Introduction
Hubility (33.762.689 DAVID DE LA CRUZ NUNEZ, CNPJ 33.762.689/0001-40) builds and operates artificial intelligence agents that carry out business operations on behalf of client companies, interacting with those companies' customers through messaging channels such as WhatsApp.
This Privacy Policy transparently describes what data we collect, how we use it, who we share it with, and how you can exercise your rights, including the deletion of your data. Our principle is to collect only what is strictly necessary to provide the service.
Scope and Roles
This Policy applies to the hubilityai.com website, the Hubility platform (the administration console used by our business clients), and the processing of messages exchanged between end users and the artificial intelligence agents we operate.
With regard to our business clients' account data, Hubility acts as data controller. With regard to conversations between end users and the agents, Hubility acts as a data processor, handling the data on behalf of and under the instructions of the business the end user communicates with.
Information We Collect
Business client account data: name, email, phone number and platform access credentials.
WhatsApp Business integration data: WhatsApp Business Account (WABA) identifiers, connected phone numbers and display name. This data is obtained through Meta's official Embedded Signup flow, with the business client's express authorization.
Conversation data: phone number, profile name, and the content and timestamps of messages exchanged between end users and the agents. When the business client enables coexistence mode with the WhatsApp Business app, the conversation history synced by Meta is also processed, as authorized by that client.
Operational data: technical records of the actions performed by the agents (events, logs and availability metrics), used for supervision, auditing and service support.
What We Do Not Collect
We do not use tracking cookies or behavioral analytics tools on our website. The website only stores the visitor's language preference locally, and the platform uses session cookies strictly necessary for authentication.
We do not sell personal data and we do not use it for advertising purposes.
How We Use Information
We use the collected data exclusively to: operate the artificial intelligence agents (interpret incoming messages and generate responses on behalf of the client company); display conversations to the client company within the platform, enabling human supervision; provide technical support; bill for the service; and comply with legal obligations.
Message content is processed by language model providers exclusively to generate the agents' responses. We do not use conversation content for advertising, nor do we hand it over to third parties for their own purposes.
Information Sharing
We share data only with the service providers required for the operation: Meta Platforms, for sending and receiving messages through the WhatsApp Business Platform (Cloud API), subject to Meta's terms; the infrastructure and hosting providers that run our systems; and artificial intelligence model providers, which receive only the content needed to generate the agents' responses.
We may also disclose data when required by law or by order of a competent authority. Under no circumstances do we sell personal data.
Data Retention
We keep data for as long as the business client's account remains active and the data is needed to provide the service, including displaying the conversation history on the platform.
After the account is closed, or upon a deletion request, data is removed or anonymized, except where retention is required by law.
Your Rights
In accordance with the Brazilian General Data Protection Law (LGPD) and other applicable legislation, you have the right to access, correct, delete, restrict or object to the processing of your personal data, as well as to request data portability.
To exercise these rights, contact us at info@hubilityai.com. We will respond to all requests within the legally required timeframes.
Data Deletion
You may request the deletion of your personal data at any time by sending an email to info@hubilityai.com with the subject "Data deletion", indicating the phone number or email address associated with the data.
End users who have interacted with an agent may also submit the request directly to the business they communicated with, which will instruct us to carry out the deletion. Requests are processed within 30 days, with the removal of personal data from our systems, except where retention is required by law.
Data Protection
We adopt technical and organizational measures to protect data against unauthorized access, loss or alteration: all communication with our systems is encrypted in transit (HTTPS/TLS), access credentials are stored using cryptographic hashing, and access to data is restricted to the personnel required to operate the service.
International Users
Hubility serves clients in different countries. We process personal data in accordance with the LGPD (Brazil) and other data protection laws applicable to the location of our clients and end users.
Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or in legislation. Any significant change will be communicated on this page, with the date at the top of the document updated. We recommend reviewing this policy periodically.
Contact Information
For questions or concerns about our privacy policy, contact us at info@hubilityai.com.