HSPconnect Privacy Policy

HSPconnect Privacy Notice

What is the purpose of this document?

We are committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you and applies to everyone whose personal data we process in our capacity as “data controller”, with the exception of our employees, workers and contractors.

We are Dunia XR Ltd trading as HSPconnect.You can contact us , Cindy Gale & Priyal Shah at help@hspconnect.app

This notice is not contractual and we may update it at any time. This version is effective from 28th December 2024

Our collection, use and transfer of your data

Members

When you apply to become a member, you are required to give us certain information such as your name, profile name, postal address, email address and telephone number, as well as a photo for your profile. Your profile name, photo and area are published on our website and may be viewed by any other member. The other information is retained by us, but not published. We may use your contact details, usually your email address, to update you in relation to our services.

We send newsletters to members (and potentially other stakeholders) no more frequently than once a month. If you wish to opt out at any time, please select 'unsubscribe' in the newsletter or contact us on help@hspconnect.app

Any personal data may also be held and used for establishing, exercising or defending legal claims.

Enquirers

We also obtain information about you, such as your name, contact details and anything you include in the message, when you make an enquiry through our website.

Complainants

We keep the details of any complaints for our legitimate interest in trying to improve our business.

Job applicants

If you apply for a job with us, we will keep your name, contact details, current salary, covering letter and CV for up to six months and may use these to contact you about applicable jobs.

General stakeholders

We collect information about many people, mainly in the form of contact details (name, job title, organisation, address, e-mail address and telephone number, as well as other information from e-mail signatures and footers) of people interested in our service for any reason, such as potential future members, suppliers and contractors. This information is usually provided directly from you and may be used for the legitimate interest of communicating with you in relation to specific issues or products that you are involved in,

or matters that you might be able to assist with. We may also contact you to keep in touch or make introductions. Any personal data may be held and used for establishing, exercising or defending legal claims.

Special category personal data and criminal convictions

“Special categories” of particularly sensitive personal information, being data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identifying people, health information and data concerning sex life or sexual orientation, require higher levels of protection.

We do not envisage processing any special category data or criminal conviction information.

Organisations that may see your data

Our banks, accountants, solicitors, insurers and other professional advisers are entitled to obtain specific data on request as part of our compliance checks and legal obligations, although they rarely need specific personal data.

Our IT, administration and marketing support providers may have access to all data on our systems from time to time to provide their services to us for legitimate interests.

Our website, community platform (includes the member profiles) and emails are currently hosted by CircleCo, Inc. (“Circle”), Hostgator & IONOS Group SE & and our newsletters are processed by The Rocket Science Group LLC t/a MailChimp.

We may share your personal information in the context of our legitimate interests in a possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

Use of our website

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer which are essential for the website to function properly and which help to provide you with a better online experience. Essential cookies cannot be switched off and do not store any of your information.

We also use analytical cookies, which allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. You can turn these off if you prefer.

Transferring information outside the UK

Our emails and website (including member profiles) are hosted by IONOS Group SE & HostGator, who are based in Germany & USA as are their data centres.

Our community platform is powered by a technology platform provided by CircleCo, Inc. (“Circle”) which is hosted in the United States

We use MailChimp to send our newsletters. Information about MailChimp’s international transfers of data can be found at https://mailchimp.com/legal/data-processing-addendum/#6._International_Transfers. This says that data may be transferred to the USA and other countries but MailChimp shall ensure that such transfers are made in compliance with the requirements of data protection laws.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at cindy@cindygalehsp.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to continue our professional relationship, depending on the specific data, why we need it and what risks the provision of it poses to your rights and freedoms. For example, if a supplier fails to provide contact details of its finance department or the details needed for payments, we may not be able to pay them.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long we keep your data for

Members

We retain membership personal data until seven years after they cease to be a member.

General stakeholders

We will hold your personal data until we are satisfied that there is no longer any purpose for retaining it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Job applicants

If you apply for a job with us, we will keep your name, contact details, current salary and CV on file for up to six months, although we may delete it before then if we do not anticipate any need for recruitment applicable to you within this time.

Anonymisation

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, correction, erasure, and restriction

You have a number of rights under the GDPR:

· the right to access personal data we hold;

· the right to ask us to rectify or complete our records;

· the right to ask us to delete personal data;

· the right to object to us processing your personal data;

· the right to restrict our processing; and

· the right to ask us to transfer your personal data to another organisation.

These are not absolute rights and are subject to specific conditions and depend on our processing purposes. If you are interested in using any of these rights, please contact us at cindy@cindygalehsp.com for more information.

In most situations, you will not have to pay a fee to access your personal information (or to exercise any of the other rights).

Please inform us of any changes

It is important that the personal information we hold about you is accurate and current. Please contact us at cindy@cindygalehsp.com if your personal information changes during your relationship with us so that we can update our records.

Complaints

If you are unhappy with any aspect of our processing of your personal data, we ask that you contact us at cindy@cindygalehsp.com first and discuss your concerns with us. If you are not satisfied with the outcome, you may lodge a complaint with the Information Commissioner’s Office, the UK supervisory authority for data protection issues. Information about how to do this can be found on their website at https://ico.org.uk/for-the-public/raising-concerns/.

HSPconnect Privacy Policy - Circle Community Platform

Last Updated: December 28, 2024

This privacy policy (“Privacy Policy”) explains how HSPconnect (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”) who access and use our online community or mobile or other downloadable applications (collectively, the “Community”). Beyond the Privacy Policy, your use of the Community is also subject to our Terms of Service.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as sending you a notification).

We encourage you to review the Privacy Policy whenever you access the Community or otherwise interact with us to stay informed about our information practices and the choices available to you.

Personal Information We Collect

Personal Information You Provide to Us.

Registration and Profile Information. When you open an account with us through the Community (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide.

Communications. We may also collect identifiers, such as your name, email address, and other information you choose to provide, when you participate in any interactive features of the Community (like send us a message through the Community), fill out a form, publish statements on our platform, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us. Messages Between Members. When you communicate with other members through the Community, we and our third-party partners receive the content of the messages you send and receive and information about those messages, such as when it was sent or received.

Content. We may collect other content and information you share through the Community when you submit information or content, such as by commenting on a blog or participating in online communities, or when you otherwise interact with the Community.

Payment Information. If you make a purchase through the Community, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

Personal Information That May Be Collected Automatically Through the Community.

When you access or use the Community or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Community and information about the device you use to access the Community, including:

Device Identifiers. Identifiers, such as your IP address, internet service provider, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Community.

Internet or Other Electronic Network Activity Information. We and our third-party partners may collect information about the devices and computers you use to access our Community, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Community, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Community and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with our Community, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Community and may record your mouse movements, scrolling, clicks and keystroke activity and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with the Community or engage in chat features through the Community.

Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).

Information From Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Community.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Community, you may not be able to utilize the features of the Community to their fullest potential.

Personal Information Collected from Third Parties.

Information from Third-Party Sources. When you interact with our members in the Community, we may collect from them any content or information you choose to share or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles.

Personal Information Usage

We use the information we collect about you to:

Personal Information Disclosure

Partners and Affiliates. We may disclose any information we receive to our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

Circle. The Community is powered by a technology platform provided by CircleCo, Inc. (“Circle”). We may disclose your information to Circle in connection with the provision of the Community.

Service Providers and Vendors. We may disclose your information to other vendors, consultants, and service providers retained in connection with the provision of the Community.

Other Members of the Community. If you provide or share information with other members of the Community, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in the Community, or when you interact with the Community through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

Analytics Partners. We may use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

Legal and Law Enforcement. We may share information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Community member to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

In Connection with a Change of Control. We may transfer or disclose 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 by another company.

Consent. Where applicable, we may share your information with your consent or at your specific direction.

Children’s Privacy

The Community is not intended for individuals under the age of 16. No one under the age of 16 is authorized to provide any personal information through the Community. We do not knowingly collect personal information from the Community from members in this age group. If we learn that we have collected or received personal information from a child under the age of 16, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Social Sharing Features

The Community may offer social sharing features and other integrated tools, which let you share actions you take on the Community with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Third-Parties

The Community may contain links to other websites, including our affiliated or co-branded websites and communities. Other websites and communities may also reference or link to the Community. These other websites and communities may not be controlled by us. We encourage our members to read the privacy policies of every website, community, or mobile application that collects personal information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites, communities, or mobile applications. Visiting these other websites is at your own risk.

Security

We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Transfer of Information to the U.S. from Other Countries

The Community is hosted in the United States and intended for visitors located within the U.S. If you choose to use the Community from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Community. By providing any information, including personal information, on or to the Community, you consent to such transfer, storage, and processing.

Your Choices

Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at help@hspconnect.app but note that we may retain certain information as required by law or for legitimate business purposes.

Location Information. If you initially consent to our collection of this location information through the Community, you can subsequently stop the collection of this information at any time through your device’s operating system settings. If you do so, certain features may no longer function properly.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Us

If you have any questions, comments or concerns about our Privacy Policy, you may email us at help@hspconnect.app