PRIVACY POLICY

Last updated: November 19, 2018 (view previous versions)

1.  PURPOSE AND SCOPE.

HBUS Holdco, Inc. ("HBUS," "we," "us," and "our") respects your privacy. This Privacy Policy applies to personal information that is processed by HBUS during our business, including on HBUS websites (each a "Site"), mobile applications and/or when you use the HBUS API (including third-party applications relying on such an API) (collectively, the "Services").

2.  ACCEPTANCE OF THE PRIVACY POLICY.

This Privacy Policy is incorporated by reference into the HBUS Terms of Service. By using the Services, you agree to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue using the Services.

3.  TYPES OF PERSONAL INFORMATION WE COLLECT.

When we say "personal information" we mean information that relates to you and can – either on its own or in combination with other information – identify you as an individual. Personal information does not include data that has been aggregated or made anonymous such that you can no longer be identified using any means reasonably available to us.

Here are some ways in which HBUS collects personal information: Account Creation. When you create an account or use the Services, we may collect the following types of information, including but not limited to: your name, date of birth, social security number, address, phone, email, and bank account details and/or credit card numbers. Identity Verification. We may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity, source of funds, and address, and/or to manage risk as required under applicable law. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. Communications with Us. Whenever you contact us or respond to our communications (e.g., email, telephone, written), we receive your contact information and any other personal information you choose to provide us. Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, details about your browser or device, geo-location information, Internet service provider, pages that you visit before and after using the Services, and other information about how you use the Services. Information from Other Sources. We may obtain information about you from third-party sources as required or permitted by applicable law, such as public databases, credit bureaus and ID verification partners.

We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.

4.  HOW HBUS USES YOUR INFORMATION

We process personal information for a variety of business purposes, including: To Provide the Services or Information Requested including but not limited to: generally manage individual information and accounts; provide a personalized experience and implement the preferences you request; process transactions and send you notices about your transactions; provide customer support. Administrative Purposes including but not limited to: resolve disputes, collect fees and troubleshoot problems; ensure quality control and staff training; verify your identity by comparing your personal information against third-party databases; send administrative or account-related information to you; enhance security, monitor and verify service access, combat spam or other malware or security risks; measure interest in the Services; improve the Services; develop new products and Services; enforce our agreements with third-parties; prevent potentially prohibited or illegal activities; enforce our Terms. Marketing HBUS Products and Services including but not limited to: better understand our users and the way they use the Services; tailor content, advertisements, and offers; deliver targeted marketing and promotional offers based on your communication preferences. Other Uses. HBUS may use personal information for any other purpose disclosed to you at the time you provide such information or otherwise with your consent.

5.  COOKIES, PIXEL TAGS/WEB BEACONS, INTEREST-BASED ADVERTISING, ANALYTICS,AND SOFTWARE DEVELOPMENT KITS.

We, as well as third-parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information through the Services. Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users' engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. HBUS may use the Facebook pixel for advertising and optimization. To opt out of Facebook showing you targeted ads from other sites, or from seeing Facebook's ads on other sites, open your Facebook page and using their "Settings" functionality adjust your ad preferences We use Technologies for the following general purposes: Operationally Necessary To operate the Services. This includes Technologies that allow you access to our Services and that are required to identify irregular behavior, prevent fraudulent activity, improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions. Performance Related. To help us understand how our visitors use and interact with the Services so that we can improve them. Functionality. To offer you enhanced functionality when using the Services. This may include identifying you when you sign into the Services or keeping track of your specified preferences, interests, or past items viewed; Advertising. To help us and third-parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites. If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of interest-based advertisements on some mobile applications by following the instructions for Android and iOS. Analytics. We may also use Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any personal information. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/. You can opt out of Google's processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout. Mobile. As noted above, you may stop or restrict the placement of cookies on your computer or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of interest-based advertisements on some mobile applications by following the instructions for Android and iOS. Online Advertising. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.

6.  THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS.

The Services may contain links to websites and services that are owned or operated by third-parties (each, a "Third-party Service"). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner's or operator's privacy policy. We're not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

HBUS's Services may include access to publicly accessible blogs, forums, or social media platforms. Personal information you voluntarily transmit or publish online in a publicly accessible blog, forum, or social media platform may be viewed and used by others without any restrictions. By using such services, you assume the risk that your personal information may be viewed and used by third-parties for any number of purposes.

7.  HBUS MAY DISCLOSE YOUR INFORMATION.

7.1 INFORMATION WE SHARE. We may share your information as described in this Privacy Policy (e.g., with our service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.
Service Providers. We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Identity Verification. We share your information with third-party identity verification services to prevent fraud and deny service to persons in compliance with our legal or regulatory requirements. This allows HBUS to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services. Payment Processing. We share your information with financial institutions with which we partner to process payments you have authorized. Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your personal information and other information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours', ours' or others' rights, property, or safety; (iv) to enforce HBUS policies or contracts; (v) to collect amounts owed to HBUS; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. 7.2 INTERNATIONAL DATA TRANSFERS. You agree that all information collected via or by HBUS may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, to provide the Services.

8.  OPT-OUT.

8.1 GENERAL In some instances, you may have the right to opt out of certain uses and disclosures of your personal information. However, if you opt-out, we may not be able to process your personal information for certain purposes. 8.2 MOBILE DEVICES. HBUS may occasionally send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. HBUS may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device. 8.3 "DO NOT TRACK". Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that at this time no formal "Do Not Track" standard has been adopted we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

9.  ACCESS AND CORRECTION.

HBUS provides users with the ability to review and correct their personal information where it is inaccurate. You may do this at any time by logging in to your account or by contacting [email protected]. If you close your HBUS account, we will mark your account in our database as "Closed," but will keep your account information in our database for a minimum of five years. This is necessary to comply with recordkeeping requirements under applicable laws and to deter fraud. However, if you close your account, your personal information will not be used by us for any further purposes, except as necessary to comply with our legal obligations.

10.  DATA RETENTION.

HBUS retains the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. HBUS will retain your personal information for a minimum of five years to comply with our legal obligations or to resolve disputes.

11.  SECURITY OF YOUR INFORMATION.

HBUS maintains appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur.

Unfortunately, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us as set forth below.

Please recognize that you play a vital role in protecting your own personal information. When registering with the Services, it is important to choose a password of sufficient length and complexity, to turn on advance security features such as two-factor authentication, to not reveal account credentials to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

12.  CHILDREN'S INFORMATION.

Our Services are not directed to people under 18 ("Minors") and we do not knowingly collect information from Minors. If we believe or learn that we have collected information of a Minor, we will take steps to disable that account and delete such information as soon as possible.

13.  CALIFORNIA PRIVACY RIGHTS.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. HBUS does not share personal information with third-parties for their own marketing purposes.

14.  UPDATES TO OUR PRIVACY POLICY.

Any information that is collected via the Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect. If at any point you do not agree to any portion of the Privacy Policy in effect, you must immediately stop using the Services and delete your account.

15.  QUESTIONS OR COMMENTS.

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:
HBUS Holdco, Inc.
550 Montgomery Street, 2nd Floor
San Francisco, CA 94111
Email: [email protected]
We will address your concerns and attempt to resolve any privacy issues in a timely manner.

PRIVACY POLICY ARCHIVE

• May 15, 2018