NOTE: This policy will go into effect on June 7, 2019. See here for the privacy policy effective until that date.
Hustle, Inc. (“Hustle,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy applies to our business customers (“Customers”) and Message Recipients (defined below) and explains how your personal information is collected, used, and disclosed by Hustle. This Privacy Policy applies to our website, Hustle.com, Hustle.life and our web and mobile apps (collectively, our “Service”). Hustle is a business to business service provider whereby Hustle provides notification and messaging services that allows our Customers to contact and send messages and information to their message recipients (“Message Recipients”) through mobile text messaging services. Customers generally use the Services via their agents and administrators, who are individuals designated by the Customer; a Customer’s agents send and receive the messages on behalf of the Customer, and a Customer’s administrators administer the Service on behalf of the Customer. Our Privacy Policy primarily explains our data collection practices when collecting, storing and or using data on behalf of our Customers as a service provider. If you are an individual Message Recipient who received a message from a Customer through Hustle and you wish to learn about how Hustle collects and uses your data, please see Section 1.2 below. If you wish to opt-out from receiving additional messages, please see Section 5 below.
By accessing or using our Service, you signify teat you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy, our Terms & Conditions of Use at https://www.hustle.com/tac/, and your Order Form and associated agreement (as applicable). “You” or “your” means an authorized user on the Service associated with a Hustle Customer account and may include (without limitation), an employee, agent, volunteer, or administrator of Customer.
1.1 The categories of information we collect can include:
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications, or invite others to join the Service. We may also send you Service-related emails or messages (e.g., account verification, updates to features of the Service, technical and security notices). We may also use this information for our internal business purposes, such as data analysis, audits, fraud prevention, developing new products, services, and/or features, improving our Service, identifying usage trends, and determining the effectiveness of our Service. For more information about your communication preferences, see “Control Over Your Information” below.
1.2 CCPA Disclosures. The California Consumer Privacy Act of 2018 (“CCPA”), expected to take effect on January 1, 2020, is anticipated to require certain companies to make disclosures about which Personal Information, as defined in the current version of the CCPA (“Personal Information”) is collected, and shared or sold with third parties. In the spirit of a forward-thinking approach towards compliance with CCPA’s privacy policy disclosure requirements, this section sets forward the categories of Personal Information collected, shared, and sold by Hustle.
We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to uniquely identify your browser, mobile device, or your account), and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We may share your personal information with:
We may also share information, including User Content and Text Message Data, with third parties and other Hustle Customers in an aggregated or otherwise anonymized form, such as aggregated user statistics, that does not reasonably identify you or your Message Recipients directly as individuals. Please see the “Control Over Your Information” section for more information.
How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. In addition, if a Customer receives a promotional text from Hustle, that Customer may opt-out of future promotional texts by texting “STOP” in response. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices). Customer’s agents and administrators who no longer wish to perform the agent or administrator functions can contact the particular Hustle Customer and request removal from groups.
Deleting Customer information. Unless otherwise agreed in writing, upon Customer’s request, Hustle will delete all Hustle Customer production data, including personally identifiable information uploaded to the Service by that Hustle Customer. We may not be able to delete your information in all circumstances. For example, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. Hustle may also retain a secure, encrypted copy of Customer Data for up to one year after termination pursuant to Hustle’s standard archiving and back-up procedures and policies.
We offer services enabling our Customers to send text messages through our Service. This Section discusses how individuals who receive a message from a Hustle Customer may opt-out of receiving messages from any particular Hustle Customer Campaign. To unsubscribe from any Hustle Customer texting campaign, Message Recipient recipients may text “STOP,” “UNSUBSCRIBE” or similar words or phrases as a response to the sender or contact us via email at support@hustle.life. Hustle will send the Message Recipient one follow-up text message to confirm that the Message Recipient has been unsubscribed. In the event the Message Recipient uses the Service with multiple Hustle Customers, we may send the Message Recipient a follow-up message to clarify which Customer from whom the Message Recipient would like to stop receiving messages. Message Recipients may also email us at support@hustle.life in the event they believe that a Hustle Customer has added their information in error or without their permission. Please note that opt-outs are tracked separately for each Hustle Customer, so unsubscribing from one Hustle Customer will not unsubscribe you from communications from another Hustle Customer.
To restart receiving text messages from a Hustle Customer, Message Recipients may text START to the Customer’s short code or long code. In the event Message Recipients use the Service with multiple Hustle Customers, we may send an automated message to clarify which customer the Message Recipient wants to restart receiving messages and calls from. Standard message and data rates apply.
If you visit our website, you should note that we participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Sites over time so that they may play or display ads on our Sites, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again.
You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).
Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Sites. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
Data storage and transfer: Your information collected through our Service may be stored and processed in the United States or any other country in which Hustle or its parent, subsidiaries, affiliates, or service providers maintain facilities. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
Data retention: We will retain your personal information only for as long as reasonably necessary to maintain the Service, to meet legal and accounting obligations, and for the purposes described in this Privacy Policy. We may anonymize and/or aggregate personal information, including User Content and Text Message Data, and store it in order to analyze aggregate metrics and trends.
Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Civil Legal Processes: Hustle’s policy is to notify Customers upon receipt of a civil subpoena demand of their account information or any associated data stored with Hustle. A two week wait period must transpire before disclosure of any information. Hustle will advise the Customer that the information will be disclosed unless Hustle is in receipt of a document seeking a court-approved protective order prior to the date on which Hustle must legally comply with the demand. Hustle will notify Customers upon receipt of legal process.
Fees for Civil Subpoena Processing: Hustle charges a fee for the processing of civil subpoenas, as authorized under 18 U.S.C. § 2706. This fee is set at $200/hour, with a two hour minimum per response. In addition, a per-subpoena fee of $50 per Customer whose data is requested shall be charged. No charge shall be required relating to matters involving the distribution of child pornography or any act of child endangerment. Furthermore, no charge shall be required to investigate matters dealing with abuse of Hustle’s services to harass, abuse or intimidate any person; provided this situation is documented when a response is requested. Hustle reserves the right to require payment in advance, to withhold delivery of information until payment is received and to seek enforcement of charges. Non-binding estimates can be provided to the requesting parties. For an estimate, please email security@hustle.life with the requisite documentation and entitle the subject “Estimate Request.” However, entities that fail to pay charges must serve process by the registered agent within the appropriate state and requests for expedited response will not be granted.
Criminal Legal Processes: Hustle will notify Customers upon receipt of criminal legal process seeking information about their accounts and/or data unless prohibited by law. Should Hustle receive any indefinite sealed legal process prohibiting notification of a Hustle Customer, including a national security letter gag, Hustle will invoke statutory procedures to have a judge review.
Hustle does not and will not provide User Content or data without a valid U.S. search warrant. Please note: If an emergency situation that presents a clear and present danger to life, or legal process prohibits notification; Hustle will notify Customer after emergency has ended, or once suppression order expires.
Hustle does not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@hustle.com.
The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
If you have any questions about this Privacy Policy or the Service, please contact us at privacy@hustle.com.
We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the ‘last modified’ date at the bottom of this page. If you object to any changes, you may close your account. Continuing to use our Service after we publish changes to this Privacy Policy means that you are consenting to the changes.
This privacy policy was last modified on June 7, 2019.