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 remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions:
You can learn more about the privacy practices and policies of Twitter by visiting their
Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page:
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook:
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