Effective Date: March 13, 2019
Hopp
PRIVACY POLICY
Hopp, LLC, a Massachusetts limited liability company, and its affiliates and subsidiaries (collectively, the “Company” or “we” or “us”) is committed to protecting privacy of your personal data. This Privacy Policy (the “Policy”) applies to those who visit the websites owned and operated by the Company, download any downloadable software, install any mobile applications, and/or use the Company’s products and services (collectively, the “Service”). For purposes of this Policy, personal data shall mean any information relating to an identified or identifiable natural person. This might be by reference to an identifier such as a name, ID number, location data or online identifier.
This Privacy Policy describes how the Company collects, uses, shares and secures the personal data of the users of the Service (the “User(s)” or “you” or “yours”, as applicable). It also describes the User’s choices regarding use, access and correction of the User’s personal data. The capitalized terms used in this Policy but not defined herein shall have the same meaning assigned to them in Company’s Terms and Conditions terms of service (the “Terms”).
1. HOW WE COLLECT AND USE INFORMATION
We collect the following types of information about you:
Information you provide us directly
We ask for and may collect certain information such as your name, phone number, credit card information, and e-mail address when you register for an account with us, or if you correspond with us. Credit card information is collected securely for use with the thrid party service Stripe. Stripe's private policy can be found here. We use this information to operate, maintain, and provide to you the features and functionality of the Service.
Information That We Collect From You through the Service
Analytics information: We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
Cookies information: When you visit the Service, we may send one or more cookies a small text file containing a string of alphanumeric characters to your computer that uniquely identifies your browser and let the Company help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your device after you close your browser. Persistent cookies may be used by your browser on subsequent use of the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.
Log file information: Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (IP) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Clear gifs/web beacons information: When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.
Device identifiers: When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more device identifiers, such as a universally unique identifier (UUID). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the devices operating system or other software, or data sent to the device by Company. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Location data: We may collect location data received from a GPS-enabled mobile device or other mechanism that you have set up in order to show your location to other Users or provide information to ensure delivery of products your geographic locality through the Service. In most cases you may prevent us from receiving such data by turning off the location-enabling functionality on your mobile device when prompted by the Service.
Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you e-mail communications containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
Use of certain service type information we collect about you: We use or may use cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems; (f) help you efficiently access your information after you sign in; (g) to provide advertising to your browser or device, and (h) automatically update the Company application on your mobile devices.
Legal Basis for Processing (EEA only): If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Service you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Policy, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further below in Section 7.
In addition to the foregoing, we may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Service; (b) enable you to access and use the Services; (c) process and complete transactions; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications; (f) monitor and analyze trends, usage, and activities in connection with the Service and for marketing or advertising purposes; (g) investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities; (h) personalize the Services; and (i) for other purposes for which we obtain your consent. You can opt-out of receiving marketing communications from us by contacting us at dev@mail.hsa.net or by following instructions on the unsubscribe link provided in such communications.
2. SHARING OF YOUR INFORMATION
Who you may choose to share your User Content with: Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings.
Business Transactions: We may buy or sell/divest/transfer the Company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your user information related to the Service may be among the items sold or otherwise transferred in these types of transactions.
Instances where we are required to share your information: Company will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service or to establish or exercise our legal rights or defend against legal claims; and/or (c) to exercise or protect the rights, property, or personal safety of Company, our Users or others.
3. HOW WE STORE, TRANSFER, AND PROTECT YOUR INFORMATION
Storage and Processing: Your information collected through the Service may be stored and processed in the United States or any other country in which the Company or its service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country
If you are accessing our Service from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information, you acknowledge and agree that your personal information may be transferred to the United States and other jurisdictions in which we operate.
Keeping your information safe: We care about the security of your information, and use commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Company, at all times. However, we cannot ensure or warrant the security of any information you transmit to Company or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Service, such as social networks. We are not responsible for the functionality or security measures of any third party.
Compromise of information: In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible
4. YOUR CHOICES ABOUT YOUR INFORMATION; ACCOUNT DELETION
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at dev@mail.hsa.net. To make a request to have personal information maintained by us returned to you or removed, please contact us at dev@mail.hsa.net. Requests to access, change, or remove your information will be handled within thirty (30) days
You control your account information and settings: You may update your account information and email-communication preferences at any time by logging into your account and changing your profile settings. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing, removing, or modifying your account information, you can contact us directly at dev@mail.hsa.net. Requests to access, change, or remove your information will be handled within thirty (30) days. To the extent that you have consented to receiving push notifications, alerts and other messages related to the Service, you may always opt out of receiving such push notifications/alerts by changing your notification settings on your mobile device.
Additional Rights for EEA and Certain Other Territories:
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:
If you would like to exercise such rights, please contact us at the contact details in Section 8 below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority
5. CHILDRENS PRIVACY
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13, and the Company’s Terms of Use prohibit the use of the Service by anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at dev@mail.hsa.net and we will use commercially reasonable efforts to delete that information.
6. CALIFORNIA PRIVACY RIGHTS AND DO NOT TRACK DISCLOSURES
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal data, such as name, e-mail, and mailing address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the name and address of all such third parties. To request the above information, please email us dev@mail.hsa.net. We will respond to such requests to information access within 30 days following receipt at the e-mail stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.
7. LINKS TO OTHER WEB SITES AND SERVICES
We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not have any control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.
8. HOW TO CONTACT US
If you have any questions about this Policy or the Service, please contact us at dev@mail.hsa.net.
9. CHANGES TO OUR PRIVACY POLICY
Company may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the Policy in a material manner we will let you know and update the last modified date at the bottom of this page. Your continued use of the Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Service.