Updated : January 31 , 2024
We process your
personal data when you use our App (“Hedy”, “we”, “our” or the “App”) and when
you use the App together with the App ( “ Hedy ” ).
In this privacy policy ( “ Hedy ”) , we would like to provide you
with information about our, the nature, scope and purpose of data collection
and usage and give you insight into the processing of
your personal data.
· Controller.
The
controller of the data processing is Hedy . You can contact us by
e-mail at the e-mail address below.
· Data
Protection Officer. Our Data Protection Officer can be
contacted via the e-mail address. If you have any questions about the
processing of your personal data, please feel free to contact him/her.
This Privacy Policy
applies to websites, applications and other services operated by us. We process
personal data that you provide to us as a user of our products, for example,
through the use of our products, and personal data that users provide to us
("Data").
Without some data about
you, such as basic profile details and the types of people you want to meet, we
can't help you make meaningful connections. We also collect information
generated when you use our Services, such as access logs, and information from
third parties, such as when you access our Services through a social media
account. We go into more detail below if you'd like to learn more.
You choose to provide
us with certain information when you use our Services. This includes:
· registration message
·
Required Information: You must provide
us with certain information in order to register with us:
·
email address
·
gender
·
Optional Information: Some information
is optional during registration and you can add or remove it later, such as
pictures. You can allow us to access your camera or photo album.
· Payment and
Subscription Information
·
We use payment providers (e.g. Apple, Google) to process payments. When you subscribe
to a paid service or purchase directly from us, you will provide information
such as your debit or credit card number or other financial information to our
payment provider or us. While we do not store any credit card information
ourselves, we store the payment ID number provided by the respective provider,
which can be assigned to a person, as well as your subscription term, price,
currency, VAT (based on country information) and payment provider.
· As part of operating
the Service, we process your chats with other users and the content you post.
· When you choose to
participate in one of our promotions, events or contests, we collect
information about you to register or participate. If you win a prize, we
collect financial information to reward you.
· If you contact our
customer service team, we collect the information you provide to us during your
interaction. We monitor or record these interactions for training purposes and
to ensure high quality service.
· When you participate in
a survey or focus group, you provide us with your insights about our products
and services, responses to our questions and recommendations.
In addition to the information you provide directly to us, we also receive
information about you from others, including:
· Register
via social media. You can use a social media login (such
as Facebook Login) to create and log into your account. We will receive your
first and last name, email address, gender, and profile picture.
· Other
partners. We may receive information about you from our partners, for
example where Hedy advertising is posted on partners’ websites and platforms
(in which case they may pass on details of the success of the campaign).
· Other
Users. Other users may provide information about you when they use
our Services. For example, we may collect information about you from other
users if they contact us about you.
When you use our
Services, we collect information about which features you have used, how you
use them, and the device you use to access our Services. For more details, see
below:
· Usage
Information. We collect information about your
activities on our Services, such as how you use them (e.g., the dates and times
you log in, the features you have been using, searches, clicks and pages
displayed to you, referring web page addresses) and how you interact with other
users (e.g., the users you connect and interact with, the times and dates you
exchange, the number of messages you send and receive).
· Device
Information. We collect information about the devices
you use to access our Services, including:
·
Hardware and software information, such
as IP address, device ID and type, specific device and application settings and
characteristics, application crashes, advertising IDs (such as Google’s AAID
and Apple’s IDFA, both of which are randomly generated numbers that you can
reset by going to your device settings), browser type, version and language,
operating system, time zone, identifiers associated with cookies or other technologies
that may uniquely identify your device or browser (for example, IMEI/UDID and
MAC address);
·
Information about your wireless and
mobile network connections, such as your service provider and signal strength;
·
Information about the device's sensors,
such as the accelerometer, gyroscope, and compass.
· Other
information with your consent. If you allow us to do
so, we may collect your precise geolocation (latitude and longitude) in a
variety of ways, depending on the Services and device you are using, including
GPS, Bluetooth, or Wi-Fi connection. Your geolocation may be collected in the
background even when you are not using the Services, if you give us permission
to do so. If you object to our collection of your geolocation, we will not
collect it. Similarly, if you consent, we may collect your photos and videos
(for example, if you want to post photos, videos, or stream on the Services).
This website uses
"cookies" - small text files placed on your computer, mobile device
and/or stored by your browser. The basis for processing data through cookies is
our legitimate interests. We use and may allow others to use cookies and
similar technologies (e.g. web beacons, pixels) to
recognize you and/or your device.
We use your data to
provide our services and to help you stay safe.
· Create and manage your
account
· To provide you with
customer support and respond to your requests
· Complete your
transaction
· Communicate with you
about our services, including order management and billing
· Connect with other
users. Analyze your profile, service activity, and preferences to recommend
meaningful connections to you and recommend you to others
· Performance.
To
monitor, analyze, and improve the use of our Products and to protect the
security or integrity of our Products.
· Research
and Development. Conduct research to further our
development, to develop new features and to provide you with a better, more
intuitive and personalized experience
· a sweepstakes, contest,
discount or other offer
· Advertising.
Use
the following data, either individually or in combination, to target and
measure advertising effectiveness to registered users and visitors:
·
gender;
·
age;
·
language;
·
Activity data (purchase, usage)
· Marketing
Director.
·
Push message marketing: We will send you
marketing push messages.
·
NOTICE REGARDING COMMERCIAL EMAIL:
Member consents to receive commercial emails from the Company and acknowledges
and agrees that the Company may use its email address and other personal
information to initiate commercial emails.
·
Retargeting: You may see marketing
messages on the platforms listed below. In addition, other users with similar
characteristics to you on these platforms may also see marketing messages on
these platforms (i.e. Facebook Lookalike audiences).
You can opt out at any time through our customer support. After opting out, it
may take a few days until you are removed from all audiences.
(List of other platforms: Facebook, Instagram, Google, Twitter, Vungle, UnityAds, Snapchat, and Bytedance)
· law
enforcement.
·
Addressing ongoing or suspected
misconduct on and off the platform
·
Conduct data analysis to better
understand and design countermeasures to these activities
·
Retain data related to fraudulent
activity to prevent recurrence
· Compliance.
·
Comply with our obligations and comply
with all applicable laws and regulations.
When you voluntarily
disclose information on the Services, including your public profile, you share
that information with other users. Please be careful with your information and
make sure that what you share is content that you can view publicly, because
once you share your information, neither you nor we can control what others do
with your information.
If you choose to limit
the audience for all or part of your profile or certain content or information
about you, it will be visible according to your settings.
We share your
information with others who help us provide and improve our products (such as
maintenance, analysis, auditing, payment, fraud detection, marketing, and
development). Service providers will have access to your information as
reasonably necessary to perform these tasks on our behalf and are obligated not
to disclose or use it for other purposes.
We use processors such
as Appsflyer, Google, Facebook, Amazon Web Services,
Inc. or Zendesk, Inc.
We may transfer your
data if we are involved in a merger, sale, acquisition, divestiture,
restructuring, reorganization, dissolution, bankruptcy or other change in
ownership or control, in whole or in part.
We may disclose your
data where reasonably necessary to: (i) comply with
legal process, such as a court order, subpoena or search warrant, a
government/law enforcement investigation, or other legal requirement; (ii)
assist in the prevention or detection of crime (in each case, subject to
applicable law); or (iii) protect the safety of any person.
We may also share data:
(i) if disclosure would mitigate our liability in
actual or threatened litigation; (ii) as necessary to protect our legal rights
and the legal rights of our users, business partners, or other interested
parties; (iii) to enforce our agreements with you; and (iv) to investigate,
prevent, or take other action regarding illegal activity, suspected fraud, or
other wrongdoing.
We may ask for your
consent to share your data with third parties. In any case, we will make it
clear why we are sharing the information.
In any of the above
situations, we may use and share Non-Personal Data (that is, data that does
not, by itself, identify you, such as device information, general demographics,
general behavioral data, geolocation in de-identified form), as well as
Personal Information in hashed, non-human-readable form.
We may also share this
information with other third parties (particularly advertisers) to develop and
deliver targeted advertising on our products or third-party applications and to
analyze and report on the ads you have seen. We may combine this data with
other non-personal information collected from other sources or with personal
data in hashed, non-human-readable form.
· Storage
period. We store your data for as long as you are a registered user
of the product. Beyond that, we only store the data if this is legally
necessary (due to warranty, limitation or retention periods) or otherwise
required.
· Account
Deletion. If you decide to delete your account, all data we have about
you will be deleted, except as follows:
·
Any details you make public (such as
comments on other registered users' activities, gifts you share, etc.) will be
anonymized, i.e. it will be clear that such details
were provided by the deleted user.
·
Any data that is required for the
fulfillment of a contractual obligation or for compliance with statutory
retention obligations by the product shall not be deleted, but shall be reduced
to the minimum possible.
If storage is legally
necessary, e.g. for accounting purposes, a deletion
request will not affect the data.
We want you to be in
control of your information, so we provide you with the following tools:
· Access / Update tools
in the service. Tools and account settings help you
access, correct, or delete the information you have provided to us that is
associated with your account directly in the service. If you have any questions
about these tools and settings, please contact our customer service team for
assistance.
· Device permissions. Mobile platforms have a
permission system for certain types of device data and notifications, such as
location services and push notifications. You can change the settings on your
device to agree or object to the collection of that information or the display
of that notification. Of course, if you do this, some services may lose full
functionality.
· Deletion.
You
may delete your account by using the appropriate functionality directly on the
Service.
We want you to understand
your privacy rights. Here are some key points to remember:
· these terms). If you would
like to request a copy of your personal information, please contact our
Customer Service Team for assistance.
· Update
your information. If you believe that the information we hold about you is inaccurate or that we are
no longer entitled to use it and wish to request correction, deletion or object
to its processing, please contact our Customer Service Team.
For your protection and
the protection of all our users, we may ask you to provide proof of identity
before we can respond to the above requests.
Please keep in mind
that we may deny a request for certain reasons, including if the request is
illegal or may violate the trade secrets or intellectual property rights or the
privacy of another user. If you wish to receive information related to another
user, such as a copy of any messages you receive from him or her through our
Services, the other user must contact our Privacy Officer to provide written
consent before the information is released.
Additionally, we may
not be able to honor certain requests to object to the processing of personal
information, particularly where such requests would no longer allow us to
provide services to you.
· Uninstall.
You
may stop all information collection by uninstalling the App using your device’s
standard uninstall process. If you uninstall the App from your mobile device,
the unique identifier associated with your device will continue to be stored.
If you reinstall the App on the same mobile device, we will be able to
reassociate this identifier with your prior transactions and activity.
· Accountability.
In
some countries, including the EU, you have the right to lodge a complaint with
an appropriate data protection authority if you have concerns about how we
process your personal information. The data protection authority you can lodge
a complaint with may be the place of your habitual residence, your place of
work or where we are located.
We work hard to protect
you from unauthorized access or alteration, disclosure, or destruction of your
personal information. Like all technology companies, although we take steps to
protect your information, we do not promise, and you should not expect, that
your personal information will always remain secure.
We regularly monitor
our systems to check for possible vulnerabilities and attacks and periodically
review our information collection, storage and processing practices to update
our physical, technical and organizational security measures.
If we suspect or detect
any breach of security, we may suspend your use of all or part of the Service
without prior notice. If you believe your account or information is no longer
secure, please notify us immediately through our Customer Service.
If we make material
changes to this Policy, we will notify you by posting the revised Privacy
Policy or by providing a notice on our website or as required by law. You agree
to review the Privacy Policy periodically so that you are aware of any
modifications. You agree that your continued use of the Service after we post a
revised Privacy Policy or provide a notice on our website will constitute your
acceptance of the revised Privacy Policy. If you do not agree to the terms of
the Privacy Policy, you should not use the Service.
If you have any
questions about this Privacy Policy, please contact us by email . Any personally
identifiable information provided in inquiries related to this Privacy Policy
will be used only to respond to the inquiry and in accordance with our Privacy
Policy.
Because we are always
looking for new and innovative ways to help you build meaningful connections,
this policy may change over time. We will notify you of any significant changes
before they take effect so that you have time to review the changes.