Privacy Policy
Effective Date: July 31, 2024
This uHoo Privacy Policy applies to uHoo Pte. Ltd. and its subsidiaries and affiliates (collectively “uHoo”, “Company”, “we”, “our” or “us”). It represents our commitment to treat information with utmost care, transparency and confidentiality in compliance with relevant and applicable data privacy laws and regulations, and with constantly changing commercially acceptable standards for data protection (collectively, the “law”). This Privacy Policy only covers the information that uHoo collects, uses, stores, processes and shares. It does not explain what third parties do with any information they may collect about you separately from uHoo. This policy also does not cover any websites, platforms, products, or services provided by others. We encourage you to review the privacy policies or notices of those third parties for information about their practices and we hope you will take some time to read this Privacy Policy.
When you use our website, application or platform (“Platform”), as the case may be, and more generally, use any of our products and services (the “Products and Services”), we appreciate that you trust us with your personal information. We take your privacy very seriously. In this Privacy Policy (“Policy”), 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 Policy that you do not agree with, please discontinue use of our Products and Services immediately.
With this policy, we present transparently that we gather, process, store and use the data of persons fairly and in accordance with law. As part of our drive to serve you better, we need to obtain and process your information. uHoo collects or processes this information only with the full knowledge, cooperation and consent of interested parties.
Your data will be kept up-to-date, collected or processed fairly and for lawful purposes only. The information you give us will be processed within legal boundaries and will be protected against any unauthorized or illegal access by internal or external parties. You are free to exercise your rights under the law as a data subject and we fully respect the same.
Your data will not be distributed to any party other than the ones consented and agreed by you or the data’s owner (exempting those compellable to be disclosed by law and legitimate requests from courts of competent jurisdiction and law enforcement authorities). Without such express consent from you or the data owner, it will not be communicated or transferred, informally or in any manner, to any other person, entity, organization or country.
We also allow you to modify, erase, reduce or correct data contained in our databases in line with your rights under the law. We will have provisions in cases of lost or corrupted data.
For protection, our officers and employees will be trained in online privacy and data security and will establish data protection practices (secure locks, data encryption, access authorization, etc.). In addition, security measures will be built through a secure network to protect data from cyber attacks.
We may change this Policy from time to time without any advance notice. You are strongly recommended to regularly review and read this Policy. Any changes in this Policy will be effective immediately upon posting in the Platform, with an updated effective date. In case of any inconsistency with any other policy of uHoo regarding data, information and system security measures, this Policy will govern.
This Policy applies to all information collected through our Products and Services, as well as any related services, sales, marketing or events. Your privacy is important to us, and we take it very seriously. The Policy exists to keep you informed as it is incorporated into and made a part of uHoo’s Terms of Use in the course of providing the Products and Services or access to the Platform to you.
Please read this Policy carefully as it will help you understand what we do with the information that we collect. Thank you for using uHoo!
TABLE OF CONTENTS
- WHY DO WE COLLECT YOUR INFORMATION?
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE AND EXERCISE YOUR DATA PRIVACY RIGHTS?
- YOUR ACKNOWLEDGMENT AND CONSENT
1. WHY DO WE COLLECT YOUR INFORMATION?
In Short: We collect your information to enable us to provide our Products and Services to you.
We are a company duly organized and existing under the laws of the Republic of Singapore. Subject to our Terms of Use, we will need to collect your personal information to the extent needed for you to access and for us to provide to you our Products and Services.
In Short: We collect your information to enable us to provide our Products and Services to you.
We are a company duly organized and existing under the laws of the Republic of Singapore. Subject to our Terms of Use, we will need to collect your personal information to the extent needed for you to access and for us to provide to you our Products and Services.
2. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect information that you provide to us.
We ask for and collect the following types of information when you use the Platform and our Products and Services. Without it, we may not be able to provide you with our services.
- Account Registration Information - When you create an account on our Platform, you voluntarily provide your first name, last name, email address, password, and time zone. You may also voluntarily indicate your birthday and gender to allow us to provide you with a more personalized experience on our Platform. Without your consent, we will not use your personal information for any purpose other than as stated in this Policy.
- Set-up Information - When you set-up your uHoo device, you voluntarily provide its time zone. This ensures that you are able to accurately view all your current and historical air quality measurements and data based on the local time they have occurred.
- Transaction Information - If you purchase our Products and Services on our Platform, you provide your transaction information, particularly your first name, last name, e-mail address, phone, billing address, delivery address, credit card number, card expiration date, and card security code. We do not store transaction information on our databases, servers, and systems. We store your delivery address, which you provide, solely for the purpose to fulfill your order.
- Device Information - When your device syncs with our Platform, air quality data recorded on your device is transferred from your device to our databases. This allows you to access all your current and historical air quality measurements and data to see how your habits and activities affect your indoor environment.
- Activity Information - When you access our Platform, we receive activity information about your usage, viewing, and preferences, including your browser or device type, related to the Platform.
- Cookie Data - When you visit our Platform, we use cookies to help us remember your settings and preferences to provide you with a more seamless experience on the Platform. We also use third party analytics tools to track and measure site usage. This allows us to continue producing engaging content, improve the Platform based on our understanding of your usage, and to make advertisements more relevant to you.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. We shall have the right to request for documentation to verify the personal information provided by you as part of our user verification processes. During the course of your use of the Platform and the provision of the Products and Services, you expressly consent to the transfer of your personal information from third parties to the Company for the purposes set out in this Privacy Policy or any other terms.
We collect information you provide when you register an account on our Platform, set-up your uHoo device, purchase our Products and Services from our Platform, and voluntarily input information on your uHoo account. We collect information by receiving it upon your usage of our Platform and the uHoo device. We also collect information by use of cookies and third party analytics tools. We will only be able to collect your personal information if you voluntarily submit the same to us or as otherwise provided for under this Policy. Unfortunately, if you choose not to submit your personal information to us or subsequently withdraw your consent in connection with our use of your personal information, we may not be able to provide you with the Products and Services or access to our Platform.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
To the extent permitted by law, in order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. When collecting information from third-party sources, uHoo ensures that the third-party provider has secured the users’ or your consent to the sharing of their data for marketing purposes.
Personal information you disclose to us
In Short: We collect information that you provide to us.
We ask for and collect the following types of information when you use the Platform and our Products and Services. Without it, we may not be able to provide you with our services.
- Account Registration Information - When you create an account on our Platform, you voluntarily provide your first name, last name, email address, password, and time zone. You may also voluntarily indicate your birthday and gender to allow us to provide you with a more personalized experience on our Platform. Without your consent, we will not use your personal information for any purpose other than as stated in this Policy.
- Set-up Information - When you set-up your uHoo device, you voluntarily provide its time zone. This ensures that you are able to accurately view all your current and historical air quality measurements and data based on the local time they have occurred.
- Transaction Information - If you purchase our Products and Services on our Platform, you provide your transaction information, particularly your first name, last name, e-mail address, phone, billing address, delivery address, credit card number, card expiration date, and card security code. We do not store transaction information on our databases, servers, and systems. We store your delivery address, which you provide, solely for the purpose to fulfill your order.
- Device Information - When your device syncs with our Platform, air quality data recorded on your device is transferred from your device to our databases. This allows you to access all your current and historical air quality measurements and data to see how your habits and activities affect your indoor environment.
- Activity Information - When you access our Platform, we receive activity information about your usage, viewing, and preferences, including your browser or device type, related to the Platform.
- Cookie Data - When you visit our Platform, we use cookies to help us remember your settings and preferences to provide you with a more seamless experience on the Platform. We also use third party analytics tools to track and measure site usage. This allows us to continue producing engaging content, improve the Platform based on our understanding of your usage, and to make advertisements more relevant to you.
We collect information you provide when you register an account on our Platform, set-up your uHoo device, purchase our Products and Services from our Platform, and voluntarily input information on your uHoo account. We collect information by receiving it upon your usage of our Platform and the uHoo device. We also collect information by use of cookies and third party analytics tools. We will only be able to collect your personal information if you voluntarily submit the same to us or as otherwise provided for under this Policy. Unfortunately, if you choose not to submit your personal information to us or subsequently withdraw your consent in connection with our use of your personal information, we may not be able to provide you with the Products and Services or access to our Platform.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
To the extent permitted by law, in order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. When collecting information from third-party sources, uHoo ensures that the third-party provider has secured the users’ or your consent to the sharing of their data for marketing purposes.
3. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or for other purposes with your consent.
We use personal information for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.
We use the information we collect or receive:
- To provide, maintain, and improve our Platform and Products and Services – We use the information we collect to allow you to access and personalize the Platform, to measure your current and historical air quality measurements and data, and to provide customer support; to aggregate and anonymize air quality measurements for industry and market analysis, geographic profiling, marketing and advertising, and other business purposes; and to improve the Platform to troubleshoot and protect against errors, perform analytics, conduct research, and develop new features. We use cookies to provide you with a convenient user experience on our website as discussed in the Cookie Data subsection above. The information and data are processed and stored in our operating offices, databases, and servers located around the world.
- To promote safety and security – We use the information we collect to verify and authenticate information you have provided, detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, respond to legal requests or claims, conduct audits and risk assessments, and enforce our terms and policies.
- To communicate with you – We use the information we collect to respond to your emails, and to send you service messages, updates, security alerts, and account notification when you log on to your uHoo account and use our Platform. We also use this information to respond to and manage your queries, feedback, claims, disputes, troubleshoot problems, or product and customer service requests, whether directly or through customer service team. With your consent, we will send you marketing materials (such as news, special offers and general information about our Products and Services and events which we offer) to the email associated with your uHoo account. If you wish to stop receiving marketing materials at any time, please click “Unsubscribe” at the bottom of each email.
- To comply with our legal obligations and performance of our contract with you pursuant to any purchase you make with respect to our Products and Services or of any other contract you have with us
- Other purposes – We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products and Service, marketing, and your experience.
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or for other purposes with your consent.
We use personal information for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.
We use the information we collect or receive:
- To provide, maintain, and improve our Platform and Products and Services – We use the information we collect to allow you to access and personalize the Platform, to measure your current and historical air quality measurements and data, and to provide customer support; to aggregate and anonymize air quality measurements for industry and market analysis, geographic profiling, marketing and advertising, and other business purposes; and to improve the Platform to troubleshoot and protect against errors, perform analytics, conduct research, and develop new features. We use cookies to provide you with a convenient user experience on our website as discussed in the Cookie Data subsection above. The information and data are processed and stored in our operating offices, databases, and servers located around the world.
- To promote safety and security – We use the information we collect to verify and authenticate information you have provided, detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, respond to legal requests or claims, conduct audits and risk assessments, and enforce our terms and policies.
- To communicate with you – We use the information we collect to respond to your emails, and to send you service messages, updates, security alerts, and account notification when you log on to your uHoo account and use our Platform. We also use this information to respond to and manage your queries, feedback, claims, disputes, troubleshoot problems, or product and customer service requests, whether directly or through customer service team. With your consent, we will send you marketing materials (such as news, special offers and general information about our Products and Services and events which we offer) to the email associated with your uHoo account. If you wish to stop receiving marketing materials at any time, please click “Unsubscribe” at the bottom of each email.
- To comply with our legal obligations and performance of our contract with you pursuant to any purchase you make with respect to our Products and Services or of any other contract you have with us
- Other purposes – We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products and Service, marketing, and your experience.
4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
uHoo acknowledges its role and responsibilities under the law, subject to the provisions of this Policy. You consent to our outsourcing of our data processing activities within and among uHoo and its subsidiaries and affiliates. We may share, transfer, disclose, and/or permit the sharing of your information with our service providers, business partners and affiliates which include our parent company and any subsidiaries, joint venture partners, or other companies controlled by us or under common control with us, in order to provide our Products and Services and to facilitate your use thereof, to complete a transaction with you, to manage your account and our relationship with you, to enhance fraud protection, to reduce credit risk, to facilitate marketing and promotions, and to fulfill any legal or regulatory requirements and requests as deemed necessary by us.
We may also process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your personal information when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract, including third party data processors necessary to perform such contractual services (i.e. cloud providers).
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), or to assert legal rights or defend against legal claims; or to prevent, detect, investigate, or otherwise address illegal activity, fraud, abuse, violations of our terms, or threats to security to the Platform, or of any person.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Furthermore, when you use your uHoo account, you can authorize us to share your current and historical air quality measurements and data with third parties. When you order our Products and Services, we share your delivery address to third party companies who perform package delivery services on our behalf solely for the purposes requested by us or required by law. We may also share aggregated and anonymized information on air quality measurements for industry and market analysis, geographic profiling, marketing and advertising, and other business purposes.
Any data transfer/sharing to outside parties will be covered by a Data Sharing/Outsourcing Agreement, when applicable. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitation or requests. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
In sharing your personal information with them, we endeavor to ensure that the third parties and our affiliates keep your personal information secure from unauthorized access, collection, use, disclosure, processing, or similar risks and that your personal information be retained only for as long as needed in order to achieve the abovementioned purposes.
Your consent to this Privacy Policy followed by your submission of such information represents your consent to such transfer. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your personal information. We may transfer or permit the transfer of your personal information outside of your country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction or for any of the purposes set out in this Privacy Policy.
Moreover, as we take industry accepted best practices and reasonable steps to safeguard your personal information, you acknowledge and agree that the Company has the right to disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities, or the relevant right owners, if the Company has reasonable grounds to believe that the disclosure is necessary for the purpose of meeting any obligations, requirements, or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, investigation, and/or request of any nature made by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against the Company for the disclosure of your personal information in these circumstances.
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
uHoo acknowledges its role and responsibilities under the law, subject to the provisions of this Policy. You consent to our outsourcing of our data processing activities within and among uHoo and its subsidiaries and affiliates. We may share, transfer, disclose, and/or permit the sharing of your information with our service providers, business partners and affiliates which include our parent company and any subsidiaries, joint venture partners, or other companies controlled by us or under common control with us, in order to provide our Products and Services and to facilitate your use thereof, to complete a transaction with you, to manage your account and our relationship with you, to enhance fraud protection, to reduce credit risk, to facilitate marketing and promotions, and to fulfill any legal or regulatory requirements and requests as deemed necessary by us.
We may also process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your personal information when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract, including third party data processors necessary to perform such contractual services (i.e. cloud providers).
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), or to assert legal rights or defend against legal claims; or to prevent, detect, investigate, or otherwise address illegal activity, fraud, abuse, violations of our terms, or threats to security to the Platform, or of any person.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Furthermore, when you use your uHoo account, you can authorize us to share your current and historical air quality measurements and data with third parties. When you order our Products and Services, we share your delivery address to third party companies who perform package delivery services on our behalf solely for the purposes requested by us or required by law. We may also share aggregated and anonymized information on air quality measurements for industry and market analysis, geographic profiling, marketing and advertising, and other business purposes.
Any data transfer/sharing to outside parties will be covered by a Data Sharing/Outsourcing Agreement, when applicable. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitation or requests. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
In sharing your personal information with them, we endeavor to ensure that the third parties and our affiliates keep your personal information secure from unauthorized access, collection, use, disclosure, processing, or similar risks and that your personal information be retained only for as long as needed in order to achieve the abovementioned purposes.
Your consent to this Privacy Policy followed by your submission of such information represents your consent to such transfer. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your personal information. We may transfer or permit the transfer of your personal information outside of your country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction or for any of the purposes set out in this Privacy Policy.
Moreover, as we take industry accepted best practices and reasonable steps to safeguard your personal information, you acknowledge and agree that the Company has the right to disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities, or the relevant right owners, if the Company has reasonable grounds to believe that the disclosure is necessary for the purpose of meeting any obligations, requirements, or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, investigation, and/or request of any nature made by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against the Company for the disclosure of your personal information in these circumstances.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We collect your information to enable us to provide our Products and Services to you.
We will only keep your personal information for as long as it is necessary for a legitimate business purpose or for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, anti-money laundering or other legal requirements).
We shall cease to retain your personal information or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal information was collected and is no longer necessary for any legal or business purpose. When we have no ongoing legitimate business need to process your personal information, we will either irreversibly delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
You understand that you are, at any time, free to unsubscribe, delete your uHoo account, uninstall our Platform, and/or submit an official request for deletion of your data, subject to this Policy. Should you wish to have your personal information deleted and destroyed or you wish to revoke or withdraw your consent in the processing or storing of your personal information, you may do so by contacting us, and we shall comply by doing the necessary deletion or anonymization.
The deletion or anonymization of your personal data shall be honored within a reasonable time from request and as long as it will not compromise, damage, injure, or make inefficient the entirety, integrity, confidentiality, and security of our Platform, and shall be performed within such reasonable time from the time of your request to do so.
In Short: We collect your information to enable us to provide our Products and Services to you.
We will only keep your personal information for as long as it is necessary for a legitimate business purpose or for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, anti-money laundering or other legal requirements).
We shall cease to retain your personal information or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal information was collected and is no longer necessary for any legal or business purpose. When we have no ongoing legitimate business need to process your personal information, we will either irreversibly delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
You understand that you are, at any time, free to unsubscribe, delete your uHoo account, uninstall our Platform, and/or submit an official request for deletion of your data, subject to this Policy. Should you wish to have your personal information deleted and destroyed or you wish to revoke or withdraw your consent in the processing or storing of your personal information, you may do so by contacting us, and we shall comply by doing the necessary deletion or anonymization.
The deletion or anonymization of your personal data shall be honored within a reasonable time from request and as long as it will not compromise, damage, injure, or make inefficient the entirety, integrity, confidentiality, and security of our Platform, and shall be performed within such reasonable time from the time of your request to do so.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of physical, organizational, and technical security measures.
We have implemented appropriate physical, technical, and organizational security measures designed to protect the security of any personal information we process subject to the requirements of the law and of commercially acceptable standards for data protection.
We develop and implement measures to ensure that all uHoo personnel who have access to any personal information will strictly process such data in compliance with applicable laws and regulations. These measures may include drafting new or updated relevant policies of uHoo and conducting or sponsoring training programs to educate our stockholders, directors, officers, employees, agents and other interested parties on data privacy related concerns. A continuing obligation of confidentiality is also imposed on our stockholders, directors, officers, employees, agents or other interested parties in connection with such personal information that they may encounter during the period of which they are such with uHoo. This obligation will still apply after they cease to work with uHoo for whatever reason.
Furthermore, we will review security policies, conduct vulnerability assessments and perform penetration testing, as applicable, within uHoo on a regular schedule prescribed by our IT Team.
Our IT team will continuously evaluate this Privacy Policy, considering the following:
- Safeguards to protect uHoo computer network and systems against accidental, unlawful, or unauthorized usage, any interference which will affect data integrity or hinder the functioning or availability of the system, and unauthorized access;
- Our ability to ensure and maintain the confidentiality, integrity, availability, and resilience of uHoo data processing systems and services;
- Regular monitoring for security breaches, and a process for identifying and accessing reasonably foreseeable vulnerabilities in uHoo computer network and systems, and taking preventive and corrective actions against security incidents;
- Our ability to restore the availability and access to personal information in a timely manner in the event of a security incident;
- A process for regularly testing and evaluating effectiveness of security measures; and
- Encryption of personal information during storage and while in transit, authentication process, and other technical security measures that control and limit access thereto.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
In Short: We aim to protect your personal information through a system of physical, organizational, and technical security measures.
We have implemented appropriate physical, technical, and organizational security measures designed to protect the security of any personal information we process subject to the requirements of the law and of commercially acceptable standards for data protection.
We develop and implement measures to ensure that all uHoo personnel who have access to any personal information will strictly process such data in compliance with applicable laws and regulations. These measures may include drafting new or updated relevant policies of uHoo and conducting or sponsoring training programs to educate our stockholders, directors, officers, employees, agents and other interested parties on data privacy related concerns. A continuing obligation of confidentiality is also imposed on our stockholders, directors, officers, employees, agents or other interested parties in connection with such personal information that they may encounter during the period of which they are such with uHoo. This obligation will still apply after they cease to work with uHoo for whatever reason.
Furthermore, we will review security policies, conduct vulnerability assessments and perform penetration testing, as applicable, within uHoo on a regular schedule prescribed by our IT Team.
Our IT team will continuously evaluate this Privacy Policy, considering the following:
- Safeguards to protect uHoo computer network and systems against accidental, unlawful, or unauthorized usage, any interference which will affect data integrity or hinder the functioning or availability of the system, and unauthorized access;
- Our ability to ensure and maintain the confidentiality, integrity, availability, and resilience of uHoo data processing systems and services;
- Regular monitoring for security breaches, and a process for identifying and accessing reasonably foreseeable vulnerabilities in uHoo computer network and systems, and taking preventive and corrective actions against security incidents;
- Our ability to restore the availability and access to personal information in a timely manner in the event of a security incident;
- A process for regularly testing and evaluating effectiveness of security measures; and
- Encryption of personal information during storage and while in transit, authentication process, and other technical security measures that control and limit access thereto.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
7. DO WE COLLECT INFORMATION FROM CHILDREN?
In Short: We do not knowingly collect data from or market to children under 13 years of age.
Children under the age of 13, or any higher minimum age in the jurisdiction where the child resides, are not allowed to use our Platform. We do not knowingly solicit data from or market to such children. By using the Platform, you represent that you are at least 13 years old or that you are the parent or guardian of such a child and consent to such child’s use of the Platform. You also confirm and warrant that you are capable of understanding and accepting the terms of this Policy. If we learn that personal information from users less than 13 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 13, please contact us. Parents or guardians who believe that their child has provided us with personal information and would like to have it deleted, please contact us as well.
The Company shall not be responsible for any unauthorized use of the Products and Services or the Platform by yourself, users who act on your behalf, or any unauthorized users. It is your responsibility to make your own informed decisions about the use of the Products and Services or the Platform and take the necessary steps to prevent any misuse.
In Short: We do not knowingly collect data from or market to children under 13 years of age.
Children under the age of 13, or any higher minimum age in the jurisdiction where the child resides, are not allowed to use our Platform. We do not knowingly solicit data from or market to such children. By using the Platform, you represent that you are at least 13 years old or that you are the parent or guardian of such a child and consent to such child’s use of the Platform. You also confirm and warrant that you are capable of understanding and accepting the terms of this Policy. If we learn that personal information from users less than 13 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 13, please contact us. Parents or guardians who believe that their child has provided us with personal information and would like to have it deleted, please contact us as well.
The Company shall not be responsible for any unauthorized use of the Products and Services or the Platform by yourself, users who act on your behalf, or any unauthorized users. It is your responsibility to make your own informed decisions about the use of the Products and Services or the Platform and take the necessary steps to prevent any misuse.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may access, modify, review, change, or terminate your account, including your personal information given during account creation, at any time.
Under the law, you are entitled to the following data privacy rights:
- the right to be informed whether your personal information shall be, are being, or have been processed;
- the right to object to the processing of your personal information;
- the right to reasonably access your personal information;
- the right to modify or to dispute the inaccuracy or error in your personal information and have us correct it immediately and accordingly;
- the right to suspend, withdraw, or order the blocking, removal or destruction of your personal information from our records (including the right to delete your uHoo account);
- the right to file a complaint with the proper government authorities for any violation of your data privacy rights;
- the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information;
- the right to data portability of your personal information; and
- the right to be informed whether personal information is being or has been processed. This includes processing through automated processing, automated decision-making and profiling.
In respecting your data privacy rights, you may opt to tell us:
- not to share your information with our subsidiaries and affiliates or with other companies that we have business with; provided that such information is not critical nor required by applicable laws and regulations in maintaining the Products and Services that you availed with us;
- to provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the relevant jurisdictions where uHoo operates by certain laws and regulations;
- to update your personal information; and
- about your other concerns relating to how we collect, use, share, protect or dispose your information.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may contact us using the contact information provided below in this Policy.
In Short: You may access, modify, review, change, or terminate your account, including your personal information given during account creation, at any time.
Under the law, you are entitled to the following data privacy rights:
- the right to be informed whether your personal information shall be, are being, or have been processed;
- the right to object to the processing of your personal information;
- the right to reasonably access your personal information;
- the right to modify or to dispute the inaccuracy or error in your personal information and have us correct it immediately and accordingly;
- the right to suspend, withdraw, or order the blocking, removal or destruction of your personal information from our records (including the right to delete your uHoo account);
- the right to file a complaint with the proper government authorities for any violation of your data privacy rights;
- the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information;
- the right to data portability of your personal information; and
- the right to be informed whether personal information is being or has been processed. This includes processing through automated processing, automated decision-making and profiling.
In respecting your data privacy rights, you may opt to tell us:
- not to share your information with our subsidiaries and affiliates or with other companies that we have business with; provided that such information is not critical nor required by applicable laws and regulations in maintaining the Products and Services that you availed with us;
- to provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the relevant jurisdictions where uHoo operates by certain laws and regulations;
- to update your personal information; and
- about your other concerns relating to how we collect, use, share, protect or dispose your information.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may contact us using the contact information provided below in this Policy.
9. CONTROLS FOR DO-NOT-TRACK FEATURES AND COOKIES
We or our authorized service providers use cookies, web beacons, and other similar technologies and similar tracking technologies to track the activity on our Products and Services and store certain information to help provide you with a better, faster, safer, and personalized experience when you use our Products and Services or access our Platform.
When you visit our Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website. This data may include:
- your computer or device’s IP address;
- browser type;
- webpage you were visiting before you came to the Platform;
- the pages within the Platform which you visit; and
- the time spent on those pages, items and data searched for on the Platform, access times and dates, and other statistics.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.
We or our authorized service providers use cookies, web beacons, and other similar technologies and similar tracking technologies to track the activity on our Products and Services and store certain information to help provide you with a better, faster, safer, and personalized experience when you use our Products and Services or access our Platform. When you visit our Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website. This data may include:
- your computer or device’s IP address;
- browser type;
- webpage you were visiting before you came to the Platform;
- the pages within the Platform which you visit; and
- the time spent on those pages, items and data searched for on the Platform, access times and dates, and other statistics.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.
10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE AND EXERCISE YOUR DATA PRIVACY RIGHTS?
If you have questions or comments about this Policy, you may contact us by email at privacy@getuhoo.com. If you have any feedback, concerns, suggestions, or complaints or suggestions in relation to personal information, please feel free to contact us through the same email.
If you have questions or comments about this Policy, you may contact us by email at privacy@getuhoo.com. If you have any feedback, concerns, suggestions, or complaints or suggestions in relation to personal information, please feel free to contact us through the same email.
12. YOUR ACKNOWLEDGMENT AND CONSENT
In Short: Yes, you acknowledge and consent to our data processing activities as described in this Policy
By communicating with us using the Platform or our Products and Services, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and/or transfer of your personal information by us as described in this Policy.
From time to time, we may modify, update or amend this Policy by placing the updated Policy on our Platform. The effective date of such modifications, updates or amendments will be noted at the start of the Policy. You should therefore review it periodically so that you are up to date on our most current policies and practices. By continuing to communicate with us, by continuing to use our Platform and Products and Services or by your continued engagement with us following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments; provided, we shall secure your express consent only when so required by the law.
By submitting the required personal information to us, you consent to such collection, disclosure, processing and use thereof. You hereby expressly waive and release us from any and all liability, claims, causes of action or damages arising from our legitimate use of the submitted personal information.
In Short: Yes, you acknowledge and consent to our data processing activities as described in this Policy
By communicating with us using the Platform or our Products and Services, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and/or transfer of your personal information by us as described in this Policy.
From time to time, we may modify, update or amend this Policy by placing the updated Policy on our Platform. The effective date of such modifications, updates or amendments will be noted at the start of the Policy. You should therefore review it periodically so that you are up to date on our most current policies and practices. By continuing to communicate with us, by continuing to use our Platform and Products and Services or by your continued engagement with us following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments; provided, we shall secure your express consent only when so required by the law.
By submitting the required personal information to us, you consent to such collection, disclosure, processing and use thereof. You hereby expressly waive and release us from any and all liability, claims, causes of action or damages arising from our legitimate use of the submitted personal information.
