Hidy (collectively, the “Company”, “we”, “our” or “us”) respects the privacy of the users of its App (“User” or “you”) and is committed to protect the User’s Personal Information (as defined below) that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at: [insert a link to Terms of Use] (“Terms of Use”), into which this Privacy Policy is incorporated by reference.
1. Your Consent (PLEASE READ CAREFULLY!)
BY ENTERING, CONNECTING TO, ACCESSING OR USING AND/OR BY INSTALLING THE APP ON YOUR DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APP, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW).
PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT INSTALL, ACCESS AND/OR USE THE APP AND/OR ENTER, AND YOU ARE REQUESTED TO PROMPTLY UNINSTALL THE APP FROM YOUR DEVICE.
IN APPLICABLE JURISDICTIONS: FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO THE COMPANY.
2. Which information we may process
2.1 The first type of information is non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from whom we have collected the Non-Personal Information.
· Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the App and/or installs the App. Non-Personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, type of operating system, type of the User’s device and its version, Wi-Fi connectivity, User’s ‘click-stream’ on the App, keyboards, features, the hardware specifications of such device (including screen resolution), time spent on various screens of the App, User demographics, the activity of the User on the App and additional information of a similar nature (collectively, “Technical and Behavioral Information”).
· Key: We also process the Key (as defined in the Terms of Use) and may offer storage services with respect to portions of the Key. Please note that the Key cannot, by itself, identify the User. Please note that we do not collect your phone number or any other information which may identify you directly.
· Tokens: We may also collect tokenized information (e.g., FCM or APN) issued by the operating system of the device on which you operate the App, for example in order to send you push-notifications. Such tokenized information is intentionally designed not to identify the User. Your consent may be required in order to provide us with such information.
· Username: please note that we collect the username that you have assigned to your Account. We recommend that you choose a username which does not include identifying details, and as such, it would constitute Non-Personal Information. However, please note that, to the extent that that username chosen by you includes identifying details (e.g., your name), it will constitute “Personal information”, as further detailed below. All usernames are listed in our internal directory, which is encrypted and stored in decentralized manner, to ensure its security and confidentiality.
2.2 The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
· Registration: you are not required to provide us with any identifying information (including telephone number) in order to register to use the App. However, as part of the registration process we may ask you to choose a username for your Account. You may also create your own avatar by uploading an image which is processed by us to create such Avatar (we will collect and process such image solely in order to create the Avatar and delete it thereafter). To the extent that your Account name or avatar includes any identifying details, then such will constitute “Personal Information”. To help other Users search for you in the App’s directory and communicate with you, your Account name and avatar are publicly available to other Users by default. The Company don’t know your real name, gender, age or any other similar information. Please note that this data is not processed on our server, but is stored on other Users’ devices in a parsed, encrypted and un-interoperable or identifiable manner.
· User Content: to the extent that the User Content, such as communications and photos, that you upload to the App include Personal Information, we may process such data for the sole purpose of providing the Services, and delivering such User Content to other Users, per your instructions. Please note that this data is processed but not stored on our servers and may be stored on other Users’ devices in a parsed, encrypted and un-interoperable or identifiable manner. If User Content that you upload to the App includes Personal Information of third parties, you represent and warrant that you have obtained all necessary consents from such third parties for the uploading of their Personal Information to the App, all to the extent require under applicable law.
· Communications with the Company: any Personal Information you provide to us as part of any communications with the Company, by any means, including by approaching the Company through its e-mail address or any other contact medium.
· Identifiers: while using the App we may collect certain unique identifiers, such as your Unique Device Identifier (UDID), User-Agent or other unique identifiers for security purposes and analytics and in order to provide you with our Services via the App.
· Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 2.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information, as long as such connection or linkage exists.
We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.
3. How Do We Collect Information on Our Users?
a. We collect information through your use of the App. In other words, when you are using the Services, may process the information relating to such usage. Such process will be conducted to the minimum required to complete the traffic between Users and provide Users with the Services.
b. We may collect information which you provide us voluntarily. For example, we may collect Personal Information when you communicate with the Company, by any means, including by approaching the Company through its e-mail address or any other contact medium.
4. What are the Purposes of the Collection of Information?
We collect Non-Personal Information and Personal Information in order to operate the App and provide the Services.
Non-Personal Information is collected in order to:
Provide the Services.
For security purposes.
Enhance the User’s experience while using the App and/or the Services.
Send push notifications to the User’s device.
Personal Information is collected in order to:
Enable the overall operation of the App and the Services.
To communicate with you (to the extent that you have contacted us, at your discretion). To this end, we do not use any Personal Information derived from the Services.
· Be able to contact Users and respond to User’s inquiry for the purpose of providing them with assistance and support upon User request.
· Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, including in order to improve our Services. Please note that in general we analyze aggregate data for such purposes, rather than specific user data, however we may need to analyze a specific case to address a specific problem.
· For administrative purposes and compliance with our legal obligations.
5. Sharing Information with Third Parties
Please note that generally, we do not store Personal Information on our servers and therefore the Company will not share any Personal Information it processes with any third party, other than with out service provides (as necessary to provide the Services, and as further detailed below) and in the following extreme circumstances: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to protect the rights, property, or personal safety of the Company, its Users or the general public; (d) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, so long as such acquirer maintains the same privacy terms hereunder; and/or (e) pursuant to your explicit approval prior to the disclosure.
Note, that we collect, hold and/or manage your Personal Information through our authorized third-party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
For avoidance of doubt, we may transfer and disclose Non-personal Information to third parties at our discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our products and services.
6. Minors
The App is intended for Users over the age of sixteen (16). Therefore, the Company does not intend and does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the App. Please contact us at [please insert] if you have reasons to suspect that the Company collected Personal Information from minors under the age of sixteen (16) and we may prohibit and block such User from accessing the App.
7. Security
We take reasonable measures to maintain the security and integrity of our App and your information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
Amongst others, we operate the App through reputable vendors that ensure a high level of data security, encrypt personal information at transit and in rest, maintain technical and organizational measures to ensure that the data is maintained secure, ensure that our personnel undergo regular training and are under a duty of confidentiality and perform regular test and audits to ensure our compliance with applicable data protection laws and market security standards.
THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA.
8. Third Party Service Providers
While using the App we may be using third party service providers, who may collect, store and/or process the information detailed herein. The Company uses commercially reasonable efforts to engage with third parties that provide high standards of protection of data. Such third parties include the following categories:
· Cloud storage services;
· Push-Notification services;
· Avatar creation services; and
· Hosting and caching services.
9. Deletion or Modification of Personal Information
We acknowledge that you may have the right to access and change the Personal Information we collect and process about you. Due to the fact that the Company only processes your Personal Information in a minimal way and only to allow you to communicate with other Users in the App and also in light of the fact that the Services are decentralized, encrypted and we do not retain a copy of your Personal Information, the Company has no possibility to modify, correct, delete or any similar action regarding your Personal Information.
Should you have any inquiries in this regard, or should you wish to delete your username or disable your Key, please contact us at: [Insert email]
10. International Data Transfer
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.
11. Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the App and any information collected with respect thereto. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the App regarding such change. Such substantial changes will take effect seven (7) days after such notice was provided on our App. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.
12. Got any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an e-mail to the following address: [Please Complete] and we will make an effort to reply within a reasonable timeframe.