Privacy Policy

Updated: 14/05/2023

Introduction

We (“we” or “us”) care about the privacy of users (the “user” or “you”) of our website and/or mobile space (the “Site” and “Mobile Space,” respectively) and are committed to protecting the information that users share with us while using our Site and/or Mobile Space (collectively, the “Digital Properties”), and we are fully committed to protecting and using your information in accordance with applicable law.

This Privacy Policy describes our practices for collecting, using and disclosing your information through our digital properties (the “Services”), when you access the Services from your device.

Before accessing or using any of our Services, please read this Privacy Policy carefully and make sure you fully understand our practices regarding your information. If you have read and fully understand this Privacy Policy, and remain opposed to our practices, you should immediately cease all use of our Digital Properties and Services. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your acceptance of this Privacy Policy and any amendments thereto.

In this Privacy Policy, you will find explanations of the following issues:

• The information we collect

• How we collect information

• Why we collect information

• With whom we share information

• Where the information is stored

• How long the information is kept

• How we protect information

• Minors

• Changes or Updates to the Privacy Policy

The information we collect

Below are the different types of information we may collect.

• Non-personally identifiable information, which may be provided by you during the registration process or collected when you use our Services (“Non-Personal Information”). Non-personal information does not allow us to identify the person from whom it was collected. The non-personal Information we collect consists primarily of technical information and aggregate usage information.

• Individually identifiable information, that is, information that identifies you or can, with reasonable effort, identify you (“Personal Information”). The Personal Information we collect through our Services includes name, email address, address, phone number, IP address, or other information requested whenever necessary. If we combine Personal Information with non-personal Information, we will treat the combined information as Personal Information for as long as it remains combined.

How we collect information

Below are the main methods we use to collect information:

• We collect information when you use the Services. When you visit our Digital Properties or use our Services, we may collect and record such usage, sessions and related information.

• We collect information that you voluntarily provide to us. For example, we collect the information you provide when you contact us directly through any communication channel (e.g., when you send us an e-mail containing a comment or feedback).

• We may collect information from third party sources as described below.

• We collect the information you provide if you connect to our Services through third-party services such as Facebook or Google.

Why we collect information

We use your Personal Information for the following purposes:

• To provide and operate the Services

• To develop, customize and improve our Services

• To respond to your feedback, requests and queries and to provide you with assistance

• To analyze demand and usage patterns

• For other internal, research or statistical purposes

• To strengthen our data security and fraud prevention capabilities

• To investigate possible violations, enforce our terms or policies, or comply with any applicable law, regulation or governmental authority.

• To send you updates, notices, promotional materials and other information regarding our Services. If we send you promotional emails, you can choose to no longer receive them by clicking on the unsubscribe link in the email.

With whom we share information

We may share your information with our service providers in order to operate our Services (e.g., storing information on third party hosting services, providing our technical support, etc.).

We may also disclose your information in the following circumstances: (i) to investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, or safety issues; (ii) to establish or exercise our rights to defend against legal claims; (iii) to protect our rights, property or personal safety and those of our users or the general public; (iv) if we or any of our affiliates undergo a change in control, including through a merger, acquisition or purchase of all or substantially all of our assets; (v) to collect, hold and/or manage your information through our authorized third-party service providers (e.g., online service companies), to the extent reasonable for business purposes; or (vi) to cooperate with third parties to improve your experience. For the avoidance of doubt, we may transfer and disclose to third parties or otherwise use Non-Personal Information in our sole discretion.

Please note that our Services allow you to participate in certain social activities such as posting content, information or comments, as well as following and chatting with other users. Please be aware that the content or information you provide in these areas can be read, collected and used by others who have access to it. We do not recommend that you upload or share any information that you do not wish to make public. If you post content to our Digital Properties or otherwise provide it in connection with the use of a Service, you do so at your own risk. We cannot control the actions of other users or members of the public who may access your information and content. You understand and acknowledge that, even after removal by you or us, copies of your information may remain visible on archived or cached pages, or that a third party may have copied or stored such content.

Cookies and similar technologies

When you visit or access our Service, we allow certain third parties to use web beacons, cookies, web beacons, scripts, tags, and other analysis technologies and services (“Tracking Technologies”). These Tracking Technologies may allow third parties to automatically collect information about you in order to improve the way you browse our Digital Properties, to improve the performance of our Digital Properties and to personalize your experience on our Digital Properties, and for security and fraud prevention purposes.

For more information, see our Cookie Policy.

We will not share your email address, or any other Personal Information, with online advertising companies or ad networks without your consent.

Personal information

Personal Information may be retained, processed and stored in the United States of America, Ireland, Japan, Israel and other jurisdictions as necessary for the proper provision of our services and/or as required by law (as further explained below).

How long the information is kept:

Please note that we retain the information we collect for as long as necessary to provide the Services and to comply with our legal or contractual obligations to you, resolve disputes and enforce our agreements.

We may correct, supplement or delete incomplete or inaccurate information at any time at our sole discretion.

How our host protects information:

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The hosting service for our Digital Properties provides us with the online platform that allows us to provide the Service to you. Your data may be stored through our hosting provider’s data storage, database or general applications. It stores your information on secure servers behind a firewall and offers secure HTTPS access to most of its services

Minors

The Services are not intended for use by minors. We do not deliberately collect information from children. If you are under the age of majority, you must not download or use the Services or provide us with any information

We reserve the right to request proof of age at any time to ensure that minors do not use our Services. If we learn that someone under the age of majority is using our Services, we may prohibit and block that user’s access to our Services, as well as delete all information stored with us about that user. If you have reason to believe that a minor has shared information with us, please contact us as indicated below.

We will only use your personal information for the purposes set out in this Privacy Policy, if:

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• Use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (for example, to provide you with the Services or to provide you with customer or technical support)

• We need to use your Personal Information to comply with a relevant legal or regulatory obligation

• It is necessary for us to use your Personal Information for our legitimate business interests, provided that such use is at all times proportionate and respects your privacy rights.

If you live in the EU, you can :

• Request confirmation of whether or not Personal Information about you is being processed, and access to the Personal Information we store about you, as well as certain additional information

• Request to receive Personal Information that you voluntarily provide directly to us in a structured, commonly used and machine-readable format

• Request correction of your Personal Information under our control

• Request the deletion of your Personal Information

• To object to the processing of personal data by us

• Requesting that we limit the processing of your Personal Information

• File a complaint with a supervisory authority

However, please note that these rights are not absolute and may be subject to our own legitimate interests or regulatory requirements. If you have general questions about the Personal Information we collect and how we use it, please contact us as set forth below.

In the course of providing the Services to our users, we may transfer information to affiliated entities or other third parties across the borders of your country or jurisdiction to other countries or jurisdictions around the world. By using the Services, you consent to the transfer of your information outside the EEA.

If you are located in the EEA, your Personal Information may only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection is in place to safeguard the Personal Information. We will take reasonable steps to ensure that we have appropriate contractual arrangements with our third parties to ensure that adequate safeguards are in place so that the risks of unlawful use, alteration, deletion, loss or theft of your Personal Information are minimized, and that such third parties act at all times in compliance with applicable laws.

CCPA rights regarding your information

If you are a California resident using the Services, the California Consumer Privacy Protection Act (the “CCPA”) may give you the right to request access to and deletion of your information.

To exercise your right to access and delete your information, please contact us as indicated below.

Users of the Services who are California residents and under the age of 18 may request and obtain removal of any content they have posted by emailing us at the address listed below in the “Contact Us” section. Any such request should be marked “California Removal Request” in your email. Any request must provide a description of the content you wish to remove and information reasonably sufficient to permit us to locate that content. We reject all California Removal Requests that are not properly marked or submitted, and we may not be able to respond if you do not provide adequate information. Please note that your request does not guarantee a complete or comprehensive removal of the content in question. For example, documents you have published can be republished by another user or a third party.

Changes or Updates to the Privacy Policy

We may revise this Privacy Policy from time to time, at our sole discretion, and the most current version will always be posted on our website (as indicated in the “Last Revised” section). We encourage you to review this Privacy Policy regularly for any changes. In the event of significant changes, we will post a notice on our website to announce these changes. Your continued use of the Services following notification of changes on our website will constitute your acknowledgement of, and consent to, such changes in the Privacy Policy and your agreement to be bound by the terms of such changes.

Contact us

If you have any general questions about the Services or the information we collect about you, or how we use it, please contact us:

Grand Duchy of Luxembourg

Name: HUMENTLA SARL-S
Address: 29, bd Prince Henri, L-1734 Luxembourg
Autorisation number: 10106818/0