> For the complete documentation index, see [llms.txt](https://policies.hubble.vote/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://policies.hubble.vote/privacy-policy/ii-data-controller-and-data-processor.md).

# II - Data Controller and Data Processor

Certain data protection laws and regulations typically distinguish between two main roles for parties processing PII:&#x20;

* the “Data Controller”, who determines the purposes and means of processing, and&#x20;
* the “Data Processor”, who processes the data on behalf of the Data Controller.&#x20;

Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Hubble processes certain data collected by our Services solely on each Owner's behalf and such Owner retains ownership of their respective data. Each Owner is the “Data Controller” of their Managers', Members', and Engagers' PII (excluding Account Data) when Hubble processes such data. This means that in such cases, we will only process such data in accordance with the reasonable instructions of the Owner, subject to our Terms of Service and our contractual agreements, and strictly on their behalf. The Owner will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

Hubble is the “Data Controller” of all data that is required to operate our Services. This includes but is not limited to the Account Data of users, the geocoordinate positions of Addresses, and Voter Information and History received from public records. In addition, certain PII when it processes such data for its own purposes. This means that when processing is performed for Hubble purposes (as set forth under this Notice), namely PII which pertains to Owners, Managers, Members, and Engagers overall use of our Services, then Hubble will control such data, and assume the responsibilities of Data Controller (solely to the extent applicable under law).


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