HUB Fleet Solutions Marketplace Privacy Policy

NOTICE:  You must be 18 years of age or older to use the Hub Fleet Solutions Marketplace (“Marketplace”). Use of the Marketplace by minors under the age of 18 is strictly prohibited. We do not knowingly or intentionally collect Personal Data from any person under the age of 18.  

The Marketplace is a one-stop solution for discovering, purchasing and accessing third-party solutions and applications for fleets. The purpose of this privacy policy is to explain to our customers and their employees (collectively, “you”) what data we collect from you when you register to use, browse and select offers from the Marketplace, how that information is used, and what measures we take to protect that data.

In order to provide you with 3rd- party solutions and applications and other services through this Marketplace, we work with – and share your information with – different 3rd-party partners, including Roadz, which is our “Marketplace Platform Provider”, and “Vendors,” which refers to the third-party solution providers whose solutions and applications are available for you to purchase and use through the Marketplace (collectively “we” or “us”).

However, this privacy policy does not apply to your purchasing solutions and applications from Vendors within the Marketplace. Vendors have their own privacy policies that apply to those transactions.  You should read and understand a Vendor’s privacy policy before purchasing a solution or application, so that you understand what personal information the Vendor collects, how the Vendor uses your personal information, and how the Vendor protects your personal information. Hub and Roadz are not responsible for the privacy practices of the Vendors.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us, including our Marketplace Platform Provider, such as name, address, contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about the Marketplace or while using the Marketplace for other purposes (such as administering your user profiles) or otherwise contacting us.

The personal information we collect may include the following:

• Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

• Payment Data. Our third-party payment processor, Stripe, collects data necessary to process your payment if you make purchases through the Marketplace, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find Stripe’s privacy policy here.  

We do not receive your credit card information in the context of such transactions. We and the Third Party Vendor receive confirmation that the transaction has concluded, so that we and Third Party Vendor may provide the Solution you have purchased and support with regard to the Solution.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information That is Automatically Collected By Us

IP address and/or browser and device characteristics.  We automatically collect certain information when you visit, use or navigate the Marketplace. This information does not reveal your specific identity (like your name or contact information) but may include other information which can be used to identify you when combined with other Personal Information.  The information collected includes information about the device or devices you use to access the Marketplace and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Marketplace and other technical information. This information is primarily needed to maintain the security and operation of the Marketplace, and for our internal analytics and reporting purposes.

Cookies and Similar Technologies.  Like many businesses, we also collect information through cookies and similar technologies, which are discussed below.

Telematics and Other Fleet Data. The Marketplace provides you with the ability to find, purchase, and access third-party Vendor solutions that may rely on telematics, including GPS vehicle location data, engine and vehicle or device diagnostic data, driver behavior data like speed and acceleration, VINs, fuel levels, odometer data, seatbelt and other safety related data, route, and administrative fleet data. We, which includes the Vendors whose solutions you buy and access through the Marketplace, may be collecting or generating such data in the course of providing services to you, and this information is shared between us, including the Vendors whose solutions you have purchased through the Marketplace and the Marketplace Platform Provider, in order to provide you services.

Any use of your information by the Vendors we partner with for purposes of selling their solutions on the Marketplace, and with whom you have entered into an agreement through the Marketplace, or directly by signing a contract with them, is subject to your agreement with those Vendors and those Vendors separate privacy policy.

2. HOW WE USE YOUR INFORMATION

We process your information for business purposes related to the fulfillment of your contracts with Hub, the Hub Fleet Solutions Marketplace, the Marketplace Platform Provider, or the Vendors, or compliance with our legal obligations.

Hub, the Marketplace Platform Provider and Third Party Vendors on the Marketplace may use Personal Information collected via the Marketplace for a variety of business purposes such as those described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, with your consent, or in order to support the Solutions you purchase through the Marketplace and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on for each of the purposes listed below.

We use the Personal Information we collect or receive for the following purposes:

Purpose

Personal Information Used

Explanation of Purpose

To Facilitate Account Creation and Logon Process

Name, Username, Email Address, Password

We may use your Personal Information to facilitate account creation and logon processes through a single-sign-on (“SSO”) authentication process. This allows you to access the Marketplace, as well as multiple Vendor applications, solutions and services, through one set of login credentials.

To Send You Marketing Communications

Name, Username, Email Address, Location, Demographics, Traffic Source, Site Engagement Metrics, Language*

We may use your Personal Information to advise you of new products or promotions. You can opt-out of our marketing emails at any time by using the “Unsubscribe” link located at the bottom of the emails or by sending an email to fleetmarketplace@hubinternational.com (see the "WHAT ARE YOUR PRIVACY RIGHTS "below).

To Send You Administrative Information

Name, Username, Email Address

We may use your Personal Information to send you notices about your account or changes to the terms of use. We may also use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To Fulfill and Manage Your Orders

Name, Username, Email, Order History.

 We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Marketplace. Note that payment and refund information consisting of payment and refund processing will be processed by Stripe to ensure security of your payment account and refund account.

To Post Your Testimonials

Name, Username, Email, Order History, Offered or Purchased, Traffic Source, Site Engagement Metrics*

We may post testimonials on our Marketplace that may contain Your Personal Information, such as your legal name or Username or email address, pursuant to your designation, and your experience with the Marketplace or with Solutions purchased.  You may wish to remain anonymous with regard to your testimonials, and we respect that choice. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at fleetmarketplace@hubinternational.com and be sure to include your name, testimonial location, and contact information.

To Request Feedback

Name, Username, Email, Purchase History, Feedback, Site Engagement Metrics*

We may use your Personal Information to request feedback and to contact you about your use of our Marketplace and the Solutions offered thereon.

To Enforce the Terms and Conditions

Name, Username, Address, Email, Company Address, Shipping Address, Site Engagement Metrics*

We may use your Personal Information to enforce our terms, conditions and policies.

Legal Requirements for Disclosure of Information

Name, Username, Address, Email, Activities and the Purchase of Solutions in Connection with Your Use of the Marketplace, Location, Demographics, Site Engagement Metrics*

We may disclose your Personal Information when we are legally required to do so in order to comply with applicable law, governmental requests or demands, a judicial proceeding, court order or legal process, such as a subpoena or court order (including in response to public authorities to meet national security or law enforcement requirements). If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

Vital Interests

Name, address, Username, Password, Equipment Used to Access the Marketplace,  the Purchase of Solutions in Connection with Your Use of the Marketplace, Your Payment History, Your Reviews and Testimonials, Device Information, Location, Demographics, Traffic Source, Site Engagement Metrics, Language*

Management of User Account

Name, Username, Address, Email, Account History, Equipment Used to Access the Marketplace*

We use your Personal Information to manage Your user accounts and keep it in working order.

To Deliver The Requested Services and Solutions

Name, Username, Address, Email, Equipment Used to Access the Marketplace, General Payment History (Not Including Payment Account Information), Language, Location*

To deliver services to you. We may use your information to provide you with the requested Services and Solutions.

To Respond to User Inquiries and Offer Support.

Name, Username, Email, Phone Number, Account History, General Payment History (Not Including Payment Account Information), Device Information, Location Data, Demographics, Site Engagement Metrics, Language*

We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Marketplace

To Provide Information Regarding Purchases to Third Party Vendors

Name, Username, Email, Confirmation of Payment, Solution Chosen, Equipment Used to Access the Marketplace, Information regarding the Fleet or Individual Rig(s) for which The Solution has been purchased*

To share data, including Personal Information, with Third-Party Vendors whose Solutions you purchased on the Marketplace in order to enable those Solutions, according to the data required by those Solutions and generally to fulfill your order and provide the Solution to you.

To Provide Personal Information to Roadz, the Marketplace Platform Provider

Name, Username, Email, Password, Password Reminders, Device Information, Purchase History (not including payment account information), Testimonials and Solution Reviews, Location, Demographics, Traffic Source, Site Engagement Metrics, Language, First-time or Returning User*

We share some of your Personal Information with Roadz, and Roadz collects some Personal Information directly when you use the Marketplace.

For Other Legitimate Business Purposes

Usage History, Purchasing History, Timing of Purchasing and Usage, Demographics, Traffic Source, Location, Site Engagement Metrics, Language,*

We may use your Personal Information for other legitimate business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our Marketplace, and selecting additional Third-Party Vendor products and services to be offered on the Marketplace.

*Device Information: including the operating system, device model, and screen resolution.

*Location Data: GA4 collects geographical information such as country, region, and city, based on the user's IP address.

*Demographics: including age, gender, and interests, depending on users' Google account information and privacy settings.

*Traffic Source: Information about how the user arrived at the site or app, such as organic search, paid search, social, direct, and referral traffic.

*Site Engagement Metrics: session duration, pages/screens per session, and events (interactions on the site or app).

*Language: language setting of the user's browser or device.

*First-time or Returning User: identifies whether the user is visiting for the first time or is a returning visitor.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE ELSE?

 Hub and the Marketplace Platform Provider share Personal Information with others to comply with laws, to provide You with Services and Solutions, to protect Your rights, to fulfill business obligations, as we may describe to you at the time we collect Your Personal Information, or as described in this Privacy Policy.

We, including Roadz, the Marketplace Platform Provider, may also share data and information for business purposes in an anonymized form which is not associated with individual end users or customers, and does not include personal information. Vendors may also share data according to the agreement you signed with them through the marketplace or directly.

We may also share your Personal Information in the following situations:

At Your Request. We may share Personal Information about you with third parties when you request that we do so for a specific purpose.  In such circumstances, we only share that Personal Information that you authorize us to share.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data among us: the Marketplace, the Marketplace Platform Provider and Vendors, as well as with other third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. For instance, we may share your information with our partners for purposes of payment processing, data analysis, email delivery, hosting services, and customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Marketplace, which will enable them to collect data about how you interact with the Marketplace over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.

Unless described in this privacy policy, we do not, sell, rent or trade any of your personal information that may be used to identify you with third parties for their promotional purposes. We may sell, rent or trade data collected from you that has been anonymized by either us or the Marketplace Platform Provider and cannot be used to specifically identify you.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

NO OTHER SALE OR SHARING OF YOUR PERSONAL INFORMATION: Except as otherwise described in this privacy policy, we do not, sell, share, rent or trade any of your personal information that may be used to identify you with third parties for their promotional or marketing purposes. We may sell, rent or trade data collected from you and other customers that has been anonymized by either Hub or the Marketplace Platform Provider so that it no longer contains Personal Information and cannot be used with other information to identify you as an individual.

4. OUR  USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Hub and the Marketplace Platform Provider, may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

5. VENDORS

In Short: We, including the Marketplace Platform Provider, may share information with Vendors (third party solution providers on the Marketplace), and those Vendors may, likewise, share information with us, that is essential to the operation of our business. As our Marketplace Platform Provider, any information submitted through the Marketplace is also accessible by Roadz, and may be used by that provider in order to provide you, HUB Fleet Solutions Marketplace and Vendors with services.

To the extent we share your information with a Vendor through our Marketplace, and in accordance with your agreement with that particular Vendor that you have engaged through our Marketplace, and you accepted the Vendor’s agreement through the Marketplace, or approved sharing of data with the Vendor either specifically, or by way of agreement with us, or signed a contract with that Vendor directly, then that Vendor’s privacy policy controls the Vendor’s use of that information.

The personal information we may share with Vendors and other third parties, is shared for purposes of engaging Vendors to provide applications and solutions to you.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless a different period is required by law.

We will only store your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). This includes storing data in order to be able to provide Vendors the data collected and/or generated by HUB Fleet Solutions Marketplace, Roadz, and other Vendors, in order to enable the services of those Vendors to you.

When we have no ongoing business need to keep your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We maintain industry standard technical and organizational measures to protect your Personal Data from loss, misuse, alteration, or unintended destruction.  We have adopted various security measures to protect Personal Information and general information we receive from or generate for Users and Registrants.

Nonetheless despite our efforts to protect your Personal Data, you should be aware that there is always some risk that bad actors could find a way to circumvent our technical and organization measures designed to prevent that occurrence. Be mindful that the transmission of personal information to and from the Marketplace is at your own risk.  You should only access the services within a secure environment. We do not represent or warrant that unauthorized access will never occur or that the privacy and security of any information transmitted to us and that we generate about you will never be breached.  

8. DO WE COLLECT INFORMATION FROM MINORS?

 We do not knowingly collect personal data from or market to children under 18 years of age.

By using the Marketplace, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Marketplace. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at fleetmarketplace@hubinternational.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review your Marketplace account at any time, as well as terminate your Marketplace account at any time provided that you have no active subscriptions with Vendors or with Marketplace services for which you have signed up and committed to a contract period which hasn’t ended yet.

Account Information

If you would like to review the information in your Marketplace account, or terminate your account provided that you have no active subscriptions with Vendors or with Marketplace services for which you have signed up and committed to a contract period which hasn’t ended yet, please contact us using the contact information provided in this Privacy Policy.

Upon your request to terminate your Marketplace account, and assuming no outstanding contracted obligations to Vendors or Marketplace services, we will deactivate or delete your Marketplace account. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online, except as may be required by applicable law. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

12..

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

YOUR PRIVACY RIGHTS UNDER APPLICABLE LAW

 Depending on the laws and regulations regarding privacy rights in your state of residence, you may have rights to:

The foregoing list may not be exhaustive, as U.S. states continue to pass data privacy laws that may add additional rights to this list.  

In order to protect you and your Personal Data, we may require evidence to confirm your identity prior to responding to the exercise of the rights above. We will respond to your request to exercise your rights within the time frame allowed by applicable law.  

 

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the rights you may have with respect to data privacy are set forth in this section.

Please see the sections above with respect to the Personal Data we collect about you and how we use the data.

Under California law, you have a right to notice upon collection of the categories of personal information collected by us and the purposes for which that Personal Data will be used.  We have provided notice through this Privacy Policy.  You may also have the following rights:

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information.

COLORADO PRIVACY RIGHTS

If you are a Colorado resident, additional rights available to you can be found here.  This section supplements the rights set forth in the balance of the Privacy Policy with those additional rights provided by Colorado law.

The Personal Data we collect about you is set forth above, as is information on how we use that information.

We do not use your Personal Data to make decisions with legal or similar effects for you based on automated processing of the data.

We have explained above how we may share your Personal Data with third parties in the event of a legal requirement to do so, in the event of sale, reorganization or other change in our company, and in the event we hire certain third-party contractors.

Subject to limitations, Colorado residents have the following rights:

We do not sell or share your personal information, except as specifically noted above.  Such sharing would not be for targeted advertising or sale of Personal Data. While you technically have a right to opt out of the sale or sharing of your Personal Data for targeted advertising, this right does not specifically apply in the instance where no such sale or sharing occurs.

CONNECTICUT PRIVACY RIGHTS

The following section describes rights you may have under Connecticut law.  Again, these rights must be read in context of the information provided elsewhere in this Privacy Policy regarding the types of Personal Data collected, processed and stored and how we use Personal Data.

We do not use your Personal Data to make decisions with legal or similar effects for you based on automated processing of the data.

Subject to certain limitations, your rights under Connecticut law are the following:

We do not sell or share your personal information, except as specifically noted above.  Such sharing would not be for targeted advertising or sale.  Nonetheless, you technically have a right to opt out of the sale or sharing of your Personal Data for targeted advertising or sale, even though we do not engage in such practices.

UTAH PRIVACY RIGHTS

Utah also provides privacy rights to its residents which become effective on December 31, 2023.  This information is in addition to information provided elsewhere in this Privacy Policy regarding Personal Data we collect, process and store and how we use your Personal Data.

Subject to certain limitations, your rights under Utah law include the following:

You have a right to opt out of targeted advertising and the sale of your Personal Data. As noted elsewhere in this Privacy Policy, we do not engage in such activities.

VIRGINIA PRIVACY RIGHTS

This section describes the rights Virginia residents may have with respect to our collection, processing and storage of Personal Data and must be read in the context of the rest of this Privacy Policy.

Virginia residents have the following rights:

As with the other State laws, you have the right to opt out of targeted advertising and sale of your Personal Data, though we do not engage in either of those practices.

CONTACT US ABOUT YOUR PRIVACY RIGHTS

The Marketplace has appointed a Data Protection Officer or DPO, who is responsible for overseeing our privacy practices and answering your questions in relation to this Privacy Policy. The DPO will address any complaints you may have regarding the protection or processing of your Personal Data by Us.  If you have any questions or would like to exercise your rights or appeal a denial of a request to exercise your rights, please contact the DPO using the following email address fleetmarketplace@hubinternational.com.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

If you use the Marketplace, you agree to be bound by such changes to this privacy policy. If you do not agree to such changes, please contact us. We will attempt to resolve your concern by either providing an explanation or making an accommodation. If we cannot accommodate you, then your only remedy is to discontinue use of the Marketplace.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at fleetmarketplace@hubinternational.com  or write to us at

Address: 2625 Middlefield Road #597 Palo Alto California 94306