Effective Date: 02 October, 2018
Some of the Heed Companies are located outside the USA as well as outside of the European Economic Area. If you would like a list of relevant entities including locations, please send an email to .
For purposes of European data protection laws, the controller responsible for the described data collection and processing is Heed, LLC of 462 Seventh Avenue, 5th Floor, New York, NY 10018, USA.
INFORMATION WE MAY COLLECT FROM YOU
When you use the App, you may provide us with, and we may collect from you, information that relates to you, including your personal information.
You may provide us with your information in a number of ways, including:
o completing forms on the App (such as "Contact Us" forms);
o corresponding with us by e-mail, phone or otherwise;
o subscribing to email updates, newsletters or other subscriptions and features made available on the App from time to time;
o reporting a problem or requesting support for the App;
o creating an account and/or signing in to our App, including signing in using your social media account(s);
o communicating with us through third party social media websites or applications; and
o participating in our contests, promotions, sweepstakes, surveys or live voting features on the App.
The information you give us may include your name, address, e-mail address, phone number, date of birth and social media account details (such as Facebook and Twitter).
Information we automatically collect about you.
With regard to your use of the App, we may automatically collect the following behavioral and usage information:
o technical information, including IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform, device type, hardware model, MAC address, unique device identifiers and mobile network information;
o information about your visit, including the full URL clickstream to, through and from our App (including date and time);
o information about your network, such as information about devices, nodes, configurations, connection speeds, and network and application performance;
o pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may receive information about you (including your personal information) if you use any of the other websites or applications operated by the Heed Companies or the other services the Heed Companies provide. In this case we will inform you when we collect that information that it may be shared internally and combined with information collected on the App. We may also receive and display information and content which you make publically available on your social media account.
If you log in to or access the App using a third party social media platform, we will have access to certain information from that platform, such as your email address, friends list and profile information.
We also work closely with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers) and may receive information about you from them.
HOW WE USE YOUR INFORMATION
We may use information we have about you in the following ways:
Information you give to us. We may use this information to:
o help us respond to your queries;
o carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
o send you our newsletter, email updates and other subscriptions which we make available from time to time and which you subscribe to receiving;
o provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
o provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
o notify you about changes to our App and other services;
o ensure that content from our App is presented in the most effective manner for you and for your device;
o facilitate contests, promotions, sweepstakes, surveys or live voting features on the App;
o monitor and analyse trends, usage and activities in connection with the App; and
o comply with legal and regulatory requirements.
Information we collect about you. We may use this information:
o to administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
o to improve the App to ensure that content is presented in the most effective manner for you and for your computer;
o to allow you to participate in interactive features of the App, when you choose to do so;
o as part of our efforts to keep the App safe and secure;
o to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
o to monitor and analyse trends, usage and activities in connection with the App;
o to make suggestions and recommendations to you and other users of our App about goods or services that may interest you or them; and
o to provide or permit third parties to provide targeted advertising via websites you visit about goods or services that you may find interesting (see more on this in our Cookies Policy).
Information we receive from other sources.
o We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this combined information for the purposes set out above.
SHARING OF YOUR INFORMATION
We may share your personal information with any of the Heed Companies and with selected third parties including:
business partners, suppliers and sub-contractors
for the performance of any contract we enter into with them or you (a list of such
parties will be made available to you upon your request by sending an email to email@example.com);
business partners, suppliers and sub-contractors
to provide you with information about promotions and offers (a list of such
parties will be made available to you upon your request by sending an email to firstname.lastname@example.org);
to advertisers, advertising networks and social
networks that require the data to select and serve relevant adverts to you and others.
We may also use aggregate information to help advertisers reach the kind of
audience they want to target. We may make use of the personal information we
have collected from you to enable us to display our advertisers’ advertisement
to a target audience; and
o analytics and search engine providers that assist us in the improvement and optimization of the App.
We may disclose your personal information to other third parties:
in the event that we sell or buy any business or
assets, in which case we may disclose your personal information to the
prospective seller or buyer of such business or assets;
if the Heed Companies that control this App or
substantially all of its assets are acquired by a third party, in which case
personal information held by it about its customers will be one of the
if we are under a duty to disclose or share your
personal information in order to comply with any legal obligation, or in the
or other agreements, or to protect the rights, property, or safety of the Heed
Companies, our customers, clients or others; and
o to any other third party with your prior consent to do so.
SOCIAL SHARING FEATURES
The App may offer the option to share content items on external applications, services and/or social networks as installed by you or offered to you by the operating system and supported by your mobile device and operating system.
Your use of such sharing will also enable the sharing of information with your friends or the public, depending on the settings you establish with the entity through which you choose to share. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities through which you choose to share.
When using the App you may choose to accept notifications from us. You can opt in to receive mobile push notifications from us. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.
STORAGE AND TRANSFER OF INFORMATION
COOKIES & OTHER TRACKING TECHNOLOGIES
By using this App, you agree to respond truthfully and accurately about your age if asked. We do not knowingly collect information from children who are 14 years old or younger. If you are 14 years old or younger, you may not submit any personal information to us.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users of the App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request pursuant to California Civil Code Section 1798.83, please send an email to email@example.com.
YOUR EU AND OTHER PRIVACY RIGHTS
Where provided under applicable law, you may request a copy of the personal information about you that we hold, and you may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information, and request the blocking, deletion and portability of such information by contacting us at firstname.lastname@example.org. We may require you to prove your identity with approved identification if you request this information. Any access request may be subject to a fee to provide you with details of the personal information we hold about you.
You have the right, where provided under applicable law, to ask us not to process your personal information.
You have the right, where provided under applicable law, to be informed, to access to certain information, to be indemnified in certain cases, to data portability, and to ask us not to process your personal information for direct marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information or clicking "unsubscribe" on the emails you receive or by changing your settings on your device. You can also exercise the right at any time by contacting us at email@example.com.
Lawful bases for processing your personal data:
We process your personal data for the following reasons and on the following legal bases:
1. Contract: It is necessary for our performance of the contract you have agreed to enter with us to use the App. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
2. Legitimate Interests: We process your personal data if it is based on our ‘legitimate interests’. For example, in relation to general enquiries and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide effective and helpful customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section "Rights of data subjects" below to find out how.
3. Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section "Rights of data subjects" below to find out how.
4. Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).
Rights of data subjects:
You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):
3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services.
7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to an EU data protection authority.
Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy.
We will retain your personal information for as long as needed to provide you with any services which you request. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You may have the opportunity to receive certain communications from us related to the App. If you provide us with your email address in order to receive marketing communications, you can opt out at any time by using the unsubscribe links at the bottom of our emails.
Some mobile platforms support a “Do Not Track” feature, which is intended to be a signal to apps that you do not wish to be tracked. Certain legal obligations require that we disclose how the App reacts to Do Not Track signals. The App does not currently change the way it operates based upon detection of a Do Not Track or similar signal.
Please note that we cannot control how third-party websites or online services you visit through the App respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.
We have implemented commercially reasonable technical and organizational procedures and measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration or disclosure. However, the internet is an open system and we cannot and do not guarantee or warrant the security of any information that you transmit on or through the App or that we otherwise maintain.
LINKS TO THIRD PARTY WEBSITES
Our App, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of third parties, including our partner networks, advertisers and affiliates. Our provision of links to any third party sites are provided on an "as is" basis and the inclusion of any such link does not imply that we endorse, approve, or guarantee information, products, services, or recommendations provided at a third-party website. Since we may not always know when information on a linked site changes, we are not responsible for the content or accuracy of any third-party website. Heed shall not be responsible for any loss or damage of any sort resulting from the use of a link on its websites nor will it be liable for any failure of products or services advertised or provided on these linked sites. Your visit to any site or page from our App, newsletters, email updates or other communications via any such link is done entirely at your own risk.
CONTACT & DATA PROTECTION OFFICER
FIRST PRIVACY GmbH
28217 Bremen, Germany
Phone: +49 421 6966 32 0
Fax: +49 421 6966 32 11