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User-Generated Content (UGC) Policy

for the HABBL APP, Version: 1.0, Effective Date: May 11, 2026


1. Preamble

This User-Generated Content Policy (“UGC Policy”) governs the creation, collection, storage, processing, transmission, and use of all content submitted, uploaded, entered, or otherwise provided by users within the HABBL APP.

This UGC Policy is intended to:

  • ensure lawful and secure operational processes;
  • maintain compliance with data protection and security requirements;
  • support documentation of logistics and transportation operations;
  • prevent fraud, manipulation, misuse, and security incidents;
  • ensure compliance with regulatory and internal compliance obligations;
  • protect the legitimate interests of the APP operator, customers, and business partners.

This UGC Policy forms an integral part of the APP’s Terms of Use.

 

2. Scope

This Policy applies to all users of the APP, including but not limited to:

  • drivers;
  • carriers;
  • subcontractors;
  • fleet operators;
  • dispatchers;
  • customers with upload permissions;
  • other authorized users.

This Policy applies regardless of the device or communication channel used and covers all content processed or transmitted through the APP.

 

3. Definition of User-Generated Content

“User-Generated Content” (“UGC”) includes all data and information created, uploaded, entered, stored, transmitted, or otherwise provided by users within the APP, including but not limited to:

  • delivery and shipment photographs;
  • proof-of-delivery documentation;
  • vehicle and cargo images;
  • damage and incident reports;
  • comments and text entries;
  • status updates;
  • messages and chat content;
  • digital signatures;
  • documents and file attachments;
  • audio and video files;
  • GPS-related notes;
  • metadata and timestamps.

 

4. Acceptable Use

Users may only provide content that:

  • is directly related to operational, logistics, or transportation activities;
  • is accurate and non-misleading;
  • complies with applicable laws and regulations;
  • does not infringe third-party rights;
  • is necessary or appropriate for operational processes.

Use of the APP must at all times remain:

  • professional;
  • factual;
  • compliant with security requirements;
  • and consistent with internal compliance standards.

to be carried out.

 

5. Prohibited Content and Conduct

Users are prohibited from uploading, storing, transmitting, or otherwise making available any content that:

5.1 Illegal Content

  • violates applicable laws or regulations;
  • promotes or supports criminal activities;
  • is abusive, discriminatory, defamatory, or threatening;
  • contains pornographic, extremist, or violent material.

5.2 Data Protection and Confidentiality Violations

  • unlawfully discloses personal data;
  • contains confidential customer, employee, or business information;
  • violates privacy, confidentiality, or security obligations;
  • unnecessarily identifies individuals.

5.3 Fraud, Manipulation, and Misuse

  • abusive duplicate reporting;
  • spam, advertising, or unrelated content;
  • political or religious campaign content.

5.4 Security-Related Violations

  • malware or malicious files;
  • phishing content;
  • credentials or authentication information;
  • content intended to bypass technical security measures.

 

6. Image and Delivery Documentation

6.1 General Requirements

Images and documentation may only be used for operational documentation of logistics and transportation processes. Uploaded content must be:

  • authentic;
  • unaltered;
  • complete;
  • verifiable;
  • operationally relevant.

6.2 Data Protection and Data Minimization

Users must comply with the principle of data minimization. In particular:

  • individuals should not be identifiable unless operationally necessary;
  • private areas should be avoided;
  • personal documents should not be unnecessarily captured;
  • license plates or addresses should only be documented where operationally required.

6.3 Prohibited Image Content

The following content is prohibited:

  • private or unrelated photographs;
  • offensive or discriminatory content;
  • manipulated image files;
  • content without operational relevance;
  • confidential information without authorization.

 

7. Rules for Communications and Text Entries

Communication and text-entry functions may only be used for operational and business purposes. Users agree to maintain:

  • professional communication;
  • respectful conduct;
  • factual accuracy;
  • truthful reporting.

The following are prohibited:

  • insults or threats;
  • discriminatory statements;
  • inappropriate comments;
  • unauthorized disclosure of confidential information;
  • misleading or false reports.

 

8. Rights to Uploaded Content

By uploading or transmitting content, the user grants the APP operator a non-exclusive, worldwide, transferable, sublicensable, and royalty-free license to use such content to the extent necessary for:

  • operation and provision of the APP;
  • execution of logistics processes;
  • compliance and audit purposes;
  • quality assurance;
  • fraud prevention;
  • legal documentation and evidentiary purposes;
  • security monitoring;
  • technical analysis;
  • AI-assisted processing;
  • service improvement.

Such rights are granted for the duration required by applicable legal retention and evidentiary obligations.

 

9. AI-Assisted Processing and Automated Systems

The APP operator may use automated systems and AI-assisted technologies for:

  • fraud detection;
  • proof-of-delivery analysis;
  • quality control;
  • pattern recognition;
  • security monitoring;
  • compliance verification;
  • process optimization.

Automated reviews may result in:

  • warnings;
  • restricted functionalities;
  • manual review procedures;
  • escalations;
  • temporary account restrictions.

Where legally required, automated decision-making shall be conducted in accordance with applicable data protection laws.

 

10. Moderation, Monitoring, and Enforcement Rights

The APP operator reserves the right, at any time and without prior notice, to:

  • review;
  • moderate;
  • restrict;
  • suspend;
  • remove;
  • or disable access to content

where:

  • violations of this Policy are suspected or identified;
  • security or compliance risks exist;
  • legal obligations require action;
  • legitimate interests of the APP operator are affected.

Users have no entitlement to permanent storage or publication of submitted content.

 

11. Retention and Storage

User-generated content may be stored and archived in accordance with:

  • statutory retention obligations;
  • compliance requirements;
  • audit and evidentiary obligations;
  • security requirements;
  • operational documentation needs.

Content will be deleted once retention is no longer required and applicable laws permit deletion.

 

12. Data Protection

Personal data shall be processed in accordance with:

  • the Privacy Policy;
  • the General Data Protection Regulation (“GDPR”);
  • and other applicable data protection laws.

Users may only upload or process personal data necessary for the relevant operational purpose.

 

13. Security and Reporting Obligations

Users are required to immediately report:

  • security incidents;
  • personal data breaches;
  • unauthorized access;
  • misuse of the APP;
  • suspected fraud or manipulation.

 

14. Enforcement Measures

In the event of violations of this Policy, the APP operator reserves the right to implement measures including:

  • removal of content;
  • warnings;
  • restriction of functionalities;
  • temporary or permanent account suspension;
  • termination of contractual relationships;
  • claims for damages;
  • legal proceedings.

Further statutory or contractual rights remain unaffected.

 

15. Amendments to this Policy

The APP operator reserves the right to amend this Policy at any time with future effect. Updated versions will be published within the APP or by other appropriate means.

 

16. Contact

EIKONA GmbH
Am Alten Bahnhof 8
97332 Volkach
eMail:
Tel: +49(0)9381 / 71778-80