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The privacy of your personal information is very important to us. This statement outlines what personal information Hoopla collects about you and how we use it in the Hoopla application, widgets, products and services, our website located at www.www.hoopla.net (the “Site”), and our application located at app.www.hoopla.net (the “App”) (collectively, the “Service”). If you have any questions or concerns relating to privacy or security, please send an email to email@example.com.
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.
Hoopla complies with the provisions of the Regulation (EU) 2016/679 of the European Parliament, known as the General Data Protection Regulation (GDPR). For purposes of Article 14(2) of the GDPR, Hoopla relies on the following lawful basis for processing Personal Data: consent, compliance with law and legitimate interest.
To use the Service or to contact us for information about our services, you will have to provide the personal information needed to activate your account. By “personal information,” we mean data that is unique to an individual, such as your name, e-mail address, and company information, user IDs and passwords, online identifiers, device information, billing and transaction information, credit card or other financial information, contact preferences, and similar information. Hoopla collects information via email, through the Site, or other direct contact from you, and in the Service, that is voluntarily given to us.
We use our third party tracking-utility partners to gather certain information automatically and store it when you use the Service. This information includes internet protocol (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, to administer the Service, to track users’ movements around the Service and to gather demographic information about our user base as a whole.
We post customer testimonials/comments/reviews on our Site which may contain personally identifiable information. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you want your testimonial removed please contact us at firstname.lastname@example.org.
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
If you provide personal information for a certain reason, we may use the personal information in connection with the reason for which it was provided. We use your personal information to provide you with access to your account, contact you or respond to questions about your account, resolve any problems you may have, send you notifications and reminders, invoicing, to better understand our users, and ask you for your feedback on how we can improve our Service.
Hoopla will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Hoopla will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We take precautions to protect your information and have implemented administrative, technical, and physical measures designed to protect your personal information from accidental loss and from unauthorized access, disclosure, use, alteration, or destruction. When you submit sensitive information via the Service, your information is protected both online and offline. Hoopla utilizes generally-accepted security measures (such as encryption) to protect against the misuse or unauthorized disclosure of any sensitive personal information you submit to us (such as log in information). However, like other Internet sites and web applications, we cannot guarantee that it is completely secure against attempts to evade security measures or intercept transmissions over the Internet. You are responsible for maintaining the security of your username and password for the Service.
We also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information.
We share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.
We use other third parties such as an email service provider to send out emails on our behalf. When you sign up for our services, we will share your personal information only as necessary for the third party to provide that service.
If you wish to subscribe to our newsletter(s) or blog, we will use your name and email address to send the related content to you. Out of respect for your privacy, you may choose to stop receiving our newsletter, blog updates, or marketing emails by following the unsubscribe instructions included in these emails, or you can contact us at email@example.com.
Our marketing services partners, enable us to present you with information on our services based on your previous interaction with Hoopla. The techniques our partners employ do not automatically collect personal information such as your name, email address, postal address, or telephone number. In addition, we use Google, Inc. to collect data to track and examine the use of www.www.hoopla.net, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.
Hoopla uses a third party credit card processing provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on our behalf, and is subject to confidentiality obligations restricting the disclosure of information collected to other third parties.
Under GDPR, Hoopla acts as a Data Processor vis a vis data provided to it through the Service by its Customers. Hoopla acts as a Data Controller with regard to data collected as part of its marketing activities. All transfers of data internally in the European Economic Area is done in accordance with Privacy Shield or Standard Contractual Clauses.
Hoopla’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Hoopla remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Hoopla proves that it is not responsible for the event giving rise to the damage.
You may opt out of any future contacts from us at any time by contacting us via the email address or phone number given below. You may opt out of Google Analytics by visiting the Google Analytics opt-out page. If you choose not to provide any personal information, you can use the Service, but may not be able to use certain parts of the Service.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below. If requested to remove data, we will respond within the applicable legal timeframe.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Service is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Websites, directly use the Service, or install the Hoopla Apps. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or on or through any of its features, install the Hoopla Apps, or directly use the Service, including providing your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data directly from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
Any questions or concerns regarding the use or disclosure of personal information should be directed to Hoopla at the address given below. Hoopla will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.
In compliance with the Privacy Shield Principles, Hoopla commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Hoopla at:
Hoopla Software, Inc. Privacy Shield 4 N. Second Street, Suite 260 San Jose, CA 95113
Or via email at email@example.com.
Hoopla has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at www.privacyshield.gov/article?id=ANNEX-I-introduction.