DRAFT. Needs legal review before launch. Text in [square brackets] is a placeholder for the business to fill in.

Privacy notice

Last updated: 25 October 2026

Hubbuna lets you make a private web page for your husband or wife. This notice explains, in plain words, what we collect, why, and what you can do about it. It is written to meet Malaysia's Personal Data Protection Act 2010 (PDPA) and the main principles of other privacy laws such as the EU/UK GDPR. [Which laws apply to be confirmed in legal review.]

Who we are

[Company legal name], [Company registration number], [Registered address]. Contact: [Contact email].

What we collect

• What you put on your page: names or nicknames, dates, photos, captions, your story, letter and du'a.
• Your email, only if you add it to your page (for edit links and the one-year reminder). We don't ask for your phone number, address or IC/ID.
• Replies the person you sent the page to writes back to you.
• Payment records (plan, amount, date). Card or bank details are handled by our payment processor, never by us.
• Basic technical data to keep the service safe: approximate country (to show prices in your currency), and IP address used briefly for rate limits against abuse. We count events (for example "a page was opened") without names or photos.

Why we use it

• To build, store and show your page to the person you share it with.
• To let you edit, export and delete it.
• To send you emails you asked for: edit links, and one reminder 14 days before your page's first anniversary.
• To take payment and keep records the law requires.
• To prevent abuse and handle reports.

We do not sell your data, show ads, or put third-party trackers on the pages you send.

Emails we send

If your page has an email address, we send at most: edit links when you ask for them, and one reminder 14 days before the first anniversary of your page, with links to download or delete it. No newsletters or marketing. Remove the email from your page and we send nothing.

Photos of other people

Your page will usually include your spouse and sometimes your children. By uploading, you confirm you have the right to share these photos. Photos are resized on your phone and location (GPS) data is removed before upload.

End-to-end encryption

New pages are end-to-end encrypted. Your photos, names, captions, story, letter, du'a choices and replies are locked in your browser with a random key before they're saved. That key travels only inside the link itself, after the # sign (for example /p/…#k=…), which browsers never send to us. We store only the locked (encrypted) data, so we can't read your page, and nor can our hosting provider.

• Your private edit link holds a second key. If you lose it, nobody, including us, can recover the page. Sign-in emails can't carry the key.
• Photos are re-saved in your browser before upload, which removes location (GPS) and camera details.
• Still readable by us: your email (if you add one, for sign-in and the reminder), dates, plan, the page's theme and display settings, and the size and number of photos.
• If you choose to show names on the envelope, they're encrypted too, but that small locked item is sent before the PIN is entered so the envelope can show them.
• The PIN is a second lock: nothing encrypted is sent until the right PIN is entered. Anyone with the full link and PIN can read the page, and the link stays in their browser history.

Who can see your page

Only people who have the link, and the PIN if one is set (PINs are on by default). Links are random and very hard to guess. Pages are marked so search engines don't list them, and there is no public gallery. Photos are only served through links that expire after a short time. Anyone you give the link and PIN to can take screenshots, so share it only with the person it's meant for.

Where it's stored

We use Cloudflare to host the service and store data. Cloudflare runs data centres in many countries, so your data may be processed outside your country. To stop spam, the create, reply and report forms use Cloudflare Turnstile, which checks your browser for signs of automation without tracking you across sites. Payments are handled by our payment processor under its own privacy policy. [Processor name and its privacy policy link to be added once chosen.]

How long we keep it

• Unsent drafts: deleted automatically after 30 days without changes.
• Sent pages: for the paid period (Simple: 1 year; Keep: as long as the service runs, at least 5 years; Special: as long as the service runs, at least 5 years).
• Deleted pages: hidden from everyone immediately, then erased for good, with every photo and reply, after 7 days. Our database provider keeps point-in-time history for up to 30 days, so encrypted copies can remain in that history for up to 30 days after erasure. They stay encrypted and can't be read without your link.
• Payment records: as long as tax and accounting law requires.

Your rights and choices

• Export everything at any time as a ZIP file: photos, text, replies and an offline copy of the page.
• Delete your page at any time from the builder (erased for good 7 days later; you can undo before then).
• Correct anything by editing your page.
• Access, object or complain: email [Contact email]. You can also complain to your data protection authority (in Malaysia, the Personal Data Protection Commissioner).

Reports and takedowns

Anyone can report a page. We review reports and take a page down within 24 hours if it breaks our rules.

Children

The service is for adults. We don't knowingly collect data from children, other than photos a parent chooses to include.

Changes

If we change this notice in a way that matters, we'll update the date above and tell paying users by email.