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Huddly AS Privacy Policy

Last Updated: 25 May 2018

Huddly AS (“Huddly”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our collection, use and disclosure of your personal data when you use our services or otherwise interact with us as a customer or potential customer.

This Privacy Policy is applicable only to the collection, use and disclosure of personal data by Huddly; other parties we cooperate with and other websites that may be accessible through this website may have different privacy policies and practices.

Huddly is the “controller” concerning the processing of your personal information under this Privacy Policy. This means Huddly is responsible for determining the purposes and means for processing your personal data as described in this Privacy Policy and also for complying with the data protection legislation. Our contact details can be found at the bottom of this Privacy Policy.

1. Huddly's processing of your personal data

1.1 Placing an order on our website

When you place orders for products on our on our website ("Site"), or when someone makes a purchase for you, we will collect your personal information, including your name, email, phone number and address, for the purpose of product delivery. We may also collect other information such as your company name or job titles. Your purchase usually involves services provided by third parties, such as delivery services, and we will disclose your personal information such as your name and contact details, where necessary, to that third party.

When you order products on the Site, we will send you an e-mail to verify your orders when your order is completed. To complete the transaction, we will also disclose personal data such as your name and billing information to our third party payment processor.  

The legal basis for these processing activities includes your acceptance of the Terms under which you make an order on our website, our legitimate interests to operate our business, or otherwise that it is necessary to fulfill our legal obligations.

We do not process, record, or maintain your credit card or bank account information after the purchase is completed. We use Stripe as our third party payment service provider. For more information on how payments are handled, or to understand the data security and privacy afforded to such information, if you are a U.S. resident, please refer to Shopify’s privacy policy at https://www.shopify.com/legal/privacy, or if you are an EEA resident, please refer to Stripe’s privacy policy: https://stripe.com/de/privacy.

1.2 Setting up and managing your user account

You are welcome to set up a user account by providing your email address and password. You may also provide your other personal information such as your company name or job titles via our website. This is to improve our communications with you and to simplify your future purchasing experience. In order to facilitate the creation of accounts, we may disclose these data to our third party service providers.

After you have set up the account, you may track your orders and view your purchase history by logging into the account with your e-mail address and password, and the purpose is to identify you as a user in our system.

By processing your email address, we will send you administrative e-mail notifications, such as security or support and maintenance advisories. We also send you service-related communications, including notices of any updates to our Terms or Privacy Policy. This is to provide you with the services that you requested through our Site and to facilitate your use and understanding of our services.

The legal basis for these processing activities is your acceptance of the Terms under which you set up your user account. Another legal basis is our legitimate interests in operating our business and maintaining our customer relationship with you.

1.3 Customer support

If you contact us regarding support for the products you purchase, or if you provide us with feedback or otherwise contact us, we will process your name and contact information, such as your e-mail address, as well as any other information in your communication with us. We will respond to your inquiries or requests by using the contact information you provide us.

We disclose the personal data as described in this section with our third party service providers, to conduct quality assurance testing, provide technical support, and provide other services you have requested.

The legal basis for these processing activities is your acceptance of the Terms under which you use our services, and our legitimate interests in addressing any inquiries or feedback from our customers.

1.4 Maintenance and improvement of our Site, products and services

When you use this Site, we process your personal data including cookies, your IP addresses, Internet service provider (“ISP”), and other information collected via technology, such as log files. You may find further description below in Section 3 regarding our use of each technology and your choices.

To the extent that the information involves your personal data, the purpose is to provide the services you request and to maintain and improve the quality of your experience when you interact with our Site, products and services. This includes, for instance, to administer the Site, to analyze trends, and to better tailor our Site to our users’ needs.

When you participate in one of our surveys, we collect personal data concerning you. Which personal data we collect depend on what survey you participate in. For example, we may collect your name, contact information or other user account information. This is for the purpose of improving the quality of our products and services. It is voluntary to participate in these surveys.

The legal basis of these processing activities is your acceptance of the Terms on our Site, your consent to the processing activities, and/or our legitimate interests of improving our Site, products or services.

We may process anonymous data records provided by our third-party services providers, such as Google Analytics. Such anonymous information will not contain your personal data. You may find further description below in Section 3 regarding our use of each technology and your choices. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Site and improve Site navigation.

1.5 Marketing

We will periodically send you free newsletters, offers and other promotional materials related to our products and services. For this purpose, we will process your personal information such your name and contact information.  If you receive newsletters or promotional communications from us, you may at any time indicate a preference to stop receiving further communications from us, and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).

We will collect your account name if you interact with us via social media. This is for us to communicate with you and to promote our products and services.

The legal basis for these processing activities is your consent and our legitimate interests of promoting our business operation. In so far as your processing activities are based on consent, you will be able to withdrawal your consents to these processing activities by contacting us via the contact information provided below or otherwise instructed above. Please note that withdrawal of any consent does not affect the lawfulness of the processing that has taken place based on a consent given prior to the withdrawal.

2. Huddly's disclosure of personal data

We do not sell your personal data for marketing purposes to other companies. We may only share your personal data as follows:

  • With our third-party service providers, who perform operations or work on our behalf and on our instructions as data processors, for the purposes indicated in this Privacy Policy;
  • To establish, exercise or defend legal claims; or
  • With public authorities or governments when required by law, regulation, legal process or enforceable governmental request.

 

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

We may also share aggregated anonymized data with our business partners and group of companies for purposes such as for improving our service, for system administration, statistics, research and analysis.

3. Cookies and other information collected via technology

3.1 Cookies

Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. 

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site that you can customize. The purpose of these cookies is to provide you with more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

Targeted and advertising Cookies

These cookies track your browsing habits to enable us to show advertising that is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts, which we think, will be relevant to your interests while you are on third party websites.

You can disable cookies that remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

 

If you decide at any time that you no longer wish to accept Cookies from our Site for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Site or all functionality of the Site.

If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

3.2 Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Site to our users’ needs.

3.3 Pixel Tags

In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs).  Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, which are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format user can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users.  We may use this information to reduce or eliminate messages sent to a user. 

We do not tie the information gathered by Pixel Tags to our users’ personal information.

3.4 Google Analytics

We use Google Analytics to help analyze how users use the Site.  Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve our Site, products and services.

You can find out more about how Google Analytics operates here: https://www.google.com/analytics/terms/us.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

3.5 Do Not Track Signals

Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communicates. We currently do not take action in response to these signals, but we may revise our Privacy Policy.

4. Storage and deletion of your personal data

Your personal data will be retained as long as necessary to fulfill the legitimate purpose(s) for the processing and as long as required by law. We determine retention periods based on our agreement with you or on the legitimate needs of the business to deliver services to you.

5. Your rights

You have the right to request access, and in some circumstances rectification, restriction and deletion of your personal data held by us, and to receive a copy of your personal data in a structured, machine-readable format. Inquiries regarding the processing of personal data and access request and requests to exercise your rights shall be directed to the point of contact provided below.

You also have rights to object to some processing, including direct marketing communications, and the right to withdraw your consent where we process your data based on the consent you provided to us. Where we process your data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.

Subject to certain exceptions, you also have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

6. Transfer of personal data to other countries

We may store and process your data outside the EEA. The data, including personal information, that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Transfer of personal data to a third country outside of the EEA that does not provide adequate protection will only take place if appropriate safeguards are provided, e.g., by Binding Corporate Rules, entering into EU Standard Contractual Clauses or if the receiving party is certified under the EU-US Privacy Shield. If you have any questions relating to this, please contact us at the contact point provided below.

We may transfer aggregated anonymous data to third parties (domestic and/or foreign) for the purposes of i) improving or developing our Site, products or other services and ii) for the proper functioning of our Site, products or other services.

7. Privacy Policies of third parties

This Privacy Policy only addresses the collection, use and disclosure of personal data by Huddly. Other parties we cooperate with and other websites that may be accessible through this website have their own privacy policies and practices. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. Any links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites, and we are not in any way responsible for the content or the privacy practices employed by other third parties.

8. Changes and amendments to this policy

This Privacy Policy is subject to occasional revision. We invite you to review the latest version of this Privacy Policy.

When we update our Privacy Policy, we will update the “Last Updated” date at the top of this Privacy Policy.  We may also notify you of the changes by sending you an email. If you do not agree to any of the modified terms, you must discontinue the use of our service and request to delete your account by sending an email to us, where applicable.

9. Jurisdiction and applicable law

This Privacy Policy shall, save for mandatory local law, be governed by and construed in accordance with the laws of Norway and be subject to the non-exclusive jurisdiction of the courts of Norway.

10. How to contact us

If you have any questions, concerns or comments about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, or to exercise your rights, please contact us by sending an email to the following email address:

Huddly AS

Attn: Privacy

privacy@huddly.com

If you have unresolved concerns, you also have the right to complain to data protection authorities.