HushLove

Privacy Policy

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Privacy Policy HUSHLOVE.COM Last Updated: 28 June 2021 This Privacy Policy (the “Policy”) describes how Karneolis Ltd. ("HushLove" or “we/us/our”) collects, uses, stores, shares and protects the personal information derived from the use made by the user (the “User”) of the platform accessible via the domain https://www.hushlove.com (the “Website”), and through the services that are offered to the user via the Website. If you have any doubts or concerns in connection with this Privacy Policy, we kindly invite you to contact us at dpo@karneolisltd.cy. This Privacy Policy governs the processing of personal data and its purpose is informing users about their rights under the General Data Protection Regulation (the “GDPR”), as well as your rights under the California Consumer Privacy Act (the “CCPS”) in the event that you are a California resident. We kindly advise you to read this Privacy Policy along with our Terms of Service carefully since they together constitute a binding agreement. We reserve the right to update this Privacy Policy from time to time and we will post the appropriate notice on the Website with indication of the effective date of such changes. Who is the data controller of your personal data? Karneolis Limited is the Data Controller of the personal information gathered through the Website, and is a company domiciled at 43 Petrou Loizou, 7520 Larnaca (Cyprus), with registration number HE 403308 . If you have any concerns related to the processing of your personal data, please contact us through this link or at dpo@karneolisltd.cy. For what purpose do we collect and process your personal data? We collect and process some personal data in the context of the services offered through the Website for the following purposes: <ol> <li> To manage user registration and to be able to manage the contractual relationship with you. Indeed, we process the following categories of data for the purposes specified in the chart below: Categories of personal dataPurpose of the processing Basic information required for registration and for providing the services (access data, registration data, email, gender, zip code, age and password)User validation, creation of a user account and rendering of the services Basic contact information (email address)User contact for performing the contractual relationship, which includes communications regarding eligibility and / or promotions for related products and / or services Additional contact information(additional identification, for example, national identification and/or passport or driving license)Verification of the user’s identity and age and fraud prevention Information on transactionsPayment processing and fulfillment of the contractual relationship Payments information (partial credit card data)User account registration, transaction processing and fraud prevention Information regarding your communications with other users and the use you make of our Website, to the extent permitted by and in accordance with the legislation in forceEnsuring a safe and trustful environment, preventing fraud, abuse and any other misuse of the Website and/or the services, resolving potential disputes with other users and complying with any potential applicable legal obligations Usage data, in particular, technical and device-related information and data transmission information (IP address, functional web and tracking data, website login and usage data)Customizing offers, bug fixing, fraud prevention, improving the service, user interface improvement and, if applicable, marketing Geolocation data (zip code)In order to be able to show you users that are close to you and recommend you users that are close to your location Voice and data provided during calls made to our customer service support team To improve quality and compliance with procedures by the operators attending our user calls Additionally, please note that if you want to complete your profile on the Website, there is some additional information you can voluntarily provide (such as pictures of you, your preferences, personal attributes, sexual interests, race, and any other personal information that you may want to include). Therefore, by providing this information and by clicking on the “I accept” (or equivalent) button incorporated in the registration form, you declare that the information and data you have provided are accurate and truthful, and you explicitly consent the processing of special categories of personal data that belong to you. </li> <li> To respond to queries that may be submitted by users in connection with the Website and/or services </li> <li> To respond to law enforcement requests and as required by applicable law, court order, or governmental regulation </li> <li> For any other business purposes stated when collecting your personal data or as otherwise set forth in applicable data privacy laws </li> <li> To prevent fraud and to improve the service </li> </ol> Furthermore, and with your consent in each case, we will use your data for the following purposes: <ul> <li>To better know your preference through evaluation of your profile</li> <li>To send you advertising and/or commercial information, including by electronic means, regarding us and/or our business partners</li> <li>To process your participation in specific promotions</li> </ul> Last but not least, please note that we will process user data when we have to fulfill a legal obligation under tax and anti-money laundering laws. What are cookies, server logs and clickstream data? When you interact with our Website or services, we automatically collect information such as: <ul> <li>your computer Internet Protocol (IP) address (a unique string of numbers that is assigned to your computer by your Internet Service Provider) each time you access the site;</li> <li>logs (such as, access time and hardware);</li> <li>usage information;</li> <li>cookie information (for more information regarding the use of cookies please see our Cookies Policy here);</li> <li>page view statistics;</li> <li>browsing history. and</li> <li>information pertaining to your computer configuration, including the Web browser software you use, the resolution settings of your monitor, and the website from which you were referred to us, if any.</li> </ul> “Cookies” are identifiers transferred to the user browser or device that allow to recognize the user browser or device and tell how and when pages and features are visited and by how many people. Please note that you may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, however please note that this may prevent you from taking advantage of some of our Website features. Please read carefully our Cookies Policy here for more information on cookies. Please note that we use the above information anonymously to help us improve our services and to create a better user experience. Therefore, to the extent that the information processed is related solely to codes or unique identifiers of devices or browsers used by the user, and is not related to data that identify the user directly, the rights indicated on section “What are your rights as data subject?” below will not be applicable unless users provide additional information that allows identification (such as Cookie ID). What is the legitimate interest for processing the data? The legal basis for processing the data is the performance of the Terms and Conditions of Use of the service, where the data processing is strictly necessary to be able to use the Website and, therefore, to allow users to benefit from the services made available to them. With respect to additional purposes, these are legitimized by the consent given by the user, which may be revoked at any time without affecting the provision of the services. Indeed, please note that users may withdraw their consent at any time contacting us at dpo@karneolisltd.cy. Please read below to obtain a more detailed explanation of the what is the legitimate interest pursuant to which we may process your personal data: <ol> <li>Contractual or pre-contractual relationship management: we use information about you to provide the services to you, including to process transactions, manage your registration as a user, allow your access to the private or members area, authenticate you when you log in, provide customer support, operate and maintain the Site, provide you with the services you have requested and attend to your requests for information, as well as to facilitate the exercise of your rights. We also analyze your profile, Website activity and preferences to recommend connections and to recommend your profile to others.</li> <li>Based on the existence of a legitimate interest of the Website: We use information about you to customize your experience, keep you informed about the services of the Website and included business partners, send you news and information about other activities that we carry out related to the services of the Website that may be of your interest, and to carry out periodic reviews of our services and satisfaction surveys in order to evaluate and improve the quality of the service we provide. We may also process your personal data in order to carry out internal reviews and, if necessary, contact you in the event that a possible fraud, misbehavior, or identity theft is detected or there are well-founded suspicions. However, if you do not want your data to be processed for these purposes, you may object at any time by contacting us at dpo@karneolisltd.cy.</li> <li>On the basis of your explicit, free and unequivocal consent that you grant at the time of collecting your data: to process the special categories of personal data that belong to you, in order to provide you the services. By clicking on the “I accept” button incorporated in the registration form, you expressly consent the processing of your personal data for these purposes.</li> </ol> Who will your data be sent to? We may communicate the personal data of users when so required by law, for defending our legitimate rights and interests, or when necessary in accordance with the services rendered to the users. Additionally, please note that the personal data may also be accessed by third party service providers and computer and technical support services for the purposes indicated below: <ul> <li> Service providers and affiliates: <ol> <li>Credit card processing companies to process payments for goods and services and to verify that user credit card account is valid and active. </li> <li>e-mail service providers to send out e-mails on our behalf. </li> <li>sales partners to sell our services. </li> <li>data partners to process data on our behalf (e.g., removing duplicate information, analyzing data, etc.). and </li> <li>marketing partners who may market our products for us and provide analysis of such marketing efforts. </li> These affiliates and service providers will have access to user information as needed to perform their functions on our behalf, but we do not permit them to use your information for other purposes. In addition, apart from the circumstances described above, please note that we will not share credit card information with any third parties without prior informed consent from you. </ol> </li> <li>Third-party marketing companies: to send users selected marketing, other than “Sensitive Information” (defined as a credit card number, financial account number, Social Security number, driver’s license number, or credit score). These businesses and third parties may include: <ol> <li>providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression, and validation vendors. </li> <li>e-mail marketers. </li> <li>telemarketers (where permitted by applicable law). </li> <li>text-message-based marketers (where permitted by applicable law). </li> <li>direct marketers. and </li> <li>online advertising networks. </li> Please note that we are not responsible for the information practices of these third parties, which are governed by their respective privacy policies. </ol> </li> <li>Other Third-parties: </li> Business partners: we establish commercial relationships with other companies, as part of our services to users, in order to create a broader community able to enrich your experience with HushLove products and services. These third parties offer the users a broader catalogue of relevant services, products and or eligibility to promotional offers. These companies are exclusively responsible of the data processing that they carry out in relation with your information when navigating their sites. Additionally, we encourage users to proactively review the corresponding Privacy Policies from these companies: <ul> <li>to any acquiring entity in connection with any sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of Karneolis Limited.</li> <li>to respond to a subpoena, court order, or legal process served on us or otherwise to comply with the law;</li> <li>when we believe that disclosure is necessary to protect the rights of Karneolis Limited, its parents, subsidiaries, affiliates, joint ventures, or third-party service providers, and each of their respective members, officers, directors, employees, agents, shareholders, co-branders, content licensors, suppliers, contractors, attorneys, and other partners, such as to enforce or apply this Privacy Policy, the Terms of Use, and other applicable HushLove agreements and policies. and </li> <li>to protect the rights, property, or safety of users or others (e.g., by exchanging information with other companies and organizations for fraud protection purposes, by providing information to law enforcement where we believe the Site is being or has been used to commit unlawful acts).</li> </ul> </ul> In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as required by the applicable regulations. Certain systems, data and services are hosted on Amazon Web Services (“AWS”) and in the Google CloudCould Platform. Your data may be transferred internationally to that company’s servers in the United States. HushLove will adopt the appropriate mechanisms in order to ensure that the transfer of personal data is conducted under a framework equivalent to that provided in the European data protection regulations. More information on our main Service Providers is available at the following links: <ul> <li>Google Analytics: https://policies.google.com/privacy/update</li> <li>Zendesk: https://www.zendesk.com/company/customers-partners/privacy-policy</li> </ul> How long will we keep your personal data? We will keep the personal data of users while they remain registered users, and the personal data will be retained after the termination of the contractual relationship, duly blocked, for the necessary time to answer for any liabilities that may be derived from the contractual relationship between us and the users. Please note that, in some case, we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. In particular, the personal data required for responding to queries made and for delivering electronic marketing communications will be processed for as long as the user does not revoke the consent given and, once the consent has been withdrawn, for the time necessary to answer for any liabilities that may have arisen. In any event, when the personal data is not required for the purpose for which it was obtained and until it is not finally cancelled, it will be retained in a blocked form. Last but not least, as indicated in our Terms and Conditions, we do not knowingly collect or solicit personal data from children underaged/minors. If you are an underaged child/minor, please do not attempt to register for or otherwise use the services or send us any personal data. Furthermore, please note that if we learn that we have collected personal data from an underaged child/minor, we will delete that information as quickly as possible. If you believe that an underaged child may have provided us personal data, please contact us at dpo@karneolisltd.cy. Do you want to update your personal data? Users may update their information through the settings available in their account or by sending an email to dpo@karneolisltd.cy. dditionally, we kindly remind you that, in order for us to adequately provide the services, users must keep their information up to date and, subsequently, users agree to regularly check the information provided to ensure it is accurate at all times. Last but not least, you can ask us to stop sending you marketing communication at any time. To this end, you can change the communication preferences in the notifications section of your account, or you can contact us at dpo@karneolisltd.cy. However, please note that this will not prevent us from sending other communications related to the services, since these are necessary to comply with the contractual relationship between you and us. What are your rights as data subject? RightContent AccessYou can obtain confirmation as to whether your personal data is being processed and check what specific personal data is being processed RectificationYou can modify your personal data when they are inaccurate, and complete those that are incomplete ErasureYou can request the erasure of your personal data when, among other reasons, they are no longer necessary for the purposes for which they were gathered OppositionYou can ask for your personal data not to be processed. We will stop processing the data, except where legitimate purposes prevail, or to exercise or defend against possible claims Restriction of processing You may request the restriction for processing of your data in the following cases: <ul> <li>While a challenge to the accuracy of your data is being verified</li> <li>When the processing is unlawful, you object to the deletion of you data and you request the limitation of their use</li> <li>When your data is not processed but is needed for exercising or defending claims</li> <li>When you have opposed to the processing of your data to carry out a mission of public interest or to satisfy a legitimate interest, while it is checked whether the legitimate grounds for processing prevail over your interests</li> </ul> PortabilityYou may receive the personal data submitted to us and obtained during your contractual relationship with us in electronic form, and transmit that data to another entity In the event that you believe that your personal data have not been processed in a lawful manner, please note that you can file a complaint with the competent supervisory authority via the following website: http://www.dataprotection.gov.cy To exercise your rights, please send an email to dpo@karneolisltd.cy stating the right you wish to exercise. Last but not least, we kindly inform you that the exercise of all these rights is free. *If you are a California resident If you are a California resident and are subject to the CCPA, please note that you may exercise the following rights: <ol> <li>The right to know and request from us what personal information has been collected during the past 12 months and for what purposes it will be used. Specifically, information regarding the categories of data processed, the sources from which the data was obtained, the purposes of the processing and/or whether such information will be sold to third parties, and the categories of third parties to whom such personal information will be disclosed to. For this purpose, you may consult the previous sections "What personal data do we collect", "What do we do with your personal data?" and "Who is your data shared with”.</li> <li>The right to delete your personal information where possible.</li> <li>"Do Not Sell My Information" meaning the right to object to the sale of your personal information to third parties as mentioned herein.</li> </ol> We also inform you that by exercising any of the above rights, you will not be discriminated against or subject to different treatment. You may exercise your rights under the CCPA at any time and at no cost by: <ol> <li>Contacting us through this form in which you specify the right you want to exercise and identify yourself. Please identify in your request in the “Problem” field by writing "Exercise of CCPA rights". State the right/s you wish to exercise, and how you will prove you are a California resident.</li> <li>When you receive any communication from us, by clicking the "opt-out" button in the notice, you can unsubscribe from all the previously accepted commercial notices.</li> </ol> Is my personal data confidential and secure? Our Website employs industry standard security measures to ensure the confidentiality and security of all data. Your personal information is protected by physical, electronic, and procedural safeguards in compliance with applicable laws and regulations. Links The Website contains links to other websites on the Internet that are owned and operated by third parties. In some instances, these websites may be co-branded and the third parties may be entitled to use HushLove name and logo on their websites. Please be aware that we are not responsible for the data practices of such websites, which shall be subject to those websites’ privacy policies. Please read the privacy policy of each and every website that you link to from the Site. This Privacy Policy applies solely to information collected by the Site. Do you want to contact us? If you have any doubts, questions or concerns regarding our Privacy Policy, please feel free to send us an email to dpo@karneolisltd.cy.