Privacy Policy

2. HOW DO WE PROCESS YOUR INFORMATION?

 

We process your personal information for a variety of reasons, including:

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• To process account creation and authentication and otherwise manage user accounts. 

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• To provide our Services, for example enabling you to track your activities and analyse your performance.

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• To respond to your enquiries, support requests and comments.

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• To send administrative information to you. We may process your information to send you details about our products and services, important company news, changes to our terms and policies, and other similar information.

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• To market and promote our Services and activities.  This includes marketing communications (if you opt in or have signed up to our app and have accepted our T&Cs) and push notifications (if you consent).​

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• To improve and protect our Services – analysis of the data we collect helps us to improve and develop our service, and quickly detect crashes and bugs so that we can fix then.

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• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

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3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law.

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If you are located in the EU or UK, this section applies to you:

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

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• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

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• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services. For example we can’t provide the Service unless we collect and use your location data.

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• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

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• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests, the vital interests of a third party, such as situations involving potential threats to the safety of any person, or our commercial interests in ensuring the sustainability of the Services.

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• Legitimate Interests. We may process your data where it is necessary for the purposes of our legitimate interest, and where it does not unduly impact your rights and freedoms. For example, to analyse our marketing activities or to conduct internal testing or reporting to improve our products and services.

 

Under European data protection laws, Hoolan is the 'data controller' of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. 

 

 

If you are located in Canada, this section applies to you:

 

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.  In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

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• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

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• For investigations and fraud detection and prevention.

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• For business transactions provided certain conditions are met.

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• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

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• For identifying injured, ill, or deceased persons and communicating with next of kin.

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• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.

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• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

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• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

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• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

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• If the collection is solely for journalistic, artistic, or literary purposes.

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• If the information is publicly available and is specified by the regulations.

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4. WHAT INFORMATION DO WE SHARE?

 

PERSONAL INFORMATION
 

We do not share or sell personally identifiable information (such as name or email address) directly with other companies for marketing purposes.  We do share personal information in specific situations as needed to run our business and provide the Services, as described below:

 

Service Providers 
We may share your data with third-party vendors (data processors), service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
 

• Cloud Computing Services

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• Communication & Collaboration Tools

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• Data Analytics Services

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• Data Storage Service Providers

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• Product Engineering & Design Tools

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• User Account Registration & Authentication Services

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• Website Hosting Service Providers

 

Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Statement.
 

Legal Requirements

We might also share personal information you have provided to us without your consent, within or outside your country of residence, if we believe:

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• It’s allowed in order to comply with the law or legal process, for example responding to court orders or warrants.

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• it's needed to detect, prevent or address fraud, security or technical issues.

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• To prevent any persons from death or bodily harm.

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• it's needed to otherwise protect our property, legal rights, or that of others.

 

AGGREGATE DATA
 

We may use and publicly post the anonymous aggregate data that we collect, as described in our ‘What information do we collect?’ section of this policy. We may also sell, licence or share this data with third parties for research, educational, business or other purposes.

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5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

We will only keep your personal information for as long as it is necessary for the purposes of providing the Services, unless a longer retention period is required or permitted by law. We delete all your personal information when you request for your account to be deleted and this process may take up to 30 days to fully complete.

 

 

6. WHERE IS YOUR DATA HELD?​

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Hoolan is based in the United Kingdom. If you are accessing our Service from other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United Kingdom as necessary for the purposes described in this Privacy Policy.

 

 

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

 

8. DO WE COLLECT INFORMATION FROM MINORS?

 

Whilst we do not specifically promote the Hoolan Services to minors, children aged 4 -18 yrs are able to download and use Hoolan as long as Hoolan's terms and this Privacy Policy have been reviewed and agreed with a parent or guardian. By using the Services, you represent that your parent or guardian consent to your use of the Services. 

 

 

9. WHAT ARE YOUR PRIVACY RIGHTS?

 

In some regions (like the EEA, UK, Canada and California), particular rights are available to you under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by emailing dpo@hoolan.app.

 

We will consider and act upon any request in accordance with applicable data protection laws.

 

Requesting to view, update or delete the data we collect from you:

If you would at any time like to review or change the information in your account or terminate your account, please email us at dpo@hoolan.app. Hoolan will process your request within 30 days.

 

Upon your request to terminate your account, we will delete your account and data from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Please note we cannot delete any data that you may have publicly shared on social media channels.

 

Withdrawing your consent:

If we are relying on your consent to process your personal information, such as your location data or your health data, you have the right to withdraw your consent at any time. You can do this by emailing dpo@hoolan.app.

Please note, however, that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting out of marketing and promotional communications: 

When you subscribe to our newsletter on our website, or when you download the Hoolan App and accept our terms and conditions, you will start receiving Hoolan's marketing and promotional communications. You can unsubscribe from these at any time by clicking on the unsubscribe link in the emails that we send, or by emailing us at dpo@hoolan.app. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. You may change your push notification settings at any time by accessing your Settings.  

 

Removing or rejecting Cookies and similar technologies: 
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Complaints:

If you are located in the EEA or UK and have a serious complaint about the way we are processing your personal information, that cannot be resolved together with us, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

 

10. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

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11. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we will notify you by prominently posting a notice of such changes and by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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12. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

 

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Lucy Jackson, by email at contact@hoolan.app.

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