(Effective Date: June 1, 2018)
HULFT, Inc. (“Company,” “we”, “us” or “our”) maintains this Privacy Notice (“Privacy Notice”) that summarizes the treatment of information provided or collected on the sites where this Privacy Notice is posted, including, without limitation our website(s) at https://hulftinc.com/ (our “Sites”).
When you visit our Sites this Privacy Notice will apply. If you have any questions or concerns about our use of your information, then please contact us using the contact details provided at the bottom of this Privacy Notice..
A. Types and Collection of Information
Our primary goal in collecting the information described below is to provide you, the user, with a customized experience on our Sites and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.
1. Types of Information We Collect
We collect two basic types of information in connection with our Service: (a) Personal Information and (b) Anonymous Information. Personal Information, Anonymous Information and Aggregated Information as used in this Privacy Notice are defined below:
“Personal Information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s first and last name, home or other physical address, email address, and telephone number. Personal Information also includes identifiers, such as cookies, IP addresses and Mobile Device IDs that recognize individuals over time and across different websites or online services, where those identifiers can be reasonably linked to an identifiable individual.
“Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual person. When Anonymous Information is directly or indirectly associated with or combined with any Personal Information, such Anonymous Information will also be treated as Personal Information.
“Aggregated Information” means information about groups or categories of persons, this can constitute Personal Information unless it does not identify and cannot reasonably be used to identify an individual person.
2. How We Collect Your Information
Information Collected Directly From You
When you interact with our Sites, we collect information (including Personal Information) you provide to us directly as described below:
Registration Information. When you register with us (including directly through a Site or your Mobile Device, or other similar option) to create an account or profile within our Sites, you will be asked to provide:
(i) your first and last name;
(ii) your e-mail and mailing address;
(iii) user name, nickname, or password;
(iv) language preferences and
(v) such other information (including Personal Information) necessary to complete the registration process.
Information Through Mobile Devices. When you access our Sites through your mobile telephone or other mobile devices (collectively, “Mobile Device”), we will collect:
(i) Mobile Device type and manufacturer;
(ii) mobile carrier;
(iii) Mobile Device identifiers or advertising identifiers (“Device ID”);
(iv) telephone number;
(v) Internet Protocol address;
(vi) geographic location/country/zip code;
(vii) platform version;
(viii) installation, navigation, access, interaction, impression and engagement information;
(ix) network connection type;
(x) browser type;
(xi) Mac address;
(xii) iOS advertiser ID; and
(xiii) such other information you voluntarily provide to us.
In addition, we collect information you provide when you sign up to have Short Message Service notifications sent directly to your Mobile Device. We use your Device ID to verify, audit and analyze your use of our Sites.
Service and Support. When you communicate with us in connection with customer service and technical support, we will collect and store your contact information, information about your use of our Sites, your user ID and such other information you voluntarily provide to us in connection with such inquiry.
Profile Information. We provide areas on our Sites where you can post information about yourself and others and communicate with others or upload content. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose Personal Information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your Personal Information.
Information Received from SNS and APIs. When you access our Sites through an SNS, we access and obtain certain information from your profile through such SNS and the applicable SNS platform Application Programming Interface (“API”). The information we receive varies by the Application and by the privacy settings you choose for the SNS and may include Personal Information, including, without limitation, the following:
(i) your first and last name;
(ii) your profile picture or its URL;
(iii) your user ID number; which is linked to publicly available information such as name and profile photo;
(iv) the user ID numbers for your friends that are also connected to our Application(s);
(v) login e-mail you provided to the SNS when you registered;
(vi) your physical location and that of your access device(s);
(vii) your password; and
(viii) your gender.
B. Use and Disclosure of Personal Information
Unless otherwise permitted or required by law, or with your additional consent, we will use and disclose your Personal Information solely for the purposes set out in this Privacy Notice.
3. How We Use Your Personal Information
We use your Personal Information for any one or more of the following purposes:
(a) to allow you to register with us to create an account or profile within our Sites;
(b) to operate, maintain and improve our Sites;
(c) to conduct market research analyses;
(d) to communicate with you concerning your account or, with your explicit consent or as permitted by law, to send you announcements, newsletters, promotional materials and other information about our Sites or offerings of our business partners, and to offer you opportunities to participate in surveys, campaigns, contests and sweepstakes;
(e) to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Sites;
(f) to respond to customer service and technical support inquiries, troubleshoot problems, investigate incidents, and handle complaints;
(g) to provide services to you and our customers;
(h) to complete payment and billing transactions;
(i) to comply with applicable laws, regulations, legal processes or enforceable government requests;
(j) to send notices, and to enforce applicable terms and conditions set forth in such policies;
(k) to enable user-to-user communications and other in-service communications and interaction;
(l) to enable us to deliver information to SNS when you use or access our Site through such SNS; and
(m) to protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
The Company processes Personal Information on our servers in the United States of America, Japan and in other countries. In some cases, we may process Personal Information outside of your country. For more information please see our section titled ‘ International Data Transfers’.
4. How We share Your Personal Information
Third Party Service Providers. We may disclose your Personal Information to third party service vendors and partners in connection with our provision of our Sites. Such third party service vendors and partners may be located in countries other than your country of residence and provide such services as payment processing, data analysis, e-mail delivery, hosting, order fulfillment, infrastructure and network storage, customer service, technical support, auditing, content licensing and promotional services.
Advertising of Third Party Products and Services. We may share (i) Aggregated Information; (ii) Anonymous Information; and (iii) certain technical information with third party advertisers for their direct marketing purposes, including, without limitation, to develop and deliver targeted advertising in our Sites and on the websites of third parties.
Affiliates. We may disclose Personal Information to our “Affiliates” (which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Japan or Europe for the purpose of transferring and processing such Personal Information based on our instructions and such purposes as described in this Privacy Notice.
Ownership Change. In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your Personal Information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, you will be notified via prominent notice on our Sites of any change in ownership or uses of your Personal Information, as well as choices you may have regarding your Personal Information.
Termination of License Arrangements. Upon the expiration or a termination of any third party license arrangements involving one or more parts of our Sites or services, your Personal Information may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Notice.
Security. Your Personal Information, and communications you make within our Sites, may be accessed and disclosed if we believe that our Sites are being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.
Legally Required Disclosures. We may also disclose Personal Information when required by law, regulation or regulatory body, to a government agency or on receipt of a court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities.
Consent. We may also disclose Personal Information to another person with your consent.
C. Storage of Information and Security
We employ appropriate technical and organizational measures to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the United States, Japan and United Kingdom. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, to protect the confidentiality of your Personal Information. Moreover, in addition to password protection offered in connection with your account, we encrypt your transmission of sensitive information to us via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.
Although we take reasonable precautions against possible security breaches of our Sites, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your Personal Information. We strongly urge you to take reasonable measures at all times (online and offline) to protect your Personal Information.
In addition, while we strive to protect your Personal Information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.
We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your Personal Information and data is treated securely and in accordance with this Privacy Notice.
D. Your Privacy Rights
1. Marketing Opt-Out Provision
In addition to withholding your consent when requested and opting out, and subject to legal and contractual restrictions, you may withdraw your consent to allowing us to use and disclose your Personal Information for the purposes listed below at any time. You may do so by emailing us at email@example.com and including your user ID or registered email address so that we can confirm your identity. We will use our commercially reasonable efforts to comply with your request. Please understand that withdrawing your consent may affect your ability to use certain features of our Sites.
(a) Receiving Marketing Communications from the Company. Receiving commercial electronic messages, including, without limitation, text and email messages, direct social media messages, announcements, newsletters and promotional materials or offers to participate in surveys, campaigns, contests or sweepstakes.
(b) Disclosing Personal Information to Affiliates. Our disclosure of your Personal Information to our Affiliates for marketing purposes.
(c) Disclosing Personal Information to Third Party Service Providers. Our disclosure of your Personal Information to authorized third party service providers for marketing purposes.
2. Your Rights
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Generally, you may review, update, correct or delete your Personal Information collected by or through our Sites by logging into your account. You may also be able to request information directly in accordance with your privacy rights.
Your California and Canadian Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, customers, prospective customers, and visitors of our Service who are residents of the State of California have the right to request certain information regarding its disclosure of Personal Information to third parties for direct marketing purposes. Canadian federal and provincial laws provide a similar right of access. If you are a resident of California or Canada and wish to request such information, please email us at firstname.lastname@example.org with “California/Canada Privacy Rights” in the subject line.
Your EEA Privacy Rights
If you are a visitor from the EEA, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your Personal Information, and you are not able to do so through logging onto your account, you can contact us using the contact details provided under the “Contact” heading below https://hulftinc.com/contact/.
- In addition, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact” heading below https://hulftinc.com/contact/.
- Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- You 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. Contact details for data protection authorities in the EEA are available here.
E. Additional Privacy Matters
1. Notification of Changes
We reserve the right to update and change the terms of this Privacy Notice at any time. If we decide to update and materially change the terms of our Privacy Notice, we will post those changes or on the applicable Sites, and in the updated Privacy Notice.
2. Links to Third Party Websites, Services and Offers
Our Sites may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information (including any Personal Information) you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing Personal Information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.
3. Protection of Children’s Privacy
Company is committed to providing special protection for the privacy of children who may use our Sites. Our Sites are not intended for nor directed to children under the age of 13 and we do not knowingly collect, use or retain Personal Information from such children. If we discover that we have inadvertently collected Personal Information from children under the age of 13, we will take all reasonable measures to delete any records of such Personal Information that come to our attention.
4. Special Note to Parents
If you become aware that your child has provided us with Personal Information, please notify us so that we may delete such information from our records and discontinue any related features or services (see Opt-Out Provision above). We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.
5. Users Outside United States
International Data Transfers
The Company is a U.S. company and Company’s U.S. business operations are primarily conducted in the State of California, U.S.A. We operate our company and administer this Privacy Notice under applicable U.S. and California laws and regulations. If you use our Sites from outside United States, your Personal Information will be transferred to, stored in and be processed in the United States, Japan and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Notice. Please note that privacy laws of the United States and the State of California may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Information as those laws. However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Notice. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information with our third party service providers and customers, which require all parties to protect personal information they process from the EEA in accordance with European data protection law. Further details can be provided upon request.
Legal Basis for Processing Personal Information (for visitors or users from the EEA)
If you are a visitor from the EEA, our legal basis for collecting and using the Personal Information described in this Privacy Notice will depend on the Personal Information concerned and the specific context in which we collect it.
We will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you, (ii) where the processing is in our legitimate interests, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we collect and use your Personal Information in reliance on our legitimate interest or those of a third party, this interest will normally be to operate the Sites, communicating with you as necessary to provide our services, improving our platform or for the purposes of detecting or preventing illegal activities.
If you have 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 under the “Contact Us” heading below.
6. Information Retention and Deletion
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting 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 (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
The controlling language of this Privacy Notice is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Notice shall govern to the extent of any inconsistency between the English version and any translated version.
8. Do Not Track. We do not respond to DNT (Do Not Track) signals.
9. Contact Us
If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Notice, or have other questions or suggestions about our information practices, including our practices respecting the storage and processing of Personal Information please contact our Chief Privacy Officer via e-mail at Policy@Hulftinc.com.
Copyright © 2018 HULFT, Inc. All rights reserved.