Privacy Policy

Last Updated: June 9, 2026

Hubly Surgical, Inc. (“Hubly,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website, contact us, request information, subscribe to updates, interact with our online forms, or otherwise communicate with us.

This Privacy Policy applies to information collected through our website and related online interactions. It does not apply to information collected offline, through separate agreements, or through other channels where a different privacy notice is provided.

Hubly Surgical is a medical device company. Our website is intended for general business, product, educational, and informational purposes. It is not intended to provide medical advice, diagnose or treat any condition, or collect patient medical information. Please do not submit protected health information, patient-identifiable information, emergency medical information, or other sensitive health information through our website forms.

1. Information We Collect

We may collect the following categories of personal information:

Information You Provide to Us

You may provide personal information when you fill out a form, request information, contact us, subscribe to updates, request a demonstration, communicate with our team, or otherwise interact with us. This information may include:

• Name
• Email address
• Phone number
• Job title or professional role
• Employer, hospital, health system, practice, or organization name
• Mailing address or business address
• Information contained in your message or inquiry
• Any other information you choose to provide

Information Collected Automatically

When you visit our website, we and our service providers may automatically collect information about your device and online activity, including:

• IP address
• Browser type
• Device type
• Operating system
• Referring website
• Pages viewed
• Dates and times of visits
• Links clicked
• Approximate location derived from IP address
• Cookie identifiers and similar tracking technologies

Cookies and Similar Technologies

We may use cookies, pixels, tags, web beacons, analytics tools, and similar technologies to operate our website, understand how visitors use it, improve our content, measure performance, and, where applicable, support advertising or marketing activities.

Cookies may be categorized as:

• Essential cookies, which are necessary for the website to function.
• Analytics cookies, which help us understand how visitors use our website.
• Functional cookies, which support enhanced website features.
• Advertising or marketing cookies, which may be used to measure or deliver marketing content.

You can manage cookies through our cookie banner or cookie preferences tool, where available. You may also be able to limit cookies through your browser settings.

2. How We Use Personal Information

We may use personal information for the following purposes:

• To respond to inquiries and requests
• To provide information about Hubly, our products, and our services
• To communicate with healthcare professionals, hospitals, business contacts, customers, potential customers, investors, vendors, and partners
• To process requests for demos, product information, sales follow-up, or support
• To send newsletters, updates, or marketing communications where permitted by law
• To operate, maintain, secure, and improve our website
• To analyze website traffic and user interactions
• To detect, prevent, and address security incidents, fraud, misuse, or technical issues
• To comply with legal, regulatory, and contractual obligations
• To enforce our rights and protect the rights, property, or safety of Hubly, our users, customers, or others
• For other purposes disclosed at the time information is collected

3. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

Service Providers and Vendors

We may share information with vendors and service providers that help us operate our business, including website hosting providers, analytics providers, customer relationship management tools, email and marketing platforms, form providers, security providers, professional advisors, and other business service providers.

Business Partners and Customers

Where appropriate, we may share information with business partners, distributors, hospitals, health systems, or other relevant parties in connection with product inquiries, sales, support, or business operations.

Professional Advisors

We may disclose information to attorneys, accountants, auditors, insurers, consultants, and other professional advisors.

Legal and Compliance Purposes

We may disclose information if we believe it is necessary or appropriate to comply with applicable law, regulation, legal process, regulatory request, court order, or government inquiry, or to protect our rights, users, customers, or others.

Business Transactions

If Hubly is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction, personal information may be disclosed or transferred as part of that transaction.

4. Analytics, Advertising, and Online Tracking

We may use analytics and similar tools to understand how visitors interact with our website. These tools may collect information such as IP address, device identifiers, browser information, pages visited, and interactions with our website.

We may also use advertising or marketing technologies, such as pixels or tags, to measure marketing effectiveness or deliver relevant content. Some state privacy laws may consider certain uses of advertising or analytics technologies to be a “sale,” “sharing,” or “targeted advertising,” even if we do not sell personal information for money.

Where required by law, you may opt out of the sale or sharing of personal information, targeted advertising, or certain non-essential cookies by using our cookie preferences tool or by clicking a “Do Not Sell or Share My Personal Information” link, if available.

We also endeavor to honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control, where required by applicable law.

5. Your Choices

You may have the following choices regarding your personal information:

Marketing Communications

You may opt out of receiving marketing emails from us by following the unsubscribe instructions in those emails or by contacting us. Even if you opt out of marketing communications, we may still send you non-marketing communications, such as responses to inquiries, transactional messages, or legal notices.

Cookies

You can manage cookies through our cookie banner or cookie preferences tool, where available. You may also be able to disable or delete cookies through your browser settings. If you disable cookies, some website features may not function properly.

Browser Privacy Signals

Some browsers and extensions allow you to send privacy preference signals, such as Global Privacy Control. Where required by law, we treat such signals as valid requests to opt out of the sale or sharing of personal information for the browser or device sending the signal.

6. State Privacy Rights

Depending on where you live and subject to applicable law, you may have certain rights regarding your personal information. These may include the right to:

• Request access to the personal information we maintain about you
• Request correction of inaccurate personal information
• Request deletion of personal information
• Request a copy of personal information in a portable format
• Opt out of the sale or sharing of personal information
• Opt out of targeted advertising
• Limit certain uses or disclosures of sensitive personal information, where applicable
• Appeal a decision regarding a privacy request, where applicable
• Not be discriminated against for exercising privacy rights

To exercise a privacy right, please contact us using the contact information below. We may need to verify your identity before processing your request. If you submit a request through an authorized agent, we may require proof that the agent is authorized to act on your behalf.

We do not knowingly sell personal information for monetary payment. However, some uses of cookies, pixels, analytics tools, or advertising technologies may be considered a “sale,” “sharing,” or “targeted advertising” under certain privacy laws. You may opt out of these activities through our cookie preferences tool or other opt-out mechanisms provided on our website.

7. Sensitive Information and Health Information

Please do not submit patient information, protected health information, medical records, clinical details about an identifiable patient, or emergency medical information through our website forms.

If you need to report a product complaint, adverse event, or urgent product-related matter, please contact Hubly through the appropriate support, regulatory, or customer service channel rather than submitting patient-identifiable information through a general website form.

We do not intentionally collect sensitive personal information through our website for the purpose of inferring characteristics about visitors.

8. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to respond to inquiries, maintain business records, comply with legal or regulatory obligations, resolve disputes, enforce agreements, and protect our rights.

Retention periods may vary depending on the type of information, the context in which it was collected, and applicable legal or business requirements.

9. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

10. Children’s Privacy

Our website is intended for adults and business users, including healthcare professionals and institutional customers. It is not directed to children, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child without appropriate consent, we will take steps to delete it as required by law.

11. Links to Third-Party Websites

Our website may contain links to third-party websites, resources, or services. We are not responsible for the privacy practices, security, or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. International Visitors

Hubly is based in the United States. If you access our website from outside the United States, your information may be processed in the United States or other jurisdictions where privacy laws may differ from those in your location.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last Updated” date above and may provide additional notice where required by law. Your continued use of our website after an updated Privacy Policy is posted means that you acknowledge the updated Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or would like to exercise a privacy right, please contact us at:

Hubly Surgical, Inc.
Email: info@hublysurgical.com
Mailing Address: 815 Ogden Ave, Lisle, IL 60532

For privacy requests, please include your name, contact information, state or country of residence, and the nature of your request. Please do not include patient-identifiable health information in your request.