PRIVACY NOTICE

[Effective February 27, 2020]

About this Privacy Notice.

What this Privacy Notice covers.  Your privacy is important to Parallax Enterprises, LLC dba Huddie (“Huddie”, “we” or “us”).  This Privacy Notice applies to websites owned and operated by Huddie and its affiliates and to the use of its platforms and applications.  This Privacy Notice describes the information practices for Huddie’s websites (such as www.Huddie.com), as well as Huddie software, platforms and applications, including what type of information is collected, how the information is used, with whom the information is shared, and how the information is protected.

Categories of information.  Huddie processes three broad types of information: (1) Customer Account Data; (2) End User Usage Data; and (3) Customer Content.  “Customer Account Data” is the personal information of a customer or potential customer of Huddie.  “End User Usage Data” is the personal information of end users who interact with an application that has been built on or which interacts with Huddie’s platform (such as communications metadata).  “Customer Content” includes materials used to communicate with end users as well as information communicated to us by our clients or their patrons.

Changes to this Privacy Notice.  If we make a change to this Privacy Notice, we will make previous versions available upon request so that you can see when changes occurred and what they are.  If we make any material changes to this Privacy Notice, we will notify you by means of a notice on this site or by an email (sent to the e-mail address specified in your account) prior to the change becoming effective.  Where we are required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your personal information.  We encourage you to periodically review this page for the latest information on our privacy practices.

What information does Huddie collect through its websites, services and/or products?

Information you provide to us voluntarily.  In general, you can visit Huddie’s websites without telling us who you are and without giving any directly identifying personal information about yourself.  There are times, however, when we (or others working for us) may need information from you.  You may choose to give us personal information in a variety of situations.  For example, you may fill out information in a web form, or we may collect personal information about you when you place an order with Huddie or access an application, such as your name, address, email address, phone number, payment card information, information used to personalize a Huddie product or software experience, date of birth and other information you choose to provide.  Huddie uses this information to facilitate order processing and to enable us to contact you if a problem arises with your order.  Additionally, if you purchase a product requiring service, your personal information may be used to obtain a credit report, if necessary.  Please note that if you do not provide us with personal information where required, we may not be able to provide you with the products or services you have requested.

We may ask you for and collect personal information at other times, including when you subscribe to receive Huddie marketing communications or newsletters, when you complete surveys, or when you interact with Huddie at a trade show, conference or similar event.  You may also share personal information with a member of our Sales Team or Customer Support Team when you communicate with them.  We use the information you provide to help us design and improve our website and our products, to customize your online experience, to provide advice and purchase recommendations, and for other purposes consistent with this Privacy Notice.

Huddie also conducts research on our users’ demographics (e.g., age, gender), interests, and behavior based on the information provided to us when making a purchase, during a promotion, from surveys and from our server log files.  We do this to better understand and serve you.  This research is compiled and analyzed on an aggregated basis so as to prevent identification of personal information relating to any one individual.  Huddie may share this aggregated data with our suppliers or developers.

Finally, we may also ask for your personal information when you express an interest in employment opportunities at Huddie by submitting an application through our websites.  The information we collect from you will be made apparent at the time you are submitting your application, and we will use this information only to evaluate your employment candidacy.

Information we collect automatically.  Our web server logs collect the domain names and certain related data of visitors to our websites automatically (such as their IP address or device identifier).  This information does not identify our visitors directly, and is used to measure number of visits, average time spent on a Huddie website, pages viewed and website usage information.  We use this information to meet legal or regulatory requirements, to measure the use of our sites; to improve the content of our sites, and to provide tailored advertisements.  This information is not used in a form that would enable direct identification of any of our visitors.

When you sign up for an account with Huddie, we will automatically assign you and your account(s) unique IDs called SIDs and we’ll automatically generate an API token for each of your accounts.  These are used like a username and password to make API requests.  Instead of using these API tokens, you can request API keys and use your API key for authentication when making requests to our APIs.  We keep a record of these credentials so we know it is you making the requests when your application makes requests to our API using these credentials.

In addition, when you use our account portal or access our websites, we collect your IP address and other data through tracking technologies like cookies, web beacons, and similar technologies.  We use this information to understand how customers are using our platform, who those customers are (if they are a company and the IP address is associated with that company), what country they are logging in from (for analytics and export control purposes), and to help improve the navigation experience.  You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.  However, if you do not accept cookies you may not be able to use some portions of our service.

Huddie uses “cookies” and “web beacons” to collect data.  A cookie is a small text file containing a random and unique identifier that either Huddie or its third party web analytics provider on behalf of Huddie transfers to your computer’s hard drive through your web browser (unless you set your browser to reject cookies) that enables Huddie or its third party web analytics provider’s system to recognize your browser.  Huddie uses cookies to track your movement through its website and verify the login status of a client using products or services linked directly within the Huddie website.  Cookies are also used to track point of entry to point of registration for those users participating in our affiliate signup programs or to track and measure the success of a particular marketing campaign.  Neither Huddie nor its third party web analytics providers store any personally identifiable information in cookies.

Web beacons (also known as clear gifs) are typically a transparent graphic image (usually 1 pixel by 1 pixel) that is placed on a site and used by Huddie and its third party web analytics providers in combination with cookies to help us understand how you interact with the Huddie website.  We use web beacons to measure visitor behavior, to help us improve visitor experience, and to manage site content.

Information we collect from other sources.  From time to time, we may supplement information you give us via a Huddie website or application with information from other sources, such as information validating your address or other available information about businesses.  We may also collect information about you from publicly available sources.  This is to help us maintain the accuracy of the information we collect and to help us provide a better service.

Information from Huddie clients.  If you are a client of Huddie (or work on behalf of a Huddie client), through our secure web interface we also collect your username and password, and any other information that you provide to us on behalf of the client that you are representing pursuant to a license or other agreement between the applicable client and Huddie (the “Client Agreement”).  You should refer to that Client Agreement in addition to this Privacy Notice with regard to your use of the Huddie website and Huddie’s privacy obligations.

What other information does Huddie collect and how do we use it?

Huddie collects information about you and your use of our products and services to keep our products working their best and to help you make the most of them.  In certain circumstances, if you do not provide us with personal information where required, we may not be able to provide you with the products you have requested.

Broadly speaking, Huddie uses Customer Account Data, End User Usage Data and Customer Content to further our legitimate interests to: understand who our customers and potential customers are and their interests in Huddie’s products and services; manage our relationships with you and other customers; carry out core business operations (such as accounting and filing taxes); and detect, prevent or investigate security incidents, fraud and other abuse and/or misuse of our products and services.

Creating an account or user profile.  When you sign up for a Huddie account and use our products and services, we may gather personal information about you (also known as Customer Account Data).  We may ask you to provide additional information, such as your name, email address, language and region, IP address, and activation data about your operating system.  This information lets us give certain of our products, as well as third-party services enabled on our products, the information they need to function, to troubleshoot problems you may have, to suggest ways to make your products work better, to provide you with news, updates and information about your products, and, if you choose to receive marketing communications, to provide you with news and information about additional products in which you may be interested.

Payment processor.  You may be asked to provide our payment processor with your payment method information, like a credit card or Paypal account, and/or your billing address and other information necessary to process payments.  Our payment processor, acting on our behalf, will share you billing address and other pertinent information with Huddie.  You billing address and personal information may also be used by Huddie for tax calculation and audit purposes.

How does Huddie use and share the information it collects?

We may share your personal information with contracted suppliers who are providing services to us or to our customers to whom we provide services.  In some cases, Huddie uses suppliers to collect, use, analyze, and otherwise process information on its behalf.  It is Huddie’s practice to require such suppliers to handle information in a manner consistent with our policies.  Huddie does not share, sell, rent or trade your identifiable personal information with third parties for their promotional purposes.

When you make a request or an order.  If you request or order something from a Huddie website, such as a product or service, a callback, or specific marketing materials, we will use the information you provide to fulfill your request.  To help us do this, we may share information with others, for instance, service providers, vendors, suppliers, financial institutions, shipping companies, or postal or government authorities involved in the fulfillment of your request.  In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.  You may opt out of surveys and/or other market research communications by contacting us as at privacy@Huddie.com.

Huddie account data and product registration.  When you create a Huddie account or register your Huddie product, we will collect information, including personal information, about you and your device(s).  In addition to your ID, we may ask you to provide your name, email address, language and region/country, device type/model, and IP address.

Marketing. 

The information you provide to us may also be used by Huddie and selected suppliers or partners for marketing purposes, such as when you subscribe to receive marketing communications, newsletters, or other promotional materials.  Before this information is collected we may offer you the opportunity to choose whether or not to have your information used in this way.  You may choose to stop receiving our marketing communications by following the unsubscribe instructions included in those communications, accessing the marketing preferences in your account settings page, or you can contact Customer Support.  Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our General Terms and Conditions or this Privacy Notice, security alerts, and other notices relating to your access to or use of our products and services.

Testimonials. 

Huddie may sometimes display product reviews, testimonials and other endorsements of satisfied customers on our site.  With your consent, we may post your comments along with your name.  If you want to update or delete your comments, you can contact us at privacy@Huddie.com.

Blog disclosure.

If you use a bulletin board, blog, or chat room on our website, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.  We are not responsible for the personally identifiable information you choose to submit in these forums.

Service quality monitoring. 

Certain activities may also involve you calling Huddie or our Customer Service or other providers calling you.  Please note that, in some cases, we may record and retain such calls for staff training and quality assurance purposes.  If you do not wish the call to be recorded, please notify the call taker.

Business partner relationships.

If you represent a Huddie business partner (i.e., a distributor or reseller of Huddie products), you may visit a Huddie website intended specifically for Huddie business partners.  We may use personal information provided on that site to administer and develop our business relationship with you, and the company you represent.  For instance, this may involve using your information to send you details of Huddie business partner programs.  It may also include sharing certain information with other business partners (subject to any confidentiality obligations that may exist), or Huddie customers or prospects.  In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes.

Supplier administration. 

If you represent a Huddie supplier, you may visit a Huddie website intended specifically for use by Huddie suppliers.  We may use the information provided on that site in connection with entering into or performing a transaction with you.  For example, this may include sharing information with other parts of Huddie, Huddie’s business partners, customers, shipping companies, financial institutions, or postal or government authorities involved in fulfillment of a transaction.  It may also be used to administer and develop our relationship with you, the supplier you represent and/or other Huddie suppliers generally.

Disclosures required by law. 

In certain circumstances, it is possible that personal information may be subject to judicial or other government subpoenas, warrants, or orders.  Therefore, when we believe in good faith that the law requires it, we may disclose personal or other information to regulatory or government bodies, courts of law, tribunals, and law enforcement bodies to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Social media features and widgets.

Some of our websites may include social media features and links, such as a social bar with icons that link to the Huddie presence on that specific site (e.g., the Huddie page on Facebook, the Huddie feed on Twitter).  These features may collect your IP address and information on which page you are visiting on our site, and may set a cookie to enable the feature to function properly.  Social media features and widgets are either hosted by another company or are hosted directly on our site.  Your interactions with these features are governed by the privacy policy of the company providing it.

Links to other websites. 

Our website may include links to other websites that are not owned or controlled by Huddie.  Please be aware that Huddie is not responsible for the privacy practices of such other sites.  We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.  This Privacy Notice applies only to information collected by the website(s) owned and operated by Huddie.

Mergers and acquisitions.

Circumstances may arise when, whether for strategic or other business reasons, Huddie could decide to sell, buy, merge, or otherwise reorganize businesses in some countries.  You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.  Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or receiving it from sellers.

Other sources.

In addition to the above, there may circumstances which require us to disclose your personal information to parties in addition to those listed above, including, but not limited to, legal advisers or debt collection agencies.

Does Huddie transfer my personal information internationally?

Where permitted by law, we may share your personal information within Huddie or our suppliers and business partners and may transfer it to other countries where we do business.  Regardless of where your information is transferred to and resides, our privacy and security practices are designed to provide protection for your personal information globally.  Where your personal information is transferred outside its country of origin, we ensure security measures and appropriate safeguards are put in place to protect your personal information and ensure that all transfers of your personal information comply with applicable data protection law, and are carried out in accordance with Huddie’s instructions.

Please note that some countries have privacy laws that are not equivalent to privacy laws in your own country.  In such countries, Huddie will still handle information in the manner we describe here and will take such measures as are necessary to comply with applicable data protection laws when transferring and processing your information.  Where required, Huddie will also maintain agreements with partners or suppliers to govern the transferring, processing and protection of personal information.

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal information descried in this Privacy Notice depends on the personal data we collect and the specific context in which we collect it.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there.  Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer.

How long does Huddie store Customer Account Data, End User Usage Data and Customer Content?

Customer Account Data.

Huddie will store your Customer Account Data as long as needed to provide you with our services and to operate our business.  If you ask Huddie to delete specific personal information from your Customer Account Data, we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.

Here is an overview of how long we hold on to Customer Account Data in a form that can be used to identify you, unless there is a specific need or obligation to retain your information longer (like in the case of an open investigation, audit or other legal matter):

  • Customer Account Data stored in our customer relationship management system(s) is generally stored up to 7 years following closure of your account.  Invoice records, including their digital equivalent, may be retained in identifying form by Huddie for longer periods for accounting, tax, and audit purposes depending on and in accordance with applicable tax law.
  • Your communications with Huddie’s Customer Support teams may be retained for up to 3 years after your account is closed.
  • Apart from the above, following closure of your account, we may either delete other Customer Account Data or transform it such that it can no longer be used to identify you.

You can make various choices about your Customer Account Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used, when you log into your Huddie account or through the marketing preferences center.  Any other requests about your data that you cannot make through these self-service tools, you can request by emailing privacy@Huddie.com or contacting Customer Support at support@huddie.com.

If you are an end user of an application built on Huddie’s platform and not a direct customer of Huddie, you should direct requests relating to your personal information to the relevant application provider in accordance with the application provider’s own privacy policy.

End User Usage Data. 

We use End User Usage Data to provide services to you and to carry out necessary functions of our business as a communications service provider.  We do not sell your end users’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.

The particular end user personal information Huddie processes when you, our customer, use our products and services and the reason Huddie processes it depends on how you use our products and services and which Huddie products and services you use.  For that reason, our API docs for each of our products and services are the best place to find information about our processing of personal information when you use that Huddie product and service.

In many cases, you can opt to store records of your communications, or other activities, on Huddie, which may include your end users’ personal information.  You may also have the option to use additional features or tools within Huddie’s products or services that allow you to do things such as analyze the records, including end user personal information, in your Huddie account.  In those cases, Huddie will process this information to provide you with the service you request.

In addition, records containing end user personal information may, from time to time, also be used in debugging or troubleshooting or in connection with investigations of security incidents, as well as for the purposes of detecting and preventing spam or fraudulent activity, and detecting and preventing network exploits and abuse.

Details regarding how long your end user personal information may be stored on Huddie systems and how to delete, access, or exercise other choices about end user data will depend on which Huddie products and services you are using and how you are using them.  For that reason, our API docs for each of our products and services are the best place to find more detailed information about managing end user data collected and stored in connection with your use of our products and services.

As a Huddie customer, if the Huddie product or service you use enables you to store records of your usage on Huddie, including personal information contained within those records, and you choose to do so, then Huddie will retain these records for as long you instruct.  In some cases, use of extended storage may cost more. If you later instruct us to delete those records, we will do so.  Please note it may take up to 30 days for the data to be completely removed from all systems.  In some cases, a copy of those records, including the personal information contained in them, may nonetheless be retained to carry out necessary functions like billing, invoice reconciliation, troubleshooting, and detecting, preventing, and investigating spam, fraudulent activity, and network exploits and abuse.  Sometimes legal matters arise that also require us to preserve records, including those containing personal information.  These matters include litigation, law enforcement requests, or government investigations.  If we have to do this, we will delete the impacted records once we are no longer legally obligated to retain them.  We may, however, retain End User Usage Data that has been transformed such that your end user cannot be identified.

When and why does Huddie share my personal information or end users’ personal information?

We do not sell or allow your Customer Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do so.  We do not sell your end users’ personal information (whether contained in End User Usage Data or Customer Content), and we do not share it with third parties for their own marketing or other purposes, unless you instruct us to do so.

Below are the different scenarios under which we may share your data with third-parties.

  • Telephony operators as necessary for proper routing and connectivity.  Huddie provides an easier way for developers to build applications that make use of the publicly switched telephone network (PSTN) to send communications.  Therefore, communications-related data is shared with and received from telephony operators as necessary to route and connect those communications from the sender to the intended recipient.  How those telephony operators handle this data is generally determined by those operators’ own policies and local regulations.
  • Other communications service providers for proper routing and connectivity.  Huddie also enables sending or receiving communications through communications service providers that do not use the PSTN, such as Viber and Facebook Messenger (referred to as Over-the-Top (OTT) communications service providers).  If you choose to use Huddie to send or receive communications by way of these providers, Huddie will share communications data with these providers as necessary to route and connect those communications from the sender to the intended recipient.  How those OTT communications service providers handle this data is determined by their own policies.
  • Third-party service providers or consultants.  Huddie engages certain third-party service providers to carry out certain data processing functions on our behalf.  These providers are limited to accessing or using this data solely to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.
  • Sub-processors.  We may share Customer Content with sub-processors who assist in providing the Huddie services, like our infrastructure provider, or as necessary to provide optional functionality like transcriptions.
  • Add-on partners.  Add-ons are additional features, functionality or services offered by Huddie’s add-on partners (third parties not affiliated with Huddie).  Some add-ons may need to access or collect some of your information, including personal information.  If you choose to use an add-on, Huddie will share your information with the applicable add-on partner so that you can use the add-on.  Huddie does not control any of its add-on partner’s use of your information and their use of your information will be in accordance with their own policies.  If you do not want your information to be shared with an add-on partner, then you should not use any add-on.
  • Compliance with legal obligations.  We may disclose your or your end users’ personal information to a third party if (i) we reasonably believe that disclosure is compelled by applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.  If Huddie is required by law to disclose any personal information of you or your end users, we will notify you of the disclosure requirement, unless prohibited by law.
  • Affiliates.  We may share your personal information or your end users’ personal information with our affiliate companies.  We and our affiliates will only use the information as described in this Privacy Notice.
  • Business transfers.  If we go through a corporate sale, merger, reorganization, dissolution or similar event, data that we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction.  Any acquirer or successor of Huddie may continue to process data consistent with this notice.
  • Aggregated or de-identified data.  We may share data with third parties if such data has been de-identified or aggregated in a way so that it cannot be used to identify you or your end users.

How is my information protected?

Huddie’s website uses security measures to help protect against the loss, misuse, and alteration of the information under our control.  We store the information in two redundant databases in two secure environments at different locations with our data hosting service provider.

Huddie takes care to reinforce the importance of our web site visitors’ security and privacy.  Huddie requires unique usernames and passwords that must be entered each time a user logs on to Huddie’s client interface.  These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of all data.  Because our business involves hosting application accounts, data security is paramount.  We’re constantly reevaluating and deploying new technologies to enhance our security.

We use standard technical and organizational measures when we transmit information, when we store data, and when we share it with third parties.  For example, we use encryption when transmitting sensitive information to keep your information secure.  When sharing your information with third parties, we take reasonable and appropriate steps that such third parties will protect your information and use it responsibly.  We also take measures to ensure that our service providers that process personal data on our behalf have appropriate security controls in place.

Our products may also include security features designed to help you protect the information you store on your Huddie product(s).  These may include solutions like encryption, passwords, PIN unlock, and remote control over your product(s) so that you can locate, lock, and erase lost or stolen products.

To protect the confidentiality of your account and protect against unauthorized use of your account, we recommend enabling two-factor authentication for your account.  Additionally, you must keep your account password and authentication token confidential and not disclose them publicly or to unauthorized individuals; this includes accidentally distributing them in a binary form or checking them into source control.  Please let us know right away if you think your password or authentication token has been compromised or misused.

Similarly, if you are provided an API key, you should keep it secret and store your API key and Account SID in a secure location.  Please let us know right away if you think your API key or Account SID has been compromised or misused.

Please remember that no product, software, or data transmission can be guaranteed to be 100% secure.  As a result, while we have taken appropriate steps to protect your product(s) and your information, Huddie cannot ensure or otherwise warrant the security of your products or any information you provide to us.  By using Huddie products, you do so at your own risk.

How does Huddie protect my child’s privacy?

Huddie products are intended for adults and children aged 16 and over, or equivalent minimum age in the relevant jurisdiction, who have permission from their parents or legal guardians to use them.  Huddie does not seek to collect information about children under the age of 16.  No information should be provided on Huddie products or services by users under the age of 16.

If Huddie learns that a child under the age of 16, or equivalent minimum age in the relevant jurisdiction, has submitted personal information via its products or services, we will take appropriate steps to delete the information as soon as possible and will not use it for any purpose.  Huddie encourages parents to take an active role in their children’s use of Huddie’s products and/or services and to inform them of the potential dangers of providing information about themselves.  If you believe that a person who is underage has signed up for a Huddie account, please contact us at privacy@Huddie.com.

What are my data protection rights?

Applicable data protection laws may give you the right to control our use and processing of your personal information.  These may include the right (i) to request access to and a copy of your personal information, (ii) to request rectification or erasure of your personal information, (iii) to object to processing of your personal information, (iv) to restrict processing of your personal information, and (v) to data portability.  Where we are using your personal information with your consent, you also have the right to withdraw your consent at any time, though this will not affect our uses of your personal information prior to the withdrawal of your consent.

To exercise any of your rights, please contact us at privacy@Huddie.com.  We will consider and act upon any such requests in accordance with applicable data protection laws, and we may ask you to verify your identity in order to help us respond efficiently to your request.

You also have the right to raise questions or complaints with your applicable national data protection authority at any time.

Transfers of personal information out of the EEA and Switzerland.

When you use our account portal, or our other products and services, personal information about you and/or your end users processed by Huddie may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate.  These transfers will often be made in connection with routing your communications in the most efficient way.

Huddie employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law.  To the extent it is applicable, Huddie complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.

What are my rights under the General Data Protection Regulation (GDPR)?

If you are a resident of the European Union (EU) or European Economic Area (EEA), you have certain data protection rights, and our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  Huddie will take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information.

We will normally collect personal information from you only where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person such as in the case where we request personal information from you in the context of a government audit or in response to a request from law enforcement.

If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us at privacy@Huddie.com.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you.  Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section.  If you are unable to perform these actions yourself, please contact us at privacy@Huddie.com to assist you.

The right of rectification.  You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object.  You have the right to object to our processing of your personal data.

The right of restriction.  You have the right to request that we restrict the processing of your personal data.

The right to data portability.  You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent.  You have the right to withdraw your consent at any time where Huddie relied on your consent to process your personal information.  Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data.  For more information, please contact your local data protection authority in the European Economic Area (EEA).

You may submit a Subject Access Request and Huddie will provide you the following information without charge: what personal information pertaining to a user is being processed; why the information is being processed; who has access to the personal information about the user; how the personal information is being used in automated decisions; and what processes are using the information.  Please consider your request responsibly before submitting it.  We will respond as soon as we can.  Generally, this will be within one month from when we receive your request but, if the request is going to take longer to process, we will let you know.

Further information and advice about your rights can be obtained from the data protection regulator in your country of residence within the EU.

What types of sensitive information does Huddie not process?

Unless otherwise required by applicable law, Huddie does not process information regarding race or ethnicity, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health or mortality data, or data regarding sexual orientation.

How can I verify my information?

You may check your information to verify, update or correct it, and may have obsolete information removed.  If you have created an account with Huddie, you can access and change your online account profile yourself.  You can also ask to review any of the information that we have obtained, how we have used it, and to whom we have disclosed it at any time by contacting us as noted below.  Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.  You may also ask us to change your preferences regarding how we use or disclose your information, or let us know that you do not wish to receive any further communication from us.

What is Huddie’s policy on do not track signals?

We do not support “do not track” signals.  “Do not track” is a preference that you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable “do not track”  by vising the preferences or settings page of your web browser.

Automated decision making.

Huddie may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity.  Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.

How does Huddie handle disputes relating to its data protection practices?

It is Huddie’s desire to resolve any disputes relating to our data protection practices between us.  You can raise your concern or dispute by emailing our Privacy Team at privacy@Huddie.com, by calling us at (866) 300-0311, or by writing to us at:

Huddie
300 N. Sagewood Drive, Suite H-263
Park City, UT 84098

For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.

California residents.

In addition to the rights outlined above, where the California Consumer Privacy Act or related data protection laws apply, you may:

Request to know the categories of personal information we collect about you, as well as the sources from which the personal information is collected; the business or commercial purpose of our collection; the categories of third parties with whom we share your personal information; and the specific pieces of personal information we hold about you.

Request certain information regarding, and/or opt-out of, our disclosure of your personal information to third parties.

Request that we delete the personal information we hold about you in certain limited circumstances.

To exercise any of your rights, please send an email to privacy@Huddie.com.

If you are a California resident, to the extent that we sell your personal information to third parties, you have the right to opt out of such sale.  For example, you have the right to opt out if we receive valuable consideration for the disclosure of your personal information to a third party.  However, you do not have the right to opt out if such disclosure is required to provide you with services that you purchased from us.  You can exercise your right to opt out at any time by contacting us at privacy@Huddie.com or (866) 300-0311.  If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf.

Changes to our Privacy Notice

We may change this Privacy Notice and/or our privacy policies from time to time.  If we make any such changes, we will revise the “Effective Date” at the top of this Privacy Notice, and we may provide additional notice such as on the Huddie website homepage, account portal sign-in page, or via the email address we have on file for you.  We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if required by applicable law.

Use of Huddie websites

Your access to and use of Huddie.com and/or any of our platforms or applications is subject to this Privacy Notice and certain other terms and conditions contained in our General Terms and Conditions.