent fraud, comply with law, or provide requested functionality. Your SMS consent will not be transferred to another business for that business’s independent marketing purposes.

Marketing email. You may opt out of marketing email at any time by using the unsubscribe link in any marketing message or by emailing privacy@hubblyvoice.io. Transactional and account-related emails may still be sent as necessary to operate the Services.

Recipients may request that a Hubbly customer stop calling or messaging them.

Where Hubbly receives or processes an opt-out or do-not-call request through the Services, we may retain information sufficient to maintain that suppression request and prevent additional communications through the applicable customer’s account.

Hubbly customers are responsible for maintaining their own legally required suppression and do-not-call programs, including registration and honoring of the National Do Not Call Registry where applicable.

We retain personal information for as long as reasonably necessary to provide the Services, maintain customer accounts, complete transactions, maintain security, prevent fraud and abuse, preserve legally required consent, suppression, and telemarketing records, resolve disputes, enforce agreements, and comply with legal obligations.

Different categories of information may have different retention periods:

Certain consent, do-not-call, suppression, opt-out, and call-compliance records may be retained after other Customer Data has been deleted when necessary to document compliance or prevent future unwanted communications. When retention periods expire, we delete, deidentify, or aggregate personal information in accordance with our internal policies.

We maintain administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, loss, or destruction. These safeguards may include:

• Encryption in transit and, where appropriate, at rest.
• Authentication and access controls.
• Role-based access restrictions and least-privilege principles.
• Logging, monitoring, and intrusion detection.
• Security protections provided by our infrastructure and platform providers.
• Regular review of our security practices.

No method of transmitting or storing information can guarantee absolute security.

Breach notification. In the event of a security incident affecting personal information, Hubbly will notify affected customers without undue delay and in accordance with applicable law, and will provide information reasonably necessary to enable customers to meet their own notification obligations to data subjects and regulators. Where Hubbly acts as a controller with respect to affected personal information, Hubbly will provide notice to affected individuals and regulators as required by applicable law.

Hubbly is based in the United States. Personal information may be processed or stored in the United States and other jurisdictions where Hubbly or its service providers operate.

Where personal information originating in the European Economic Area, the United Kingdom, or Switzerland is transferred to a country that has not received an adequacy decision, Hubbly relies on appropriate safeguards, including the European Commission’s Standard Contractual Clauses (2021) and the UK International Data Transfer Addendum, as applicable. Copies of these safeguards are available on request to privacy@hubblyvoice.io.

Depending on where you live, you may have rights concerning your personal information, including the right to:

• Request access to personal information.
• Request correction of inaccurate information.
• Request deletion.
• Request a portable copy of certain information.
• Request information about how personal information is processed.
• Restrict or object to certain processing.
• Withdraw consent where processing is based on consent.
• Opt out of certain targeted advertising or profiling.
• Opt out of the sale or sharing of personal information.
• Limit the use of sensitive personal information, where applicable.
• Appeal certain decisions regarding a privacy request where provided by law.

These rights are subject to applicable exceptions.

How to submit a request. Email privacy@hubblyvoice.io with a description of your request and the information necessary to identify your account or communication.

Verification. To protect your information, we may need to verify your identity before completing certain requests, typically by asking you to confirm information already associated with your account or with the communication at issue. We do not require you to create an account solely to submit a request.

Response time. We will acknowledge receipt of most requests within 10 business days and respond within 45 days for CCPA/CPRA requests and within 30 days for GDPR/UK GDPR requests. We may extend response times as permitted by law and will notify you if we do so.

Appeals. If we deny your request in whole or in part, you may appeal by replying to our decision within 45 days. We will review your appeal and respond within 45 days. If we deny your appeal, you may contact the Attorney General of your state or the applicable supervisory authority.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We will require written authorization and, in some cases, verification of the agent’s identity.

Non-discrimination. We will not discriminate against you for exercising your privacy rights.

Requests routed to customers. If Hubbly processes information solely on behalf of one of our customers, we may direct your request to that customer and assist with routing.

Where applicable law requires us to recognize browser-based opt-out preference signals such as Global Privacy Control (“GPC”), we treat those signals as a valid opt-out of the sale or sharing of personal information for the browser or device from which the signal is sent.

A GPC signal applies to the browser or device from which the signal is sent and may not identify you across different browsers, devices, or accounts unless you are logged into a Hubbly account or applicable law requires otherwise.

Hubbly may use cookies and similar technologies necessary to:

• Operate the websites.
• Authenticate users.
• Maintain sessions.
• Prevent fraud.
• Remember preferences.
• Understand website and Service usage.

Where we use non-essential analytics, advertising, or targeting technologies that require consent or an opt-out under applicable law, we provide appropriate controls through our cookie banner and “Your Privacy Choices” interface.

Customers may connect the Services with third-party applications, such as CRM, scheduling, communications, or other business systems.

When a customer directs Hubbly to transmit information to a third-party integration, that third party’s privacy practices may also apply. Customers are responsible for choosing and configuring their integrations, and for the actions of those third parties once information is transmitted.

Hubbly is a business product and is not intended for individuals under 18 years of age. We do not knowingly collect personal information directly from children through our websites or permit children to create Hubbly customer accounts.

We do not knowingly sell or share the personal information of consumers under 16 years of age, and we do not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act.

If you believe a child has provided personal information directly to Hubbly, contact us at privacy@hubblyvoice.io and we will take reasonable steps to delete that information.

We may update this Privacy Policy to reflect changes in our Services, technology, business practices, or applicable law. When we make changes, we will update the “Last Updated” date at the top of this policy. Where required by law, we will provide additional notice of material changes, such as through in-product notice or email.

For privacy questions, privacy-rights requests, or concerns regarding this Privacy Policy, contact:

The Hubbly Corporation, 2021 Guadalupe St, Austin, TX 78705. Email: privacy@hubblyvoice.io