What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information, social security number or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, place an order, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat, Open a Support Ticket or enter information on our site.
Provide us with feedback on our products or services
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To quickly process your transactions.
• To ask for ratings and reviews of services or products
• To follow up with them after correspondence (live chat, email or phone inquiries)
How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use 'cookies'?
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If you turn cookies off .
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.
We do not include or offer third-party products or services on our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have not enabled Google AdSense on our site but we may do so in the future.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Can change your personal information:
• By logging in to your account
How does our site handle Do Not Track signals?
We don't honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. We don't honor them because:
Does our site allow third-party behavioral tracking?
It's also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
• Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages.
HMBD Privacy and Cookies Policy
(Effective Date: May 17, 2018)
We may provide additional information about our privacy practices at other points, for example, when we ask you to provide personal information in connection with a particular service, and where this will help us provide more relevant and timely information.
1. INFORMATION THAT WE COLLECT ABOUT YOU
Customers and Website Users
Information Provided by You Upon Registration and/or Making a Purchase. When you register for an account on a Site and/or purchase a product or service from us, we collect information that allows us to identify you, such as:
Information Provided When You Contact Us. We also collect personal information that you voluntarily provide to us when you contact us with a question or comment about our products and services, download our whitepapers or sign up for product demonstrations or events. Typically, this includes:
Passively Collected Information. When you access our Sites, we automatically collect (i) technical information about your device including your device’s internet protocol (IP) address, your browser type and version, time zone setting, and operating system and platform; and (ii) information about your visit, including the URL clickstream to, through and from our Sites (including date and time), products you viewed or searched for, your account activity (when logged in), the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies. See Section 2 for more detail.
Information Collected From Our Partners. We may partner with our third party resellers to receive information about you, such as name and contact information. This helps us to fulfill your service requests and/or to provide you with services that may be of interest to you.
Information Collected in Connection with our Review Services or other Services. Where our customers use our review service or other services, we compile statistical and other information related to the performance and operation of the relevant service and will use or share with our customers and prospective customers, aggregated information collected from reviewers or other users of our services for research and development purposes or to provide analytics, reports and benchmarking about our services (e.g. average location ratings or frequently used terms within the reviews). We also use such aggregated information for our own advertising and promotional purposes. If you use our services to solicit reviews from your customers via email, or other forms of communication, including but not limited to text messages, we will collect, on your behalf, the personal information and any other information provided in such reviews from your customers (“Reviewers”). We will use the information provided by Reviewers to provide services to you. We have no direct relationship with Reviewers. You are responsible for ensuring that you have the appropriate consent for us to collect and process Reviewers’ information to provide our services. If you are a Reviewer and believe you have received an email from us on behalf of one of our customers, please contact that company directly with any questions.
Partners, Publishers and other Service Providers
We will process certain contact information about individuals within organizations that we work with such as publishers, mailing houses, payment providers, IT hosting and maintenance providers, events companies and other service providers.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE
The above technologies are used in analyzing trends, administering the Sites, services and products, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
The table below sets out the cookies we use on the Sites, their purpose, and how you may opt out of our use of these cookies.
Type of Cookies
Required cookies enable you to navigate the Sites and use its features, such as accessing secure areas of the Sites and using the HMBD products and services.
Technical cookies can be grouped into session cookies, which allow you to navigate and use the Sites, and functionality cookies, as described below.
Because required cookies are essential to operate the Sites and the HMBD products, there is no option to opt out of these cookies.
Functionality cookies allow the Sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide you with more personal features. These cookies also enable you to optimize your use of the HMBD products after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when using the Sites.
If you wish to not have this information collected and used for targeted advertising, you may opt-out by clicking here for partners that participate in the TRUSTe opt-out tool (or if located in the European Union click here). If you wish to opt out from this type of advertising for companies that participate in the Digital Advertising Alliance (DAA), you can do so by clicking here.
Please note that this does not opt you out of being served ads. You will continue to receive generic ads. HMBD adheres to the DAA’s Self-Regulatory Principles when we allow third parties to collect data on the Sites for such advertising.
To learn how to manage privacy and storage settings for Flash cookies click here.
Analytics cookies collect aggregate information on the number of visitors and the pattern of visits to the Sites and other sites over time for non-advertising purposes.
To manage and opt-out of analytics cookies based on Google Analytics solution click here.
Social Media Cookies
In order to enhance your Internet experience and to make the sharing of content easier, some of the pages on our website may contain tools or applications that are linked to third-party social media service providers such as Facebook or Twitter (see the ‘Social Media Widgets’ section, below). Through these tools or applications, the social media service provider may set its own cookies on your device.
You can also change your cookie settings via your browser. For further information, visit www.allaboutcookies.org.
The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.
3. USES MADE OF YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING
Providing personal information is optional; however, in order to provide you with access to our services and other resources such as whitepapers and demos, providing certain personal information (e.g., contact information and name, log-in details) may be necessary in order to receive these services and resources. You may choose whether or not to receive electronic marketing communications from us and we will only send you such communications where we have the appropriate consents to do so (to the extent required by applicable law). For more information on your choices, please see Section 5 below.
We process personal information through electronic and manual means for the following purposes:
Customers and Website Users
To fulfill a contract or to take steps linked to a contract. This includes:
As required to conduct our business and pursue our legitimate interests, in particular:
Where you give us consent:
As required by law:
Partners, Publishers and other Service Providers
We use contact information about individuals within other organizations that we work with in order to fulfill our contractual obligations or as required to conduct our business and pursue our legitimate interests including for our own internal functions such management, corporate reporting, and record keeping.
4. DISCLOSURES OF YOUR PERSONAL INFORMATION
Service Providers. When we employ an affiliate or third-party to perform a function on our behalf, we provide it with the personal information that it needs to perform its specific function. These companies are authorized to use your personal information only as necessary to provide these services to us. We use service providers for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications.
Legal Requirements. We disclose personal information to government authorities or other third-parties if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena, court order or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, (d) protect against legal liability, (e) to investigate fraud or other unlawful activity or (f) or as otherwise required or permitted by law.
Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including in bankruptcy, your personal information may be part of the transferred assets. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Publishers. If you have requested us to do so, we may provide personal information to third-party publishers that we work with. For example, if you have provided your name or a biography to be published on a third-party publisher’s website.
Third-Party Partners. We may share your personal information with selected third-party partners, including for their direct marketing purposes. We will obtain your prior consent for such a transfer where required by applicable law.
International Transfers of Personal Information. Your personal information is stored on servers in the US and is supported from the US. We may also transfer your personal information to our affiliates and other service providers who perform functions on our behalf which are based around the world, including in countries outside of the European Economic Area (EEA) and Switzerland which may have different data protection standards to those which apply to your country of residence. You can click here to see a list of countries where we may access or transfer your personal information. Where your personal information is transferred from Japan (and subject to Japanese privacy laws), you hereby agree to the transfer of your personal information to HMBD, Inc., HMBD affiliates and service providers located in the countries listed in Section 7.
HMBD, Inc. participates in and has certified its compliance with the EU-US Privacy Shield and the Swiss-US Privacy Shield frameworks regarding the collection, use and onward transfer of personal data from the EEA and Switzerland. To learn more about the Privacy Shield Framework, visit the US Department of Commerce’s website (www.privacyshield.gov). To learn more about HMBD, Inc.’s participation in the Privacy Shield Framework, please see our Privacy Shield Notice here for further information).
Where your personal information is transferred outside of the EEA and Switzerland, and where this is to an affiliate or service provider in a country which is not subject to an adequacy decision by the EU Commission, we will take steps to ensure your personal information is adequately protected either by EU Commission approved Standard Contractual Clauses, Binding Corporate Rules, or in the case of transfers to the US based affiliate HMBD, Inc., its self-certification to Privacy Shield. A copy of the relevant mechanism can be obtained for your review on request by using the contact details in Section 7.
5. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO HMBD’S DIRECT MARKETING
Where we rely on consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above in Section 3. You have the absolute right to opt out of our direct marketing at any time, and EEA individuals can also opt out of profiling we carry out for direct marketing at any time. To stop receiving newsletters or marketing communications from us, you can use the unsubscribe mechanism in the relevant communication or you can send an email to email-unsubscribe@HMBD.com with information necessary to process your request. Please note that this will not stop you from receiving service related messages (i.e., non-marketing communications) such as email messages to let you know our service has been suspended for maintenance.
6. YOUR RIGHTS
If you are an individual located in the EEA, you have the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data, to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process such data in order to meet a contractual or other legal requirement).
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are set out in applicable data protection laws. We will inform you of the relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, please email privacy@HMBD.com with the information necessary for us to process your request. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
If you deactivate your account, we will delete, block or anonymize your personal information so that it is no longer possible to identify you, subject to our retention policy below.
If you have provided a location review to one of our customers, please contact that customer directly if you have any questions about their privacy practices or wish to stop receiving communications from or exercise your rights in respect of personal data processed by that customer.
Social Media Widgets. Our Sites include buttons that allow you to share content on the Sites through services provided by Facebook, Twitter and LinkedIn. Facebook, Twitter and LinkedIn are social media networks not affiliated with HMBD. They are headquartered at the following addresses:
Facebook: 1 Hacker Way, Menlo Park, CA 94025, USA
Twitter: 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
LinkedIn: 2029 Stierlin Court, Mountain View, CA 94043, USA
When you use the Facebook, Twitter or LinkedIn share buttons, your device will access their respective webpages and, therefore, your data will be sent to the party associated with that share button and such party may also know that you visited our Site. Further information on Facebook, Twitter and LinkedIn’s collection, use and disclosure of your personal information can be found in their respective privacy policies which can be accessed on their respective webpages.
Security. We take commercially reasonable steps to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from a Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any personal information to us or to any other party via the Internet. When you enter sensitive information (such as a credit card number) on our order forms or login credentials (such as username and password) on our platform login, we encrypt the transmission of that information using secure socket layer technology (SSL).
Retention. We will retain your information for as long as your account is active or longer if needed to provide you services, comply with our legal obligations, resolve disputes or enforce our agreements. For more information on our retention periods you can contact privacy@HMBD.com.
Minors. Visitors under 16 years of age are not permitted to use and/or submit their personal information on any Site. We do not knowingly solicit or collect information from visitors under 16 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
1 Madison Ave.
New York, NY 10010
United States of America
HMBD, Inc.’s European representative:
HMBD SAS (see address below)
All other activities (both online and offline)
HMBD (Canada) Corp.
160 Elgin Street
Ottawa, ON K1P 1C3
12 Golden Square
London W1F 9JE
Kantstraße 164, 30. Stock
cc: HMBD GmbH Data Protection Officer
Kinast & Partner Rechtsanwälte
Venloer Str. 24
c/o Genint SA
rue Jean-Calvin 12
Responsible for processing orders and invoicing and (with your consent, where required) providing information about other HMBD products and services that may be of interest.
33 Rue la Fayette
Ginsen Shimbashi Bldg. II, 8F
5-1-9, Shimbashi, Minato-ku, Tokyo
Under the Act on the Protection of Personal Information in Japan, HMBD KK is a business operator handling personal information obtained through HMBD.co.jp or all other activities (both online and offline) in Japan and is primarily responsible for management of such personal information.
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