Huxly Inc.

Privacy Policy


Effective Date: 13.September.2022

Date Last Updated:  13.September.2022


Huxly Inc. and its affiliated entities (“Huxly,” “we,” “our,” and “us”) are committed to protecting individual privacy and maintaining trust with our business clients (“Clients”), and our Clients’ audiences and end users (collectively, “End Users”). To achieve these goals, this Privacy Policy (“Policy”) describes data collections matters across our products, platforms, and services (the “Huxly Platform”). We provide the Huxly Platform to our Clients for use via social media platforms. Our Clients use the Huxly Platform to deliver interactive content over the messaging functions of various social media websites and applications.


Please note that Huxly typically has no direct relationship with End Users. We simply process and store End Users’ information, including Personal Information, on our Clients’ behalf and at our Client’s direction as their service provider. Any use of Personal Information is carried out pursuant to an agreement in place between Huxly and the applicable Client.


If you, as an End User, have any questions or concerns about the data handling practices of our Clients using the Huxly Platform, please contact the Client (or Clients) with whom you have interacted.


Table of Contents


1.    Information We Collect

2.    How We Use Information

3.    How We Disclose Information

4.    Our Use of Cookies

5.    Do Not Track

6.    Information Regarding Children

7.    Your Privacy Rights

8.    Legal Disclaimers

9.    Links

10.  Updates to This Policy

11.  Contact Us


1.   Information We Collect


On behalf of our Clients, we collect information that identifies, describes, or is reasonably capable of being associated with End Users (“Personal Information”). Personal Information does not include publicly available information from government records, deidentified information, or aggregated information. We collect and use different types of Personal Information for various reasons depending on how End Users interact with the Huxly Platform and our Clients. The following describes the types of Personal Information we collect on behalf of our Clients.


Personal Information We Collect Directly From End Users

We may collect Personal Information directly from End Users who interact with the Huxly Platform. The Personal Information we collect on behalf of our Clients may include:


      Contact Information. We collect information such as End Users’ first and last name.

      Social Media Information. We collect social media information related to an End Users’ social media username, profile information, profile picture, gender, or other information available on the social media profile.

      Message Contents. If an End User sends messages to our Clients through social media via the messaging function, we also collect message contents, including responses to open ended or multiple-choice questions, and any other information End Users may choose to provide.

      Preferences. We also may collect information about End Users’ preferences, including communications preference and other preferences End Users provide when interacting with our Clients.


Personal Information Collected Passively or Automatically


We may automatically collect the following Personal Information from or about End Users who interact with our Clients:


      Device Identifiers. When an End Users interacts with our Clients, we may automatically collect information such as IP address, unique device identifiers, operating system, and other information related to the device used to interact with our Clients via the Huxly Platform.

      Network and Activity Information. We may collect information related to how End Users interact with our Clients in the Huxly Platform, including interactions with advertisements, such as referring and exit web pages and URLs, browsing history, and other similar information. As described below in the “Our Use of Cookies” section, we may use analytics providers and technologies, including cookies and similar tools, to collect this information.


To the extent permitted by applicable law, we may combine this information with other information we collect, including End Users’ Personal Information.




Personal Information We Collect From Third Parties


When End Users interact with our Clients, we may collect Personal Information about End Users through our service providers, affiliates, and vendors who provide services on our behalf.


2.   How We Use Information


We may use the Personal Information we collect for the following purposes:


      Operate Our Business. We use Personal Information to allow End Users to use our services, interact with our Clients via the Huxly Platform, and to otherwise run our day-to-day operations.

      Data Analysis. We use Personal Information collected from and about End Users to conduct data analysis and to provide insights to our Clients on End Users.

      To Communicate With You. We may use Personal Information to communicate with End Users about our services, and to respond to inquiries.

      Evaluate and Improve Our Platform. We may use the Personal Information we collect to evaluate and improve the Huxly Platform, and to measure, improve, and understand the effectiveness of our platform and its features. We may also use this information to develop new service offerings.

      Security Purposes. We may use Personal Information to mitigate fraud and protect Huxly.

      Legal Requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements

      Other Operational Purposes. We may use Personal Information for purposes not provided for in this Policy, but if we do, we will notify the End User (and, if necessary, obtain consent) before using the Personal Information in that way.


3.   How We Disclose Information


We may disclose End Users’ Personal Information with the following parties:


      Service Providers. We disclose information we collect from End Users to service providers, vendors, contractors, or agents who perform functions on our behalf. This includes entities that host the Huxly Platform, perform research and development, and assist us in performing analytics.

      Client and Business Partners. We disclose information we collect to our Clients and business partners for purposes of delivering interactive content.

      Affiliates. We disclose the information we collect to our affiliates or subsidiaries.


We also may disclose End User Personal Information in the following circumstances:


      At an End User’s Request. We may disclose information to others when it is necessary to provide the services requested.

      Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of Personal Information with lenders, auditors, and advisors, including attorneys and consultants.

      In Response to Legal Process. We disclose Personal Information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. If we receive such a request we will take reasonable steps, resources-permitting, to challenge such request and, if we are ultimately unsuccessful in our challenge, we will strive to limit our disclosure to only what is absolutely necessary.

      To Protect Us and Others. We disclose Personal Information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use or this Policy, or as evidence in litigation in which we are involved.

      With an End User’s Permission. We may disclose Personal Information in ways not described above. If we do so, we will notify End Users, and if necessary, obtain consent.


4.   Our Use of Cookies


We use cookies, tags, and similar tracking technologies (“Cookies”) on our website ( to provide, customize, evaluate, and improve our services. A Cookie is a small piece of text that is placed on your device’s browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and partners. Some Cookies are only stored temporarily and are destroyed each time you close your web browser. We also use persistent Cookies, which do not delete when you close your browser and may collect and store data for a set period of time after leaving our platform.


How We Use Cookies


We use Cookies for the following purposes:


      Performance and Analytics. Cookies help us analyze how you interact with our Clients via the Huxly Platform. These Cookies enable us to monitor and improve our platform’s performance, our services, and End User experiences.


How to Manage Cookies


If you wish to prevent Cookies from tracking your activity you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, certain features and services may not work. For more information on how you can customize your browser’s Cookie setting, please visit the link to your web browser below:


      Google Chrome


      Internet Explorer

      Mozilla Firefox


We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.


5.   Do Not Track


Some web browsers and mobile operating systems offer a “Do Not Track” setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Currently, the Huxly Platform and our services do not recognize “Do-Not-Track” requests.


6.   Information Regarding Children


We do not knowingly collect Personal Information from End Users under the age of thirteen (13) without parental consent. If we become aware that we have collected information from a child under 13 years old without parental consent, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please contact using the information provided in the “Contact Us” section below.


7.   Your Privacy Rights


Our Clients are responsible for what they do with the Personal Information they collect about End Users using the Huxly Platform. End Users may have certain rights regarding their Personal Information. Please note these rights are generally exercisable against Huxly’s Clients and not against Huxly because Huxly is acting as a service provider to our Clients.


End Users who have questions or concerns about the data handling practices of our Clients or who wish to exercise privacy rights should contact the relevant Client directly. Where necessary, Huxly will assist our Clients with an exercise of a privacy right by an End User.


8.   Legal Disclaimers


Nothing in this Policy restricts our ability to:


      Comply with federal, state, or local laws;

      Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;

      Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law;

      Exercise or defend legal claims;

      Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or

      Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our business.


9.   Links


The Huxly Platform may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.


10.        Updates to This Policy


This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically.


11.        Contact Us


If you have questions about this Policy, the privacy aspects of our platform, or would like to make a complaint, please contact us at:


Huxly Inc.