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Privacy Policy

Last updated: September 30, 2022

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure

of Your information when You use the Service and tells You about Your privacy rights and how

the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree

to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following

conditions. The following definitions shall have the same meaning regardless of whether they

appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

– Account means a unique account created for You to access our Service or parts of our

Service.

– Business, for the purpose of General Data Protection Regulation (GDPR), refers to the

Company as the legal entity that collects Consumers’ personal information and

determines the purposes and means of the processing of Consumers’ personal

information, or on behalf of which such information is collected and that alone determines the purposes and means of the processing of consumers’ personal

information.

– Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement)

refers to HDL Design House, Golsvordijeva 35, Belgrade, Serbia.

For the purpose of the GDPR, the Company is the Data Processor.

– Data Subject, for the purpose of General Data Protection Regulation (GDPR), means a

natural person whose personal data are being processed.

– Cookies are small files that are placed on Your computer, mobile device or any other

device by a website, containing the details of Your browsing history on that website

among its many uses.

– Country refers to: Serbia

– Data Processor, for the purposes of the GDPR (General Data Protection Regulation), refers to a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

– Device means any device that can access the Service such as a computer, a cellphone or a

digital tablet.

– Facebook Fan Page is a public profile named HDL Design House specifically created by

the Company on the Facebook social network, accessible from

https://www.facebook.com/people/HDL-Design-House/100029115624386/

– Personal Data, for the purposes of GDPR, means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

– Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

– Service refers to the Website.

– Sub-processor means any natural or legal person who processes the data on behalf of

the Company.

– Usage Data refers to data collected automatically, either generated by the use of the

Service or from the Service infrastructure itself (for example, the duration of a page

visit).

– Website refers to HDL Design House, accessible from https:/www.hdl-dh.com

– You means the individual accessing or using the Service, or the company, or other legal

entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data

Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable

information that can be used to contact or identify You:

– Email address

– First name and last name

– Phone number

– Usage Data

-Residence location

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP

address), browser type, browser version, the pages of our Service that You visit, the time and

date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic

data.

When You access the Service by or through a mobile device, We may collect certain information

automatically, including, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Personal Data collected are limited to what is necessary in relation to the purposes for which they are processed pursuant to Art. 5 GDPR.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store

certain information. Tracking technologies used are beacons, tags, and scripts to collect and track

information and to improve and analyze Our Service. The technologies We use may include:

– Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can

instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.

However, if You do not accept Cookies, You may not be able to use some parts of our

Service

– Web Beacons. Certain sections of our Service and our emails may contain small

electronic files known as web beacons (also referred to as clear gifs, pixel tags, and

single-pixel gifs) that permit the Company, for example, to count users who have visited

those pages or opened an email and for other related website statistics (for example,

recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal

computer or mobile device when You go offline, while Session Cookies are deleted as soon as

You close Your web browser. You can learn more about cookies on TermsFeed website article.

For more information about the cookies we use and your choices regarding cookies, please visit our cookie policy.

Use of Your Personal Data

The Company collects first and last name, e-mail address and phone number based on Art. 6, 1a GDPR for the following purposes:

– To manage your account: to manage Your registration as a user of the Service. The

Personal Data You provide can give You access to different functionalities of the Service

that are available to You as a registered user

– To contact You: To contact You by email, telephone calls, SMS, or other equivalent

forms of electronic communication, such as a mobile application’s push notifications

regarding updates or informative communications related to the functionalities, products

or contracted services, including the security updates, when necessary or reasonable for

their implementation.

– To provide You with news, special offers and general information about other goods,

services and events which we offer that are similar to those that you have already

purchased or enquired about unless You have opted not to receive such information.

– To manage Your requests: To attend and manage Your requests to Us.

The Company collects first and last name, e-mail address, phone number and residence location based on Art. 6, 1b for the following purpose:

– For the performance of a contract: the development, compliance and undertaking of

the purchase contract for the products, items or services You have purchased or of any

other contract with Us through the Service.

The Company collects first and last name, e-mail address, phone number and usage data based on Art. 6, 1a for the following purpose:

– To deliver targeted advertising to You: We may use Your information to develop and

display content and advertising (and work with third-party vendors who do so) tailored to

Your interests and/or location and to measure its effectiveness, unless you have opted not to receive such information. We may share Your information with our business partners to

offer You certain products, services or promotions, unless you have opted not to receive such information.

The Company collects usage data based on Art. 6, 1a for the following purposes:

– data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and improvement of our Service, products, services, marketing and your experience.

The Company collects all kinds of personal data mentioned above (namely first and last name, e-mail address, phone number, residence location and usage Data) for the following purposes:

– To provide and maintain our Service, including to monitor the usage of our Service. In this case we may share your personal information with our Affiliates. In this case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with Us. The process is based on Art. 6, 1a

-For business transfers: We may use Your information to evaluate or conduct a merger,

divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or

all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or

similar proceeding, in which Personal Data held by Us about our Service users is among

the assets transferred. The process is based on Art. 6, 1c.

We may share Your personal information:

– With other users: when You share personal information or otherwise interact in the

public areas with other users, based on Art. 6, 1a such information may be viewed by all users and may be publicly distributed outside.

The company shall process personal data pursuant to the principles stipulated in Art.5 GDPR and consent, when asked, is always given under the provisions of Art. 7 GDPR.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set

out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally

retained for a shorter period of time, except when this data is used to strengthen the security or to

improve the functionality of Our Service, or We are legally obligated to retain this data for

longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and

in any other places where the parties involved in the processing are located. It means that this

information may be transferred to — and maintained on — computers located outside of Your

state, province, country or other governmental jurisdiction where the data protection laws may

differ than those from Your jurisdiction. The company ensures that the transfer of your personal data to these countries takes place according to GDPR provisions.

Your consent to this Privacy Policy followed by Your submission of such information represents

Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely

and in accordance with this Privacy Policy and the requirements of GDPR and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data and according to provisions of Chapter V GDPR (Transfers of personal data to third countries or international organisations).

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have

collected about You according to Art. 17 GDPR.

Our Service may give You the ability to delete certain information about You from within the

Service.

You may update, amend, or delete Your information at any time by signing in to Your Account,

if you have one, and visiting the account settings section that allows you to manage Your

personal information. You may also contact Us to request access to, correct, or delete any

personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal

obligation or lawful basis to do so. In this case, the Company shall restrict data subject’s data from further processing according to Art. 18 GDPR.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be

transferred as long as the contracting party meets the legal data protection requirements and prove their data protection level according to GDPR.

We will provide notice before Your Personal Data is transferred and becomes subject

to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if

required to do so by law or in response to valid requests by public authorities (e.g. a court or a

government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is

necessary to:

– Comply with a legal obligation

– Protect and defend the rights or property of the Company

– Prevent or investigate possible wrongdoing in connection with the Service

– Protect the personal safety of Users of the Service or the public

– Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to us. We implement appropriate technical and organisational measures to ensure a level of security which ensures the availability, confidentiality and integrity of your Personal Data, according to Art. 32 GDPR.

Detailed Information on the Processing of your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party

vendors collect, store, use, process and transfer information about Your activity on Our Service

in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

– Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports

website traffic. Google uses the data collected to track and monitor the use of our

Service. This data is shared with other Google services. Google may use the collected

data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google

Analytics by installing the Google Analytics opt-out browser add-on. The add-on

prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing

information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy

& Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional

materials and other information that may be of interest to You. You may opt-out of receiving

any, or all, of these communications from Us by following the unsubscribe link or instructions

provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

– Sugar CRM

Their Privacy Policy can be viewed at https://www.sugarcrm.com/legal/privacy-policy/

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our

Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us

recognize Your Device and understand how You use our Service so that We can improve our

Service to reflect Your interests and serve You advertisements that are likely to be of more

interest to You.

These third-party vendors collect, store, use, process and transfer information about Your

activity on Our Service in accordance with their Privacy Policies and to enable Us to:

– Measure and analyze traffic and browsing activity on Our Service

– Show advertisements for our products and/or services to You on third-party websites or

apps

– Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by

browser settings that block cookies. Your browser may not permit You to block such

technologies. You can use the following third-party tools to decline the collection and use of

information for the purpose of serving You interest-based advertising:

– The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

– The EDAA’s opt-out platform http://www.youronlinechoices.com/

– The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile

device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See

Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online

identifiers collected on Our Service with these third-party vendors. This allows Our third-party

vendors to recognize and deliver You ads across devices and browsers. To read more about the

technologies used by these third-party vendors and their cross-device capabilities please refer to

the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

– Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google

Display Network ads by visiting the Google Ads Settings page:

http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on –

https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-

out Browser Add-on provides visitors with the ability to prevent their data from being

collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy

& Terms web page: https://policies.google.com/privacy

– Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their instructions:

https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their

Privacy Policy page: https://twitter.com/privacy

– Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page:

https://www.facebook.com/help/516147308587266

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook:

https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising

established by the Digital Advertising Alliance. You can also opt-out from Facebook and

other participating companies through the Digital Advertising Alliance in the USA

http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada

http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in

Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data

Policy: https://www.facebook.com/privacy/explanation

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

– Consent: You have given Your consent for processing Personal Data for one or more

specific purposes.

– Performance of a contract: Provision of Personal Data is necessary for the performance

of an agreement with You and/or for any pre-contractual obligations thereof.

– Legal obligations: Processing Personal Data is necessary for compliance with a legal

obligation to which the Company is subject.

– Vital interests: Processing Personal Data is necessary in order to protect Your vital

interests or of another natural person.

– Public interests: Processing Personal Data is related to a task that is carried out in the

public interest or in the exercise of official authority vested in the Company.

– Legitimate interests: Processing Personal Data is necessary for the purposes of the

legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the

processing, and in particular whether the provision of Personal Data is a statutory or contractual

requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee

You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

– Request access to Your Personal Data. The right to access, update or delete the

information We have on You. Whenever made possible, you can access, update or

request deletion of Your Personal Data directly within Your account settings section. If

you are unable to perform these actions yourself, please contact Us to assist You. This

also enables You to receive a copy of the Personal Data We hold about You.

– Request correction of the Personal Data that We hold about You (right to rectification Art. 16 GDPR): You have the right to have any incomplete or inaccurate information We hold about You corrected.

-Right to object (Art. 21 GDPR). This right exists where We are relying on

a legitimate interest as the legal basis for Our processing and there is something about

Your particular situation, which makes You want to object to our processing of Your

Personal Data on this ground. You also have the right to object where We are processing

Your Personal Data for direct marketing purposes.

– Request erasure of Your Personal Data. You have the right to ask Us to delete or

remove Personal Data when there is no good reason for Us to continue processing it.

– Request the transfer of Your Personal Data. We will provide to You, or to a third-

party You have chosen, Your Personal Data in a structured, commonly used, machine-

readable format. Please note that this right only applies to automated information which

You initially provided consent for Us to use or where We used the information to

perform a contract with You.

– Withdraw Your consent. You have the right to withdraw Your consent on using your

Personal Data. If You withdraw Your consent, we may not be able to provide You with

access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting

Us through our website and by e-mail: privacy@hdl-dh.com . Please note that we may ask You to verify Your identity before responding to such requests.

If You make a request, we will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of

Your Personal Data. For more information, if You are in the European Economic Area (EEA),

please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As

operator of the Facebook Fan Page https://www.facebook.com/people/HDL-Design-

House/100029115624386/, the Company and the operator of the social network Facebook are

Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the

Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms

of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information

about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook,

Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan

Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our

users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan

Page. Each Cookie contains a unique identifier code and remains active for a period of two years,

except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when

the user visits the Facebook services, services that are provided by other members of the

Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy

here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our

Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of

California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being

associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer

or Device. The following is a list of categories of personal information which we may collect or

may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the

CCPA. This does not mean that all examples of that category of personal information were in

fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of

that information from the applicable category may be and may have been collected. For example,

certain categories of personal information would only be collected if You provided such personal

information directly to Us.

– Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier,

Internet Protocol address, email address, account name, driver’s license number, passport

number, or other similar identifiers.

Collected: Yes.

– Category B: Personal information categories listed in the California Customer

Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or

description, address, telephone number, passport number, driver’s license or state

identification card number, insurance policy number, education, employment,

employment history, bank account number, credit card number, debit card number, or any

other financial information, medical information, or health insurance information. Some

personal information included in this category may overlap with other categories.

Collected: Yes.

– Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship,

religion or creed, marital status, medical condition, physical or mental disability, sex

(including gender, gender identity, gender expression, pregnancy or childbirth and related

medical conditions), sexual orientation, veteran or military status, genetic information

(including familial genetic information).

Collected: No.

– Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: No.

– Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity

patterns used to extract a template or other identifier or identifying information, such as,

fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other

physical patterns, and sleep, health, or exercise data.

Collected: No.

– Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

– Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

– Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

– Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

– Category J: Non-public education information (per the Family Educational Rights

and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational

institution or party acting on its behalf, such as grades, transcripts, class lists, student

schedules, student identification codes, student financial information, or student

disciplinary records.

Collected: No.

– Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends,

predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

– Publicly available information from government records

– Deidentified or aggregated consumer information

– Information excluded from the CCPA’s scope, such as:

o Health or medical information covered by the Health Insurance Portability and

Accountability Act of 1996 (HIPAA) and the California Confidentiality of

Medical Information Act (CMIA) or clinical trial data

o Personal Information covered by certain sector-specific privacy laws, including

the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or

California Financial Information Privacy Act (FIPA), and the Driver’s Privacy

Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of

sources:

– Directly from You. For example, from the forms You complete on our Service,

preferences You express or provide through our Service.

– Indirectly from You. For example, from observing Your activity on our Service.

– Automatically from You. For example, through cookies We or our Service Providers set

on Your Device as You navigate through our Service.

– From Service Providers. For example, third-party vendors to monitor and analyze the

use of our Service, third-party vendors to deliver targeted advertising to You, or other

third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or

Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial

purposes” (as defined under the CCPA), which may include the following examples:

– To operate our Service and provide You with our Service.

– To provide You with support and to respond to Your inquiries, including to investigate

and address Your concerns and monitor and improve our Service.

– To fulfill or meet the reason You provided the information. For example, if You share

Your contact information to ask a question about our Service, We will use that personal

information to respond to Your inquiry.

– To respond to law enforcement requests and as required by applicable law, court order, or

governmental regulations.

– As described to You when collecting Your personal information or as otherwise set forth

in the CCPA.

– For internal administrative and auditing purposes.

– To detect security incidents and protect against malicious, deceptive, fraudulent or illegal

activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive.

For more details on how we use this information, please refer to the “Use of Your Personal Data”

section.

If We decide to collect additional categories of personal information or use the personal

information We collected for materially different, unrelated, or incompatible purposes We will

update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or

Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the

following categories of personal information for business or commercial purposes:

– Category A: Identifiers

– Category B: Personal information categories listed in the California Customer Records

statute (Cal. Civ. Code § 1798.80(e))

– Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean

that all examples of that category of personal information were in fact disclosed, but reflects our

good faith belief to the best of our knowledge that some of that information from the applicable

category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We

enter a contract that describes the purpose and requires the recipient to both keep that personal

information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing,

disseminating, making available, transferring, or otherwise communicating orally, in writing, or

by electronic or other means, a consumer’s personal information by the business to a third party

for valuable consideration. This means that We may have received some kind of benefit in return

for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean

that all examples of that category of personal information were in fact sold, but reflects our good

faith belief to the best of our knowledge that some of that information from the applicable

category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of

personal information:

– Category A: Identifiers

– Category B: Personal information categories listed in the California Customer Records

statute (Cal. Civ. Code § 1798.80(e))

– Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following

categories of third parties:

– Service Providers

– Our affiliates

– Our business partners

– Third party vendors to whom You or Your agents authorize Us to disclose Your personal

information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of

Age

We do not knowingly collect personal information from minors under the age of 16 through our

Service, although certain third party websites that we link to may do so. These third-party

websites have their own terms of use and privacy policies and we encourage parents and legal

guardians to monitor their children’s Internet usage and instruct their children to never provide

information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years

of age, unless We receive affirmative authorization (the “right to opt-in”) from either the

Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less

than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of

future sales at any time. To exercise the right to opt-out, You (or Your authorized representative)

may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with

personal information, please contact Us with sufficient detail to enable Us to delete that

information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal

information. If You are a resident of California, You have the following rights:

– The right to notice. You have the right to be notified which categories of Personal Data

are being collected and the purposes for which the Personal Data is being used.

– The right to request. Under CCPA, You have the right to request that We disclose

information to You about Our collection, use, sale, disclosure for business purposes and

share of personal information. Once We receive and confirm Your request, We will

disclose to You:

– The categories of personal information We collected about You

-The categories of sources for the personal information We collected about You

– Our business or commercial purpose for collecting or selling that personal

information

– The categories of third parties with whom We share that personal information

– The specific pieces of personal information We collected about You

– If we sold Your personal information or disclosed Your personal information for a

business purpose, We will disclose to You:

– The categories of personal information categories sold

– The categories of personal information categories disclosed

– The right to say no to the sale of Personal Data (opt-out). You have the right to direct

Us to not sell Your personal information. To submit an opt-out request please contact Us.

– The right to delete Personal Data. You have the right to request the deletion of Your

Personal Data, subject to certain exceptions. Once We receive and confirm Your request,

We will delete (and direct Our Service Providers to delete) Your personal information

from our records, unless an exception applies. We may deny Your deletion request if

retaining the information is necessary for Us or Our Service Providers to:

– Complete the transaction for which We collected the personal information,

provide a good or service that You requested, take actions reasonably anticipated

within the context of our ongoing business relationship with You, or otherwise

perform our contract with You.

– Detect security incidents, protect against malicious, deceptive, fraudulent, or

illegal activity, or prosecute those responsible for such activities.

– Debug products to identify and repair errors that impair existing intended

functionality.

– Exercise free speech, ensure the right of another consumer to exercise their free

speech rights, or exercise another right provided for by law.

– Comply with the California Electronic Communications Privacy Act (Cal. Penal

Code § 1546 et. seq.).

– Engage in public or peer-reviewed scientific, historical, or statistical research in

the public interest that adheres to all other applicable ethics and privacy laws,

when the information’s deletion may likely render impossible or seriously impair

the research’s achievement, if You previously provided informed consent.

– Enable solely internal uses that are reasonably aligned with consumer

expectations based on Your relationship with Us.

– Comply with a legal obligation.

– Make other internal and lawful uses of that information that are compatible with

the context in which You provided it.

– The right not to be discriminated against. You have the right not to be discriminated

against for exercising any of Your consumer’s rights, including by:

– Denying goods or services to You

– Charging different prices or rates for goods or services, including the use of

discounts or other benefits or imposing penalties

– Providing a different level or quality of goods or services to You

– Suggesting that You will receive a different price or rate for goods or services or a

different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident,

You can contact Us:

– By email: privacy@hdl-dh.com

Only You, or a person registered with the California Secretary of State that You authorize to act

on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

– Provide sufficient information that allows Us to reasonably verify You are the person

about whom We collected personal information or an authorized representative

– Describe Your request with sufficient detail that allows Us to properly understand,

evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

– Verify Your identity or authority to make the request

– And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving

Your verifiable request. The time period to provide the required information may be extended

once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable

request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is

readily usable and should allow You to transmit the information from one entity to another entity

without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and

confirm a verifiable consumer request from You, we will stop selling Your personal information.

To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may

use technology on the Service that sells personal information as defined by the CCPA law. If you

wish to opt out of the use of Your personal information for interest-based advertising purposes

and these potential sales as defined under CCPA law, you may do so by following the

instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every

browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by

following our instructions presented on the Service:

– The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

– The EDAA’s opt-out platform http://www.youronlinechoices.com/

– The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt

out. If you change browsers or delete the cookies saved by your browser, You will need to opt

out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps

You use in order to serve You ads that are targeted to Your interests:

– “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

– “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing

the preferences on Your mobile device.

“Do Not Track” Policy as Required by

California Online Privacy Protection Act

(CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are

visiting such websites, You can set Your preferences in Your web browser to inform websites

that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or

settings page of Your web browser.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect

personally identifiable information from anyone under the age of 13. If You are a parent or

guardian and You are aware that Your child has provided Us with Personal Data, please contact

Us. If We become aware that We have collected Personal Data from anyone under the age of 13

without verification of parental consent, We take steps to remove that information from Our

servers.

If We need to rely on consent as a legal basis for processing Your information and Your country

requires consent from a parent, We may require Your parent’s consent before We collect and use

that information.

Your California Privacy Rights (California’s

Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents

with an established business relationship with us can request information once a year about

sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are

a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users

(California Business and Professions Code

Section 22581)

California Business and Professions Code Section 22581 allows California residents under the

age of 18 who are registered users of online sites, services or applications to request and obtain

removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using

the contact information provided below, and include the email address associated with Your

account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or

information posted online and that the law may not permit or require removal in certain

circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a

third party link, You will be directed to that third party’s site. We strongly advise You to review

the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or

practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by

posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change

becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this

Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

– By email: privacy@hdl-dh.com

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