HIVER MOBILE APP PRIVACY POLICY

 

Last updated: April 25th, 2018

 

This Mobile App Privacy Policy ("Policy") applies to information collection and use by Colmeia Ltd and its affiliates ("Colmeia", "we", "us", "our") including whilst downloading and/or streaming Colmeia's mobile software application, Hiver ("App"), owned or operated by Colmeia Ltd, 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ. For the purposes of EU data protection laws ("Data Protection Legislation"), Colmeia is data controller (i.e. the company who is responsible for, and controls the processing of, your personal data).

This Policy sets out the basis on which any personal data collected from you or that you provide to us, via the App, will be processed by us. Before installing and using the App, please read the following carefully to understand how we will treat your personal data.

We take privacy issues very seriously at Colmeia and we are fully committed to protecting your privacy. Please read this Policy carefully as it contains important information regarding how we collect, store, process, transfer, share and use information about you.

Before accessing or using the App, please ensure that you have read and understood our collection, storage, use and disclosure of your personal data as described in this Policy.

  • WHEN DOES THIS POLICY APPLY?
  1. Any personal data we collect from you or that you provide to us via an App will be processed in accordance with this Policy and it applies in addition to any separate terms or privacy notices made available to you at any other time.
  2. This Policy does not apply to the personal data we collect from you (as relevant) in connection with your use of our website (www.hivertech.com). Please refer to the Website Privacy Policy in that regard. It does not apply to the personal data we collect from you in connection with our products and services or when we sign up to written terms with you in connection with the same (please refer to the separate privacy notice(s) issued to you on those occasions).
  • INFORMATION WE MAY COLLECT WHEN YOU USE THE APP
      1. We collect personal data about you when you voluntarily submit information directly to us when you access and use our App. This can include information you provide to us [when you register to use our App, fill in a form, correspond with us via the App, phone, email or otherwise, subscribe to a product or service, report a problem with the App, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the App as available from time to time or in any other instances you provide us with information in connection with an App].
      2. If you choose not to provide personal data, we may not be able to provide the App to you or respond to your other requests.
      3. The table at Annex 1 sets out the categories of personal data we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal data, the categories of recipients of the personal data and information as to how we determine applicable retention periods.
      4. We also automatically collect personal data about you indirectly, including about how you access and use the App and information about the device you use to access the App.
      5. The table at Annex 2 sets out the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data, the categories of recipients of the personal data and information as to how we determine applicable retention periods.
      6. We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
      7. We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the App and developing new products and features. We may also share such anonymised information with others including, for example, event organisers.
  • [MARKETING AND ADVERTISING
      1. From time to time we may contact you with relevant information about the App. Most messages we send will be by e-mail. For some messages, we may use personal data we collect about you to help us determine the most relevant information to share with you.
      2. If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails].
  • Storing and transferring your personal DATA
    1. Security. The security of your personal data is important to us. However, please be aware that there are inherent security risks of providing information and dealing online over the internet and we cannot therefore guarantee the security of any data disclosed via the App. We ask that you do not provide us with any sensitive or special categories of personal data via the App unless we specifically ask for it to be provided.

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on secure servers. All electronic transaction entered into via our App will be protected by SSL encryption technology.

Where you register for an account on the App, you are responsible for maintaining your account’s security.

      1. International Transfers of your Personal Data. [The personal data we collect via the App may be transferred to, and processed and stored in, countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Union ("EU"), your personal data may be processed outside of the EU, including, for example, in the United States; these international transfers of your personal data are made (i) to a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission, or (ii) to a the third party that is a member of a compliance scheme recognised as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission, or (iii) pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission or the EU-U.S. Privacy Shield. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Policy.]
  • cookies and similar technologies
    1. The App uses cookies to distinguish you from other users of the App. This helps us to provide you with a good experience when you use the App and also allows us to improve the App.
    2. Cookies are pieces of code that allow for personalisation of the App experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device's hard disk (such as your computer or smartphone) for record-keeping purposes.
    3. We use the following types of cookies:
      1. Strictly necessary cookies. These are cookies that are required for the essential operation of the App such as to authenticate users and prevent fraudulent use.
      2. Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the App when they are using it. This helps us to improve the way the App works, for example, by ensuring that users are finding what they are looking for easily.
      3. Functionality cookies. These are used to recognise you when you return to the App. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Please be aware that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies (such as Facebook and Twitter).

      1. The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Service. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
        1. Cookie settings in Internet Explorer
        2. Cookie settings in Firefox
        3. Cookie settings in Chrome
        4. Cookie settings in Safari web and iOS.
      2. Although we do our best to honour your privacy preferences, we are unable to respond to Do Not Track signals set by your browser at this time.   
  • YOUR RIGHTS IN RESPECT OF your personal information
      1. This section applies to you if you are located in the EU.
      2. In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:
        1. Right of access. The right to obtain access to your personal data.
        2. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
        3. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
        4. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
        5. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organisation to another.
        6. Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
      3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Policy.
      4. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  
  • Links to third party sites

The App may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

  • OUR POLICY TOWARDS CHILDREN

The App is not directed at persons under 18 and we do not knowingly collect personal data from persons under 18. If you become aware that your child has provided us with personal data, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

  • Changes to this policy

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make material changes to this Policy, we will notify you by means of a prominent notice on the App prior to the change becoming effective.

  • NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Policy.

  • Contacting us

Questions, comments and requests regarding this Policy are welcome and should be addressed to hello@hivertech.com or to Colmeia Ltd, 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.



ANNEX 1 – PERSONAL INFORMATION WE MAY COLLECT WHEN YOU USE THE APP

Category of personal information

How we use it

Legal basis for the processing

Categories of recipients

Retention period

Contact information and basic personal details such as your title, name (first and last names), phone number, address, e-mail address, country as well as your industry.




We use this information to:


  • communicate with you to, for example, provide you with information about the products and services we supply to you;  
  • send information to you about updates to the App[, and any news, alerts and marketing communications (in line with your settings and options)];
  • subscribe to a product or service;
  • report a problem with the App;
  • deal with enquiries and complaints made by or about you relating to the App;
  • operate, maintain and provide to you the features and functionality of the App;
  • maintain the safety of the App;
  • carry out any of our obligations arising from your use of the App;
  • ensure that our records are accurate and up to date;
  • notify you about changes to our products, services or App;
  • to verify your log in details and enable you to use an App; and
  • comply with our legal and regulatory obligations.

The processing is necessary for:


  • the performance of a contract and to take steps prior to entering into a contract;
  • our legitimate interests, namely administering the App, [for marketing purposes and communicating with users]; and
  • for compliance with our legal obligations.


As required in accordance with how we use it, we will share your personal data with the following:

Event organisers: We may convert your personal data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including producing statistical research and reports. For example, we may produce reports on which of our services are most popular with users of our App. We may share aggregated data and data analytics in several ways, including with event organisers.

Other users of the App. Other users of the App that you interact with or that we share information, with, such as information that you provide on LinkedIn.

Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements (for example, on Facebook and Twitter) providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or analytic services (such as Hubspot Inc.).

Purchasers and third parties in connection with a business transaction. Personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of the App; and/or (c) exercise or protect the rights, property, or personal safety of Colmeia, users of the App, or others.




For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

Location: When you use the App, we will collect and process information about your actual location during an event. We use various technologies to determine location, including Bluetooth, IP address, GPS and other sensors that may, for example, provide Colmeia with information on nearby devices, Wi-Fi access points and mobile towers.

We use this information to operate, maintain and provide to you the features and functionality of the App.

The processing is necessary for:


  • the performance of a contract and to take steps prior to entering into a contract; and
  • our legitimate interests, namely administering the App.

In addition, you provide your consent to the processing of location data when you choose to join the App at an event. Consent may be a lawful reason for processing your personal data in relation to our App, in certain cases. This means your freely given, specific, informed and unambiguous consent which may be collected from you. You should be aware that you are entitled under Data Protection Legislation to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the App.

Information provided by social networks, including LinkedIn, when you connect to the App. The features and functionality of the App connects social networks, predominantly LinkedIn, to our App. In this case, we collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information, such as your name, LinkedIn ID, profile picture, network, gender, username, userID, age or age range, language, country, connections and any other information you have agreed it can share or that the social network provides to us.  

We will use the personal information provided to allow you to log-in to the App, to help create a public profile for you, and where we provide the functionality, we will also use the information provided to assist you in sharing the content you create, or your experiences on the App with your contacts on the connected social network.

The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; and

our legitimate interests, namely administering the App.

All personal information set out above.

We will use all the personal information we collect to:


  • operate, maintain and provide to you the features and functionality of the App;
  • communicate with you;
  • monitor and improve the App and business, to help us develop new products and services;
  • to detect and prevent fraud and defend ourselves from any legal claims;
  • to comply with any applicable legal and internal governance obligations;
  • to prevent or detect crime, for quality, training and security purposes; and
  • market research, analysis and developing statistics.

The processing is necessary for our legitimate interest, namely, to administer and improve the App, our business and develop new services; and compliance with our legal obligations.


ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information

How we use it

Legal basis for the processing

Categories of recipients

Retention period

Information about how you access and use the App including, for example, how frequently you access the App, the time you access the App and how long you use the App for, whether you access the App from multiple devices, and other actions you take on the App.

We use this information to:


  • present the App to you on your device;
  • measure or understand the effectiveness of advertising we serve to you, and to deliver relevant advertising to you (with your consent, where relevant),
  • [determine news, alerts and other products and services that may be of interest to you for marketing purposes];
  • administer the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • administer our legitimate internal management analysis, audit, forecasts and business planning and transactions;
  • monitor and improve the App and our business, and to help us develop new products and services;
  • detect and prevent fraud;
  • establish, defend or exercise our legal rights,
  • comply with our legal, regulatory and internal governance obligations,
  • prevent or detect crime, for quality, training and security purposes; and
  • market research and analysis and developing statistics.


The processing is necessary for our legitimate interests, namely to:


  • for business administration, including statistical analysis;
  • tailor the App to the user and to improve the App generally;
  • monitor and resolve issues;
  • [for marketing purposes];
  • communicate with users;
  • contact users;

and compliance with our legal obligations.  




As required in accordance with how we use it, we will share your personal data with the following:

Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements (for example, on Facebook and Twitter) providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or analytic services (such as Hubspot Inc.).

Purchasers and third parties in connection with a business transaction. Personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of the App; and/or (c) exercise or protect the rights, property, or personal safety of Colmeia, users of the App, or others.

For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

Information about your device including information about the device type and its unique device identifier (e.g., the device's mobile phone number), the type of mobile browser and mobile operating system that you are using and application connected to the App through the device, visitor sessions by device type, your Internet service provider or mobile network.