This privacy notice for Hulepay Inc ("Company," "we," "us," or "our"), describes how and
why we might collect, store, use, and/or share ("process") your information when you
use our services ("Services"), such as when you:
Visit our website at https://hulepay.com, or any website of ours that links to this
privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and practices, please do
not use our Services. If you still have any questions or concerns, please contact us at
contact@hulepay.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice.
What personal information do we process? When you visit, use, or navigate our Services,
we may process personal information depending on how you interact with Hulepay Inc
and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive
personal information.
Do we receive any information from third parties? We do not receive any information
from third parties.
How do we process your information? We process your information to provide, improve,
and administer our Services, communicate with you, for security and fraud prevention,
and to comply with law. We may also process your information for other purposes with
your consent. We process your information only when we have a valid legal reason to do
so.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third
parties.
How do we keep your information safe? We have organizational and technical
processes and procedures in place to protect your personal information. However, 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, cyber
criminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding your personal
information.
How do you exercise your rights? The easiest way to exercise your rights is by
submitting a data subject access request, or by contacting us. We will consider and act
upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on
the Services, express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or otherwise when you
contact us.
Personal Information Provided by You. The personal information that we collect
depends on the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we collect may
include the following:
names
phone numbers
mailing addresses
email addresses
usernames
passwords
contact preferences
billing addresses
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number, and the security code associated
with your payment instrument. All payment data is stored by paypal. You may find their
privacy notice link(s) here: https://www.paypal.com/myaccount/privacy/privacyhub.
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.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language preferences,
referring URLs, device name, country, location, information about how and when you use
our Services, and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information through cookies and similar
technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you interact with us, this
log data may include your IP address, device information, browser type, and settings
and information about your activity in the Services (such as the date/time stamps
associated with your usage, pages and files viewed, searches, and other actions you
take such as which features you use), device event information (such as system activity,
error reports (sometimes called "crash dumps"), and hardware settings).
Device Data. We collect device data such as information about your computer, phone,
tablet, or other device you use to access the Services. Depending on the device used,
this device data may include information such as your IP address (or proxy server),
device and application identification numbers, location, browser type, hardware model,
Internet service provider and/or mobile carrier, operating system, and system
configuration information.
Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For
example, we may use GPS and other technologies to collect geolocation data that tells
us your current location (based on your IP address). You can opt out of allowing us to
collect this information either by refusing access to the information or by disabling your
Location setting on your device. However, if you choose to opt out, you may not be able
to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We
may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
To deliver targeted advertising to you. We may process your information to develop
and display personalized content and advertising tailored to your interests, location, and
more.
To post testimonials. We post testimonials on our Services that may contain personal
information.
To protect our Services. We may process your information as part of our efforts to
keep our Services safe and secure, including fraud monitoring and prevention.
To evaluate and improve our Services, products, marketing, and your experience. We
may process your information when we believe it is necessary to identify usage trends,
determine the effectiveness of our promotional campaigns, and to evaluate and improve
our Services, products, marketing, and your experience.
To determine the effectiveness of our marketing and promotional campaigns. We
may process your information to better understand how to provide marketing and
promotional campaigns that are most relevant to you.
To comply with our legal obligations. We may process your information to comply
with our legal obligations, respond to legal requests, and exercise, establish, or defend
our legal rights.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section
and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data
with third-party vendors, service providers, contractors, or agents ("third parties") who
perform services for us or on our behalf and require access to such information to do
that work. We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything with
your personal information unless we have instructed them to do it. They will also not
share your personal information with any organization apart from us. They also commit
to protect the data they hold on our behalf and to retain it for the period we instruct. The
categories of third parties we may share personal information with are as follows:
Ad Networks
Affiliate Marketing Programs
Data Analytics Services
Social Networks
Sales & Marketing Tools
Payment Processors
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company.
4. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with
third parties that we may link to or who advertise on our Services, but are not affiliated
with, our Services.
The Services may link to third-party websites, online services, or mobile applications
and/or contain advertisements from third parties that are not affiliated with us and
which may link to other websites, services, or applications. Accordingly, we do not make
any guarantee regarding any such third parties, and we will not be liable for any loss or
damage caused by the use of such third-party websites, services, or applications. The
inclusion of a link towards a third-party website, service, or application does not imply
an endorsement by us. We cannot guarantee the safety and privacy of data you provide
to any third parties. Any data collected by third parties is not covered by this privacy
notice. We are not responsible for the content or privacy and security practices and
policies of any third parties, including other websites, services, or applications that may
be linked to or from the Services. You should review the policies of such third parties
and contact them directly to respond to your questions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such technologies
and how you can refuse certain cookies is set out in our Cookie Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements). No purpose in
this notice will require us keeping your personal information for longer than the period
of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either 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.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process.
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. Although we will do our best to
protect your personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure
environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of
age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Services. If
we learn that personal information from users less than 18 years of age has been
collected, we will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at contact@hulepay.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable
law, you have the right to withdraw your consent at any time.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, we may retain some information
in our files to prevent fraud, troubleshoot problems, assist with any investigations,
enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and
to reject cookies. If you choose to remove cookies or reject cookies, this could affect
certain features or services of our Services. You may also opt out of interest-based
advertising by advertisers on our Services.
If you have questions or comments about your privacy rights, you may email us at
contact@hulepay.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
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
privacy notice.
11. 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
Services, you have the right to request removal of unwanted data that you publicly post
on the Services. 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 Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
12. 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 privacy notice 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. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly sending
you a notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
contact@hulepay.com or by post to:
Hulepay Inc
4952 Timber Ridge Road
California
Sacramento, CA 94260
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access
to the personal information we collect from you, change that information, or delete it.