PRIVACY POLICY
Table of Contents:Introduction
Information We Collect
How We Use Information
Data Retention
Information Sharing and Disclosure
International Transfers and Privacy Shield
Managing Your Personal Information
Children's Privacy
Links and Pointers to Other Sites
Data Storage and Security
Changes to This Policy
Contact Us
Effective November 22, 2018
INTRODUCTION
This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of personal information when you use our Services - website and mobile applications. It also provides information on what rights you may have regarding your personal data and how you may exercise these rights. Our objective is that you should feel confident that your personal integrity is respected and that your personal data is processed correctly. All personal data processing within our Services is undertaken in accordance with applicable data protection legislation. If you are accessing our Services from a member state of the European Union (EU) or contracting party to the European Economic Area (EEA) Agreement your personal data will be collected and processed in compliance with the EU’s General Data Protection Regulation (2016/679). We will only collect and process personal data about you where we have lawful bases. Your data will not be processed for other purposes or beyond the scope of this Privacy Policy, except where expressly permitted or required by applicable law and will be protected against unauthorized access. We will not use or share your information with anyone except as described in this Privacy Policy. The Data Controller for your personal information collected through our Services is HOBBLIFE INC., corporation registered in Delaware, USA. By using the Services or submitting personal information through the Services, you expressly consent to the collection, use, and disclosure of your personal information according to this Privacy Policy.INFORMATION WE COLLECT
Generally the information collected when you interact with our Services falls into two categories:(1) Personal information you provide us directly, such as when you register an account, create user content or communicate with us; and
(2) Non-personally identifiable information collected automatically through technology, which includes tracking information collected by us or our service providers.
You could visit our website while remaining anonymous without registering an account. However, when you first visit our website we will ask for your consent to place cookies on your device and to track your website usage behaviour. Please be aware, this way we may collect automatically non-personally identifiable information, such as your IP address or device type. Yet if you like to create any User content or use certain features, we would require you to have a registered account.
We collect the following information that you provide us directly:
Basic Account Information
To register an account you need to provide data including your first and last name, valid e-mail address and password. Please consider that on HOBBLIFE your first and last name will be visible to everyone on the Services and outside the Services through search engines. In addition, you can create a HOBBLIFE account by logging in with your Google or Facebook account. By using this feature you are asking that service to send us certain information from your account with the service, and you authorize us to collect, store and use that information in accordance with this Privacy Policy so we would automatically create you an account. At your discretion you can disable the link between your HOBBLIFE account and your Google or Facebook account at any time though the “Settings” section of our Services. Please note that if your Google or Facebook account terminates, then functions enabled through the link between your HOBBLIFE account and that other account will terminate as well.
User Profile
Providing a Profile picture or “About me” description is optional. Please consider that on HOBBLIFE your Profile picture and “About me” description will be visible to everyone on the Services and outside the Services through search engines. It’s your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available. Your Profile contains a list of hobby categories you are currently joined to. That information is not visible for the other users. The Profile includes information about user's activity – e.g. displaying all published posts, blogs, questions, answers, marketplace ads, their exact number and also the total number of accrued points. Please note that the current number of available redeemable points and the list of coupons for which points were redeemed are available only to that respective user.
User Content
User Content includes your posts, blogs, questions, answers, photos, videos, comments, likes, votes, your listed ads on the Marketplace and all other information you provide or upload on our Services. Please consider that on HOBBLIFE your User Content will be visible to everyone on the Services and outside the Services through search engines. By posting any information or content via the Services, you should think carefully about what you are making public. Please note that certain information, such as your name and Profile may be publicly displayed on the Services along with your User Content. Please consider that your use of our Services is subject to HOBBLIFE’s Terms of Services as well.
Messaging
Our users may communicate with each other by nonpublic direct messages through the Personal Messaging System we provide. If you use that feature, we will store and process your communications and information related to them, such as when sent or received. Please remember that even though it is personal messages, the recipient User may also store, copy and reshare the contents of your private communications.
Communication With Us
We collect the personal data you voluntarily disclose when you contact us via email or by posting publicly in our Feedback and Support Section. You may also choose to provide information when you fill out a form, participate in activities or promotions or otherwise communicate with us. Unless indicated otherwise in this Privacy Policy, your data will not be used without your consent other than to handle your request/enquiry, e.g., to provide you with the service information you asked for, and not be used for any other purpose, unless expressly permitted or required by applicable law.
Metadata
Metadata is usually technical data that is associated with your use of the Services or the Content you post. For example, metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted. You can add or may have Metadata added to your User content including hashtag, e.g. to mark keywords when create blog post, post or question, or uploading picture or video. This makes your User Content more searchable by others and more interactive.
We automatically collect the following information:
We and our third party service providers, including analytics and embedded content providers, may automatically collect certain information from you whenever you access or interact with the Services. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you.
Device Information
Like other online companies, we receive technical information about your computer or other device that you use when you access our Services. The information we collect includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Services and the device type. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Services, and our servers identify your device by its Device Identifier. We also collect your browser type and version, version of the mobile application installed, internet service provider, browser language, time zone setting, geolocation information, referring/exit pages, date/time stamp, operating system. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Services.
Usage Information
We may log certain information about your use of our Services and website traffic. The information we collect includes pages of our Services that you visit, the time and date of your visit, the time spent on those pages, your search terms and search results and other clickstream data. We may also store software crash reports and information about performance of our services for a specific user, as well as information about messages and advertisements that have been displayed (e.g. the fact that it has been displayed, its size, the website on which it was displayed, the time it was displayed). In addition, we may use third party services, such as Google Analytics, Mixpanel and Application Insights, that collect, monitor and analyze this type of information in order to increase our Service’s functionality.
Technology used to automatically collect information include the following:
Cookies
Like many websites, we and our service providers collect information through cookies. A cookie is a tiny text file containing information, generated by a web server when you visit a website or application and is placed by that web server on the browser or hard drive of your computer or mobile device. Some cookies may include an anonymous unique identifier. As further described in our Cookie Policy, we use cookies to provide and improve our Services, to recognize your device and analyze how people use our Services or to save your log-in information for future sessions. You can block and delete cookies by adjusting your browser settings. Please note that this may impact website functionality and user experience. For further information on cookies and how they are used for the Service, please visit our Cookie Policy.
Analytics Tools
We may use analytic tools and third party analytics services such as “Google Analytics”, “Mixpanel” and “Microsoft Application Insights” to collect information about use of our Services. They use Cookies to gather usage data and help us learn how people use our Services. Such as the pages they visit and for how long, actions they take or the features they use and also the errors that may occur when people use our sites. We use this information to generate general statistics as a tool to improve our Services. These third party analytics service providers have access to your information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose. They would act as data processors of your information since we control what data to be send to these service providers. “Google Analytics”, “Mixpanel” and “Microsoft Application Insights” have their own Privacy Policies addressing how they use such information.
GOOGLE ANALYTICS
Google Analytics service is provided by Google Inc. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service, available at: http://www.google.com/analytics/terms/us.html
and the Google Privacy Policy, available at:
http://www.google.com/policies/privacy/ You may learn more about how Google collects and processes data specifically in connection with Google Analytics at:
http://www.google.com/policies/privacy/partners/
You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at:
https://tools.google.com/dlpage/gaoptout/
MIXPANEL
Mixpanel is analytics service provided by Mixpanel Inc.
Mixpanel’s use of information collected through Mixpanel is set forth in the “Privacy Policy” section of its Terms of Use available at:
https://mixpanel.com/terms/
You may opt-out of Mixpanel’s automatic retention of data at: https://mixpanel.com/optout/
MICROSOFT APPLICATION INSIGHTS
Microsoft Application Insights is analytics service provided by Microsoft, Inc.
Information on data collection, retention and storage in Application Insights is available at: https://docs.microsoft.com/en-us/azure/application-insights/app-insights-data-retention-privacy
For more information on the privacy practices of Microsoft, please visit the Microsoft Privacy & Terms web page: https://privacy.microsoft.com/en-US/
Embedded Scripts
On our Services we allow video content to be embedded by YouTube and Vimeo. The embedded content functions like an inbound link and requires a connection to be established to YouTube and Vimeo servers. Third party embedded content may in some cases set cookies as well as collect personal data and cause it to be stored. We do not control the collection, storage and use of any of your information by YouTube or Vimeo and do not have access to any information collected. You should read YouTube’s and Vimeo’s Privacy Policy carefully before you use any of their features.
HOW WE USE INFORMATION
We use your personal information according to the terms of the Privacy Policy in effect at the time of our use. We will only process your personal information, including sharing it with third parties, where we have lawful basis and at least one of the following applies: (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party (including your registration or agreements with us), (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial or regulatory interests, provided your interests and fundamental rights do not override those interests. Our lawful basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the specific context in which we collect or use it. HOBBLIFE may process your personal data for the following purposes. One or more purposes may apply simultaneously.Provide Our Services
We collect, store, use and process information about you to provide you the services you request, to operate and maintain the Services and to carry out our obligations arising from your registration and any other agreement entered into between you and us, including to maintain your account and help you efficiently access your information after you sign in.
Analytics
To gather metrics to better understand how users access and use our Services. For example, we may administer and track user activities on our Services to test, monitor and analyse the performance or the appropriateness of our Services and determine how to improve our content and features. We also use that information to optimize our Services and to diagnose and fix errors or other technology problems you may have with our Services.
Research And Development
We may use Personal Information to create non identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products, to test changes in our Services or develop new features and products.
Perform Surveys
From time to time, Hobblife may perform research via surveys. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve our users by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities.
Marketing and Promotion
For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services. Also to administer contests, sweepstakes and promotions.
Safety And Security
We use information about you and your use of the Services to detect, prevent, investigate and respond to suspicious activities that may violate our terms and policies or be illegal or that may threaten the security, integrity or availability of our or third party’s products, systems and services. In particular: to verify accounts and activity and prevent unauthorized access to or use of our Services, to block suspected spammers, to investigate suspected fraud or abuse or situations involving potential threats to the safety of any person and any other wrongful and/or harmful behavior.
Comply with Law
To comply with legal and contractual obligations.
Communicate with you
We may use your information (including your designated email address) to contact you when we have to respond to your inquiries, including to answer support questions and investigate, respond to and resolve disputes and complaints. We should also provide notices to you regarding your use of our Services, such as sending you the requested coupons or notifying you for changes to our terms and policies or if your actions violate your agreement with us. Unless you have notified us otherwise, we may occasionally send you emails to keep you up to date about ongoing activities, promotional games and lotteries, unread notifications or any new features available on our Services.
With Your Consent
We use information about you where you have given us consent to do so for a specific purpose not listed above.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details provided below in this Privacy Policy.
DATA RETENTION
We will retain your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. For example, if you register for an account on the Services, we retain your personal data for as long as you have an account with us and then for only as long as required for us to comply with applicable laws, discharge our contractual obligations to you, or defend our legal interests in connection with any claim or defence we could face before any formal dispute resolution body; to meet regulatory requirements, maintain security, prevent fraud and abuse or other harm, enforce our agreements, terms and policies, or fulfill your request to “unsubscribe” from further messages from us. We take reasonable measures to ensure that personal data is deleted or anonymized as soon as possible once the purposes for which personal data was collected have been fulfilled. We will retain depersonalized information after your account has been closed. Please note that your User Content and information you have shared with others will remain visible after you closed your account. The User Content associated with closed accounts will show an unknown user as the source. Closure of your account would not affect the licenses granted for the use and storage of the posted User Content as described in our Terms of Service.INFORMATION SHARING AND DISCLOSURE
We do not share or disclose your private personal information except in the limited circumstances described here:Publicly available information
Any information or content that you voluntarily disclose for posting to the Services, such as User Profile and User Content, becomes available to the public. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if other Users have copied or saved that information. Any User Content that you make public is searchable by other Users and subject to use under our HOBBLIFE API. Please be aware that by posting User Content it would be available on the Services for indefinite period and regardless of your account existence.
Messages to other users
If you use our Personal Messaging System to communicate with other users we will store and share your direct messages with the user you communicate with.
Aggregated and Non-Identifying Information
We may share publicly or otherwise disclose the results of aggregated data about our users to third parties. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
Third Party Service Providers
We may have third party service providers that perform functions on our behalf, such as hosting, analytics, fraud protection, etc. These entities have access to your personal information only as needed to perform their functions and they are obligated to maintain the confidentiality and security of that personal information. They are obligated not to use, sell, distribute or alter this information in any way other than to provide the requested services.
Third Parties With Whom We Do Business
We may share your personal information with certain third parties with whom we do business and that participate in our Partnership program, so that they can provide you with discount coupons, special offers, promotional materials, and similar materials that may be of interest to you. Although our treatment of your personal information is governed by this Privacy Policy, the third party’s treatment of your personal information will be governed by its privacy policy. You may withdraw your consent in accordance with their policy. Although, we may provide your personal information to our business partners, in no event will we sell or rent your personal information as part of a customer list or similar transaction without your express permission.
Sweepstakes, Contests, and Promotional offers
We may offer sweepstakes, contests, and other promotional offers (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
Affiliates
We may share your information with other companies under common ownership or control with HOBBLIFE INC., primarily for business and operational purposes. These companies use your information as described in this Privacy Policy.
Business Transactions
We may change our ownership or corporate organization while providing the Services. We may also sell certain assets associated with the Services. As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we do not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this Privacy Policy.
Legal Disclosures
We may need to share your information to a third party when we believe it’s required by law or to help protect the rights and safety of HOBBLIFE, our users or others, if:
(a) we believe that disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request;
(b) we believe it is necessary to protect the security or integrity of our Services (such as by sharing with companies facing similar threats);
(c) to enforce our agreements, terms and policies, or to investigate and defend ourselves against any claims or allegations asserted against us;
(d) to protect our Services, our users or the public from harm or illegal, fraudulent or unethical activities;
(e) to protect our or any third party’s legal rights and property;
(f) to protect the safety of the public or any person.
To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Consent
We may share your information in other ways if you have asked us to do so or have given consent.
However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s request to disclose your information. Other than as indicated above, we will not provide your personal data to any third party without your prior consent, unless we are compelled by law to do so.
INTERNATIONAL TRANSFERS and PRIVACY SHIELD
In order to provide you with our Services, we operate globally and may have entities and service providers in the United States and throughout the world. Your information collected by us and our Service Providers may be transferred, processed and stored in the United States or any other country they operate or maintain facilities and where the data protection laws may not provide equivalent levels of data protection as your country of residence. By allowing us to collect information about you, you consent to such transfer and processing of your data. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through: putting in place appropriate written data processing terms and/or data transfer agreements, using contractual clauses as approved by the European Commission or following an adequacy decision by the EU Commission. When we transfer personal data outside of the EU or EEA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data or EU-US and Swiss-US Privacy Shield principles. Our Service Providers (Microsoft, Google, Mixpanel, Vimeo) complies with the EU-US and Swiss-US Privacy Shield principles regarding the collection, use, sharing, and retention of personal data from the European Union and Switzerland.MANAGING YOUR PERSONAL INFORMATION
You have certain choices available to you when it comes to your information. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account or by contact us as provided in the Contact Us section below to make a request.Access and Modify Your Data
If you have registered an account, we provide you with tools and account settings to access, correct, delete, or modify the personal data you provided to us and associated with your account. If you choose to provide us with personal information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you. You may also access, correct, modify or delete your User Content, depending on the editing tools associated with that content. For example, any deleted content will be removed from third party sites from which it has been shared via the standard sharing features; however we have no control over deletions or changes to Your Content if it has been shared manually by others. When you make edits to Your Content, other users may be able to see the history of those edits in your profile activity and on content edit logs.
Delete Data Instructions
You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you). You can file your request via the "Contact Us" section. We will use commercially reasonable efforts to honor your requests for deletion. However, this doesn’t apply to information that you have made public by posting on our Services or have made available to third parties yourself. Please note, however, that we may need to retain certain information for record keeping purposes, to complete requested services or to comply with our legal obligations.
Restrict, Object or Withdraw Consent
You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held). If you have reason to believe that your personal data is inaccurate, unlawful, or no longer required, you can request that we restrict the processing and we will investigate the possibilities without delay. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object to that use. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent. Please keep in mind that certain services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information.
Portability
You can ask us for a copy of your personal data which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller.
Opt-out of receiving emails
When you join our Services by signing up for an account we may occasionally send you emails to keep you up to date about ongoing activities, promotional games and lotteries, unread notifications or any new features available on our Services. If you no longer wish to receive such communications from us, please follow the unsubscribe instructions or contact us using the contact details provided below. Please note that we may still send you certain communications relating to your account or use of the Services.
Complaints
We are committed to resolving valid complaints about your privacy and our collection or use of your personal data. While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have a right to lodge a complaint with the relevant supervisory authority.