Last Updated: June 1, 2022
- Our Website, http://www.myhavo.com, including all related sites and microsites (the “Website”).
- Social Media, such as Facebook, Instagram, LinkedIn, and Twitter 1 (collectively, “Social Media”).
- Email and similar electronic messages, except for personal messages sent to our clients.
- Company either offline or through any other means.
- Any third party, including through any application, content, or advertising that may link to or be accessible from or on the Website or Social Media.
1. INFORMATION COLLECTED
We collect several types of information from and about users of our Website and Social Media, such as information that may personally identify you, like your name, postal address, email address, employer information, telephone number, IP address, or any other unique electronic identifier.
- a. Personal Information. “Personal Information” collected by Company may include:
- Information you provide by filling in forms, such as when you submit an employment application, submit an inquiry, register for an event, request information, enter a promotion, report a problem with the Website, or otherwise contact us via the Website. Identifiers may include your name, alias, postal address, or other information you provide.
- Content that you authorize us to access, publish, and view on Social Media.
- Records of your correspondence with us.
- Date and time your computer accessed the Sites.
- Your search queries and content viewed on our Website.
Also, you may provide information to be published or displayed on public areas of our Website or Social Media, or transmitted to other users of the Website, Social Media or third parties. Information you provide and publish in public areas is transmitted to others at your own risk. Company cannot control the actions of other users of the Website or Social Media, and cannot and does not guarantee that your published information will not be viewed or used by unauthorized persons and/or in unwanted ways.
We may associate this Other Information to Personal Information that you have provided through the Website or Social Media.
- when the collection, use or disclosure of personal information is permitted or required by law;
- in an emergency that threatens an individual’s life, health, or personal security;
- when the personal information is available from a public source;
- when Company or its affiliates require legal advice from an attorney;
- for the purposes of collecting a debt;
- to assist Company and its affiliates in loss prevention and to protect Company and its affiliates from fraud;
- to create, develop, operate, deliver, and improve our products, services, content and advertising; or
- to investigate an anticipated breach of an agreement or a contravention of law.
Consent may be provided orally, in writing, electronically, through an authorized representative or affiliate, or it may be implied where the purpose for collecting, using, or disclosing the Personal Information would be considered obvious and you voluntarily provide Personal Information for that purpose. Consent may also be implied when you are given notice and a reasonable opportunity to opt-out of providing Personal Information being used for mail-outs, marketing, or other Company functions, and you do not opt-out.
- b. Other Information Each time a computer visits our Website or Social Media to read or download information, we may collect certain information from that computer automatically which may include the following (the “Other Information”):
- Web browser, operating system, and device type.
- The internet domain name or IP address from which your computer accessed the Sites.
- The name or IP address of the website that connected you to our Sites.
- Date and time your computer accessed the Sites.
- Your navigation pathway into, through, and exit from our Sites.
We may associate this Other Information to Personal Information that you have provided through the Website or Social Media.
- Information Collection Methods. We collect Personal and Other Information directly from you when you provide it to us and automatically as you navigate through our Website or Social Media via analytics tools, tracking tools (including cookies), and third-party data providers. Company may use Google Analytics® (“Google Analytics”) and/or similar services. We may implement Google Analytics or similar features based on Display Advertising (Google Analytics Demographics and Interest Reporting). You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. We will use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users’ interests and to help refine our advertising strategies.
- Cookies. Company’s Website may place a small text file called a cookie in the browser files of computers that visit it. Cookies enable websites and service providers’ systems to recognize your browser, enable website features, personalize content to your preferences, and store website-specific information. You may decline our cookies if your browser allows, and those cookies will no longer collect information from you, but some parts of our Website may not work properly should you delete or disable cookies.
- How You Can Manage Collection of Non-Personal Data. Third-party advertising companies may collect data about your visit to our Sites and others; this is referred to as “Online Behavioral Advertising”. You may opt out from this collection and use of data by companies participating in the Digital Advertising Alliance (“DAA”) on the “Opt Out from Online Behavioral Advertising” website, located at: https://optout.networkadvertising.org or http://www.networkadvertising.org/managing/opt_out.asp.
2. HOW WE USE INFORMATION COLLECTED
Company may use any of the information we collect from you to:
- Present our Website, Social Media, and its content to you.
- Personalize content according to your preferences.
- Improve our Website’s user experience and determine its effectiveness.
- Contact you to provide information or services that you request from us.
- Send periodic emails.
- Compile analytics reports about traffic, navigation, preference, and content performance.
- Notify you about changes to the Website, Social Media or any services we offer or provide though it.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- Accomplish any other purpose for which you provide it.
Company may also share materials that contain no Personal Information with business partners.
3. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information that does not contain Personal Information about our users, to the extent allowed by applicable law, to the following:
- Our subsidiaries and affiliates.
- Contractors, service providers and other third parties we use to support our business.
- A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Company’s business or assets, in which Personal Information held by Company users is among the assets transferred.
- Fulfill any reason you specify with your consent.
- For any other purpose disclosed by us when you provide the information.
- Accomplish the purpose for which you provide it.
We may also disclose your Personal Information to:
- Comply with any court order, law or legal process, including to respond to any government or regulatory request.
- Protect the rights, property, or safety of Company, our customers, or others if disclosure is required to do so.
4. COMPANY DOES NOT SELL YOUR INFORMATION
Company does not sell your Personal Information. You may request that we delete your Personal Information from our records and direct any service providers to delete that Personal Information from their records. After we receive and confirm your request, we will delete that Personal Information unless a legal exception applies.
5. PROTECTING YOUR INFORMATION
Company leverages third-party technological tools to ensure the security of your Personal Information through reasonable and appropriate measures to protect it from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, while considering the risks involved in the processing of and nature of the Personal Information.
However, the transmission of information via the internet is not a completely secure process. Although Company uses best practices to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
6. PRIVACY ON THIRD-PARTY WEBSITES AND SOCIAL MEDIA
Our Website or Social Media may link to third-party applications, products, services, or websites (“Third-Party Locations”) for your convenience and information. We do not review, control, or monitor the privacy practices of those Third-Party Locations and are not responsible for the practices employed by Third-Party Locations. These sites or services may constantly change their content and links, and may have their own privacy policies, service policies, and terms. Interaction with any other websites, including websites which have a link to our Website, is subject to that website’s own terms and policies. Company does not endorse and cannot make any representations about Third-Party Locations.
We may also provide Social Media features that enable you to share information with your social networks and to interact with Company on social media platforms. Your use of Social Media may result in the collection or sharing of information about you. If you post, comment, indicate interest, complain, share Personal Information, or photographs to any social network, blog, or other such forum, upon which Company has an account, know that any information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you or used for purposes over which neither you nor Company have control. Company is not responsible for the Personal Information you share in Social Media forums.
7. ACCESS, CORRECTION, OBJECTION, AND PORTABILITY RIGHTS
You have the right to request access to, correction of errors in, or erasure of your Personal Information. You also have the right to object to the processing of your personal data and to receive a copy of your Personal Information. You may email us at firstname.lastname@example.org with proof of your identity to request access, correction, cessation, erasure, portability, or object to our processing of any Personal Information that you provided us. Company may not fully accommodate a request if its fulfillment would violate applicable law or is not required under applicable law.
8. DO NOT TRACK MECHANISMS
Your browser may deliver a Do Not Track header or similar signal to this Website. Because of the changing state of technology and variance in standards within the technology and marketing industries regarding the meaning of Do Not Track signals, we currently do not guarantee that we will honor Do Not Track signals.
9. NOTICE TO CALIFORNIA RESIDENTS
These disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act (“CPRA”) may provide additional rights to know, delete and opt out, and may require some applicable businesses collecting or disclosing Personal Information to provide notice of rights California residents may exercise. By voluntarily providing notice of and explaining some of these rights, Company in no way acknowledges or consents to being subject to either the CCPA or CPRA, and expressly disclaims applicability of CCPA and/or CPRA to its business based on small business exemptions to both laws.
Notice of Collection and Non-Collection.
- Company may collect or may have collected information corresponding to the following categories of information enumerated in the CCPA.
- Identifiers, including name, address, email address, account name, Social Security Number, IP address – and an ID number assigned to your account.
- Customer records, phone number, billing address, credit or debit card information, employment or education information.
- Demographic information, such as your age or gender. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.
- Analytics and Advertising, including purchases and engagement with our services.
- Internet activity, including history of visiting and interacting with our service, browser type, browser language and other information collected automatically.
- Geolocation data, including location enabled services such as Wi-Fi and GPS.
- Inferences, including information about your interests and preferences.
- Sensitive Personal Information, including biometric data, social security numbers, driver’s license numbers, geolocation data, race, ethnicity, religious or philosophical beliefs, union membership, content of nonpublic communications, genetic data, or sex life or sexual orientation information.
Company may disclose the following categories of information for commercial purposes: Commercial Information; Demographic Data; Location Data; Identifiers; Inferences; and Internet activity. Company may use and/or partner with different types of entities to assist with our daily operations and manage our Sites.
- Right to Know and Delete. If you are a California resident, you may have the right to know certain information about our data practices in the preceding 12 months. You may request the following from us:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information was collected;
- The categories of Personal Information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the Personal Information was disclosed or sold;
- The business or commercial purpose for collecting or selling the Personal Information; and
- The specific pieces of Personal Information we have collected about you.
- In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and we may have legal grounds for keeping such data.
To exercise any of these rights, please submit a request to Company at email@example.com. In the request, please specify which right you are seeking to exercise and the scope of the request. Company will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity or determine that we are not bound by law to respond to your request(s), we may deny your request(s).
- Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
- Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you choose to exercise any of your rights.
- Shine the Light. Site users who are residents of California may request: (i) a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information. To submit a request, please contact us at firstname.lastname@example.org. Requests must include “California Shine the Light Request” in the subject line and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and if we determine that we are not bound by law to respond to your request(s), we may deny your request(s). Please note that Company is not required to respond to requests made by means other than through the provided email address or mail address (below). We may decline to process any requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by law. We may also decline aspects of deletion or data access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes.
10. NOTICE TO EUROPEAN UNION USERS
You may have a right under GDPR to: (i) withdraw consent; (ii) request your Personal Information previously collected by Company; or (iii) pause any data processing relating to your Personal Information in the event you object to it. If you are subject to GDPR and would like to exercise any of the options listed in this section, please contact Company at email@example.com.
11. CHILDREN UNDER THE AGE OF 18
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), as amended. Company does not sell products or services for purchase by children, and the Sites are intended for adult use only. If you are under 18, you may not use Company services and/or products without the written consent of a parent or guardian. Company does not knowingly collect personal information from children under the age of 13. Similarly, Company complies with the provisions in GDPR regarding privacy of children and does not solicit information of any kind from children under 16 in jurisdictions subject to GDPR.
It is possible that by fraud or deception we may receive information pertaining to children under 13, or equivalent minimum age depending on jurisdiction (under 16 in the case of jurisdictions subject to GDPR, for example). If we are notified of this, as soon as we verify the information, we will immediately delete the information from our servers. If you want to notify us of our unauthorized receipt of information by children under 13, or equivalent minimum age depending on jurisdiction, please do so by sending an email to Company via firstname.lastname@example.org.
14. TERMS & CONDITIONS
Read Company’s full terms and conditions of service at https://myhavo.com/terms-conditions.
15. CONTACT US