Last updated: [2018-12-14]
This Privacy Notice describes GlobalHop policies and practices regarding the collection and use of your personal data and sets forth your privacy rights. This Privacy Notice may be applicable to you if:
1. You are using Globalhop’s Cliplist software, which contains our SDK;
2. You are using other applications containing our SDK;
3. You are visiting our website and/or corresponding with us.
We recognize that ensuring privacy of our users is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
If you have any questions regarding this Privacy Notice or if you have any requests related to the processing of your personal information, you can contact us at [email protected]
PERSONAL INFORMATION OF APP OWNERS AND WEBSITE VISITORS
We collect following information about our users and website visitors:
- Log-in information. Upon registration to our dashboard, you will be asked to provide a valid email address that is used to automatically create your account. Without this information you will not be able to access GlobalHop Dashboard.
- Authentication and payment related information. If you request for our SDK, we will ask for additional information from you (e. g. your or your company name, address). We use this information to authenticate our users. Also, to receive a payment from us, you will need to provide payment related information (e. g. your bank account). All this information is necessary for the performance of an agreement between you and GlobalHop.
- Correspondence. If you correspond with us by email, live chat or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry and administer it. We may also send you information with transactional content to provide you with important details linked to the use of our services. GlobalHop. has a legitimate interest in maintaining correspondence related personal information of our users and website visitors.
We rely on your consent to send you marketing related content. However, where applicable law permits us to contact you without a separate consent, we will contact you under the legal basis of our legitimate interests to make you an offer of our services. As always, if you wish to have GlobalHop refrain from communicating with you, please contact us at [email protected] or opt-out by clicking an unsubscribe button in our emails where available.
- Website. As is true of most websites, our website collects certain information automatically and stores it in log files. The information may include internet IP addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other website usage information. We use this information to help us to better design our site, to help diagnose problems with our server, to administer our website and analyze trends. We have a legitimate interest in understanding how users and visitors interact with our website.
GlobalHop. does not track users to subsequent sites and does not serve targeted advertising to them. Therefore, we do not respond to ‘do-not-track’ signals.
For information regarding cookies and web beacons used on the website please refer to our Cookie Notice.
PERSONAL INFORMATION OF APP END USERS
By using our Cliplist software or third-party applications with our SDK, you allow GlobalHop. to access your device and to use a small bit of your network connection and device’s resources. Your device resources are used when the device is idle and is on Wi-Fi connection (we may seldom use your cellular data, but very sparsely). Please note that our purpose for using your device resources is not to gather data about you, but to access and collect data from public internet resources, such as websites, e-shops, search engines, etc.
For us to be able to use your device resources, we process a limited amount of your personal information:
- Device IP and OS version;
- Application name;
- Location information (country and city only);
- Network status (e. g. Wi-Fi is on/off);
- Device charging state and last seen status.
Your personal information is processed for the purposes of recognizing the application you are interacting with and accessing your resources only according to the information provided here and referenced in application terms.
The above-mentioned information is processed with your consent that you give to the app owner before using the application. The app owner is under a contractual obligation to make sure that you gave a valid consent for us to process your data. If you think that your data is processed without your valid consent, contact the application owner at once.
INFORMATION OF CHILDREN
We do not knowingly attempt to solicit or receive information from children under the age of 13 or any other age that requires a consent or authorization for data processing from the holder of parental responsibility. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Notice by instructing their children to refrain from providing personal data to us. If we become aware that we have collected personal data from children without verification of parental consent when it is necessary, we take steps to remove that information from our servers.
The personal information we collect from you is stored in one or more databases hosted by third parties. These third parties do not use or have access to your personal information for any purpose other than data storage and retrieval.
We do not otherwise reveal your personal data to third-parties for their independent use unless: (i) you request or authorize it; (ii) the information is provided to comply with the law (e. g. to comply with court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (iii) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (iv) to address emergencies; or (v) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
We may also gather aggregated data about our users and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers and/or other third parties for marketing or promotional purposes.
DATA SUBJECT RIGHTS AND CHOICES
Closing Your Account. If you wish to close your account, you may do so by logging in and using the dashboard settings or by contacting us at [email protected]
Access and Correction. If you wish to access and correct account information, you may do that by logging in to the dashboard and using account settings.
Individuals in the European Economic Area (EEA) have the following additional rights with respect to their personal data:
- Erasure. You can ask us to erase your personal data, but only where it is no longer needed for the purposes for which it was collected. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
- Restriction. You can ask us to restrict (i.e., keep but not use) your personal data when personal data is processed without complying with legal requirements or when there is another legal basis.
- Objection. You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but only where our processing is based on your consent and the processing is carried out by automated means.
- Withdrawal of consent. You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided. If you are the application end user and you like to withdraw your consent to process your personal data, please contact the application owner who will administer your request.
- Complaint. If you think that your personal information is processed unlawfully, or your privacy rights are violated, you have a right to contact a relevant data protection authority of your habitual residence, place of work or of an alleged infringement and file a complaint.
If you wish to implement any of above-mentioned rights, please contact us at [email protected]
We maintain technical, physical, and administrative safeguards to help protect the privacy of the data that we process. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. Nevertheless, please note that no company, including GlobalHop, can guarantee the absolute security of internet communications.
We retain your personal information for the duration of the business relationship between you and GlobalHop, and for a period of 5 years thereafter to allow users to recover accounts if they decide to renew, to analyze the data for GlobalHop own operations, and for historical and archiving purposes.
We retain communication related personal information for up to 3 years. However, we will maintain your personal information longer where required to ensure we would be able to defend or raise a claim, or where we have a legitimate interest to retain the information longer.
Personal information of app end users gathered through our SDK is retained for as long as the device in use is online and connected to our servers. Information regarding device country and application name is stored indefinitely for statistical and archiving purposes.
INTERNATIONAL TRANSFER OF DATA
We are based in the Republic of Kazakhstan. The information we collect may be transferred to, used from, and stored in Kazakhstan or other jurisdictions in which GlobalHop, our affiliates, or service providers are located; these jurisdictions (including Kazakhstan) may not guarantee the same level of protection of personal data as the jurisdictions in which you reside. By using our services, you acknowledge and agree to any such transfer of information outside of the jurisdiction in which you reside.
CHANGES TO THIS PRIVACY NOTICE
If you are a GlobalHop user and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice through the dashboard prior to the change becoming effective.
We encourage our users and website visitors to periodically review this Privacy Notice for the latest information on our privacy practices.