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    Privacy Notice For California Residents 

    Last updated June 29, 2020

    Thank you for choosing to be part of our community at Hllo Friend, doing business as H_llo Friend (“H_llo Friend”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at friends@hllofriend.com.
    When you visit our website http://www.hllofriend.com (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
    By subscribing to H_llo Friend text notifications, you agree to receive automated marketing text messages from us about our products and services at the phone number you provided when you subscribed, and that the messages may be sent via automatic telephone dialing system or other technology. Message frequency is recurring. Consent is not a condition of purchase. Message and data rates may apply. Reply STOP, END, CANCEL, UNSUBSCRIBE or QUIT to opt-out and HELP for customer support. You may receive an additional text message confirming your decision to opt-out.  You understand and agree that attempting to opt-out by any means other than texting the opt-out commands above is not a reasonable means of opting out.
    This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing or events.
    Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

    DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

    California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

    If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).  

    CCPA Privacy Notice

    The California Code of Regulations defines a "resident" as:

    (1) every individual who is in the State of California for other than a temporary or transitory purpose and

    (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

    All other individuals are defined as "non-residents."

    If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.

    What categories of personal information do we collect?

    We have collected the following categories of personal information in the past twelve (12) months:

     

    Category

    Examples

    Collected

    A. Identifiers

    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name


    NO

    B. Personal information categories listed in the California Customer Records statute

    Name, contact information, education, employment, employment history and financial information


    YES

    C. Protected classification characteristics under California or federal law

    Gender and date of birth


    NO

    D. Commercial information

    Transaction information, purchase history, financial details and payment information


    NO

    E. Biometric information

    Fingerprints and voiceprints


    NO

    F. Internet or other similar network activity

    Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements


    NO

    G. Geolocation data

    Device location


    NO

    H. Audio, electronic, visual, thermal, olfactory, or similar information

    Images and audio, video or call recordings created in connection with our business activities


    NO

    I. Professional or employment-related information

    Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us


    NO

    J. Education Information

    Student records and directory information


    NO

    K. Inferences drawn from other personal information

    Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics


    NO

    We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels

    • Participation in customer surveys or contests; and

    • Facilitation in the delivery of our Services and to respond to your inquiries

    How do we use and share your personal information?

     

    More information about our data collection and sharing practices can be found in this privacy notice.

    You may contact us by email at friends@hllofriend.com, or by referring to the contact details at the bottom of this document.

    If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

    Will your information be shared with anyone else?

    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

    We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

    Hllo Friend has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Hllo Friend will not sell personal information in the future belonging to website visitors, users and other consumers.

    Your rights with respect to your personal data

     

    Right to request deletion of the data - Request to delete

     

    You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

     

    Right to be informed - Request to know

     

    Depending on the circumstances, you have a right to know:

    • whether we collect and use your personal information;
    • the categories of personal information that we collect;
    • the purposes for which the collected personal information is used;
    • whether we sell your personal information to third parties;
    • the categories of personal information that we sold or disclosed for a business purpose;
    • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
    • the business or commercial purpose for collecting or selling personal information.

    In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

     

    Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

     

    We will not discriminate against you if you exercise your privacy rights.

     

    Verification process

     

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

     

    We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

     

    Other privacy rights

    • you may object to the processing of your personal data
    • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
    • you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
    • you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

    To exercise these rights, you can contact us by email at friends@hllofriend.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

    Financial Incentives

    "Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information.

    The law permits financial incentives or a price or service difference if

    • a business has calculated a good-faith estimate of the value of the consumer's data that forms the basis for offering the financial incentive or price or service difference, and

    • if a description of the method the business used to calculate the value of the consumer's data.

    We may decide to offer a financial incentive (e.g. price or service difference) in exchange for the retention of sale or consumer's personal information.

    If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including categories of personal information that are implicated by the financial incentive or price or service difference.

    If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at friends@hllofriend.com, or by referring to the contact details at the bottom of this document.

    Let’s Be Friends