Consumer Disclosures & Rights Standard

1. Authorized purpose categories

An HOD Report may be furnished for an eligibility decision only for one of the authorized purposes recognized under the Fair Credit Reporting Act (FCRA), including:

• Written instructions of the person the report relates to.
• Extension of credit, review, or collection of an account belonging to that person.
• Employment purposes, subject to separate written disclosure and authorization.
• Underwriting of insurance involving that person.
• Determination of eligibility for a license or benefit that requires consideration of financial responsibility.
• A legitimate business need connected to a transaction that person initiated, or to review an account to confirm it still meets its terms.
• Court orders or federal grand jury subpoenas.

2. Authorized purpose certification

Every subscriber requesting an HOD Report for an eligibility decision must, before access and before each renewal, provide a written certification identifying (i) the specific authorized purpose, (ii) the person the report relates to, (iii) the intended use, (iv) compliance with all applicable federal, state, and local law, and (v) that the report will not be used for any other purpose. Certifications are logged with a timestamp, IP address, and account identifier and are retained as part of the audit trail.

3. Employment reports

If you intend to use an HOD Report for employment purposes, you must (a) make a clear and conspicuous written disclosure to the person in a document consisting solely of that disclosure, (b) obtain that person's written authorization, (c) before taking any adverse decision based in whole or in part on the report, provide the person with a copy of the report and a copy of Hub or Dub's summary of consumer rights, and (d) after taking the adverse decision, provide notice as described in Section 5. Additional state and local requirements, including fair-chance and pay-inquiry laws, may apply and remain your responsibility.

4. In-depth investigative reports

Where an HOD Report includes an in-depth investigation into a person's character, reputation, or mode of living based on personal interviews, you must provide the person with the required disclosure and honor requests for the nature and scope of the investigation.

5. Decision notice obligations

Any subscriber who takes an adverse decision against a person based in whole or in part on an HOD Report obtained for an authorized purpose must provide that person with (i) notice of the decision, (ii) the name and contact information of Hub or Dub, including its secure support ticket channel, (iii) a statement that Hub or Dub did not make the decision and cannot provide the specific reasons for it, and (iv) notice of the person's right to obtain a free file disclosure from Hub or Dub within sixty (60) days and to dispute the accuracy or completeness of the information, all in accordance with the Fair Credit Reporting Act (FCRA). Additional risk-based pricing notices may be required depending on the decision. Hub or Dub does not accept incoming calls and does not have a corporate phone number. Request a callback from a local HOD Agency or submit a support ticket online.

6. Rights honored by Hub or Dub

• Free file disclosure once every twelve months and in comparable circumstances.
• Dispute and reinvestigation, completed within thirty (30) days (extended by up to fifteen (15) days if you supply additional information during the investigation).
• Correction, deletion, or notation of inaccurate, incomplete, or unverifiable information, with notice to prior recipients on request.
• Security freeze and fraud alert at no cost.
• Identity theft block of information resulting from identity theft.
• Published retention limits (typically seven (7) years for adverse items and ten (10) years for bankruptcies, subject to stated exceptions).
• State equivalents, honored alongside comparable state consumer-protection statutes.

7. Data categories and how they are treated

Hub or Dub separates the information it holds into distinct categories, each with different handling, verification, display, and treatment:

• Eligibility-decision information. Information bearing on a person's creditworthiness, standing, character, general reputation, personal characteristics, or mode of living that is used or expected to be used for an eligibility decision. Furnished only in an HOD Personal Report or HOD Business Report purchased by a verified business with a certified permissible purpose recorded for that purchase, and always subject to the full standard described on this page.
• Reputation information (HOD Score). Verified findings, corroborated documentation, and investigator determinations expressed as a 0 to 1,000 HOD Score. When a HOD Score or the underlying file is used for an eligibility decision, it is treated as eligibility-decision information.
• Public-record information. Court records, licensing records, registrations, and other lawfully available government records. Public-record items are independently corroborated against the source before publication, are subject to Hub or Dub's published retention limits, and are re-verified when reported for employment purposes.
• User-submitted content (HOD Drops). Information submitted by consumers, businesses, or the public. Submissions are free, are never published as received, and are excluded from any HOD Score or HOD Report unless and until an investigator verifies them against independent documentation. Unverified, anonymous, or speculative submissions are rejected.
• Self-provided identity and account data. Information you supply to verify your identity, claim your file, or operate your account. It is used for verification, security, fraud prevention, and service delivery, and is governed by the Privacy Policy.

8. Who may obtain a report; no resale

Every person and business may access, monitor, and dispute their own file for free, forever. Only verified businesses with a certified FCRA permissible purpose may purchase an HOD Personal Report or HOD Business Report on another person or business, one report at a time, subject to business verification, written permissible-purpose certification for each purchase, and audit. Individuals may not purchase or run a report on another person or business.

No purchase, price, volume, or negotiated term sold by Hub or Dub reduces, waives, delays, or circumvents any right afforded to the people and businesses Hub or Dub covers, or any applicable federal or territorial law. Every subject keeps the same rights to free file disclosure, dispute, reinvestigation, correction, deletion of unverifiable information, notice of adverse action, and a record of who accessed their file, regardless of how many reports the requesting business has purchased.

Plan access matrix

Hub or Dub is not a reseller. We assemble and verify our own file information and do not resell reports assembled by another organization. Subscribers may not resell, redistribute, sublicense, syndicate, or re-furnish a report or any portion of it to any third party, and may not use a report for any purpose other than the purpose certified at the time of the run.

9. Accuracy procedures and recordkeeping

Hub or Dub follows reasonable procedures designed to assure maximum possible accuracy under the Fair Credit Reporting Act (FCRA). Every item is evidence-backed, source-attributed, and reviewed by a human investigator before publication; every active file is re-reviewed at least once every three (3) months; and disputed items are marked, reinvestigated, and corrected, deleted, or annotated based on documentation. We maintain records of every authorized-purpose certification, report run, identity verification, dispute, reinvestigation outcome, correction, and disclosure recipient, retained for the period required by applicable law and available to consumers and regulators on request.

10. Summary of your rights

Hub or Dub's plain-language summary of your rights is included with every adverse decision notice, file disclosure, and dispute response we generate, and is available at any time on the Your Rights page. The Consumer Financial Protection Bureau's Summary of Consumer Rights is also available at consumerfinance.gov. State-specific supplements are provided where required.

11. Regulatory cooperation and audits

Hub or Dub cooperates with applicable regulators and state attorneys general nationwide. Business subscribers agree to reasonable audit rights sufficient to demonstrate ongoing compliance with the authorized-purpose standard, on reasonable advance notice and subject to confidentiality.

12. Contact for consumer matters

Hub or Dub Inc., Consumer Relations. Free file disclosures, disputes, and adverse decision inquiries: hubordub.com/disputes. Consumers may also reach us through the secure support ticket system. Hub or Dub does not accept incoming calls and does not have a corporate phone number. Request a callback from a local HOD Agency or submit a support ticket online.

Hub or Dub Inc.'s National Headquarters is located at 101 6th Avenue, 9th Floor, New York, New York 10013. Hub or Dub Inc. does not currently accept in-person visits to its HQ, and does not accept postal mail, walk-ins, in-person appointments, document drop-offs, or on-site service requests. All inquiries must be submitted online through the appropriate channels provided. All support, verification, reporting, investigations, and disputes are handled remotely through approved digital channels. Please scan and email all documentation to hello@hubordub.com.