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Privacy Policy

Humanize Global Sàrl, Rue du Fort Elisabeth 21, 1463 Luxembourg, Luxemburg and our US subsidiary Humanize of 4041 Soquel Drive, #213, Soquel 95073, United States (hereinafter: “Humanize”, “we” or “us”) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data (as defined in the Luxembourg`s Data Protection Act (DPA) and the General Data Protection Regulation (GDPR)) (the “Personal Data”) we collect from account holders or individual users or visitors to our Platform, or that is uploaded to our Platform, will be processed by us. Account holders, users and visitors of our Platform or owners of Personal Data collected by us (each, “you”) should read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

By providing any Personal Data to us, you consent to the collection, use, disclosure and transfer of such Personal Data in the manner and for the purposes set out below.

Information we may collect

We may collect and process the following data which may contain Personal Data:

information that you provide by filling in forms on the Humanize platform (“our Platform”), including information provided at the time of registering to use our Platform, subscribing to any services provided by us, posting material, reporting a problem with our Platform, or requesting further services;

  • information, data, documents or images that you upload onto our Platform;
  • details of transactions you carry out through our Platform;
  • details of your visits to our Platform, resources that you access and actions you are working on through the Platform;
  • if you contact us, a record of that correspondence; and
  • responses to surveys that we send to you, although you do not have to respond to them.

IP Addresses

We may also collect and process information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Log Files

We may also collect and process access data that your internet browser automatically transmits to us for technical reasons in order to provide the website. Depending on the access protocol used, the protocol data record contains general information with the following contents: Your session data (usage behavior, length of stay, which links were clicked on, etc.), your abbreviated and unabbreviated IP address, your browser version, your operating system, your website-specific settings, your cookie IDs, your pixel IDs. This data does not allow any direct inference to your person and is processed to improve our website offer and to defend against attempted attacks on our web server.

Cookies

Please refer to our Cookie Policy for more information on how we use cookies.

Where we store your data

The Personal Data that we collect may be transferred to, and stored at, a destination outside Luxemburg. It may also be processed by staff operating outside Luxemburg who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your services ordered by you, the processing of your payment details and the provision of support services. By submitting any Personal Data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Uses made of the information

We use information held, including Personal Data, in the following manner:

  • to ensure that content from our Platform is presented in the most effective manner for you and for your device;
  • to provide you with information, products or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;
  • to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to notify you about changes to our services;
  • to investigate any complaints relating to the use of our Platform or any suspected unlawful activities;
  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • any other purposes for which you have provided the information; and
  • carrying out whatever else is reasonable or related to or in connection with the above and our provision of services to you.

Disclosure of your information

We may disclose your Personal Data to any member of our group, which means any corporation deemed to be related to us.

We may disclose your Personal Data to third parties:

  • for the purposes of providing products or services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, processing payments in connection therewith or otherwise in connection with your use of our Platform;
  • where a third party claims that any content posted or uploaded by you to our Platform constitutes a violation of their rights under applicable law, in which case we may disclose your identity to that third party;
  • in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; or
  • if we or substantially all of our shares or assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets.

We may also disclose your Personal Data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the Platform, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.

Consent

By providing your Personal Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy (“Purposes”).

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Personal Data in accordance with this privacy policy.

You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

Your Rights

California Specific Rights

If you are a California resident, you have the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Data we collect, use, or share; (2) purposes for which categories of Personal Data are collected or used by us; (3) categories of sources from which we collect Personal Data; and (4) specific pieces of Personal Data we have collected about you.
  • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
  • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Data about you that we have collected.
  • Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. We do not sell the Personal Data of our users. For more information about these rights, please contact us.

GDPR Rights

If you are a European Citizen, you have the following rights:

  • to confirmation as to whether data relating to them is being processed,
  • to information about the data processed, to further information about the data processing and to copies of the data;
  • to correction or completion of incorrect or incomplete data;
  • to immediate erasure of the data concerning them;
  • to receive the data concerning them and provided by them and to transfer this data to other providers/controllers.
  • to lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions.

In addition, the provider is obliged to inform all recipients to whom data has been disclosed by the provider of any correction or deletion of data or restriction of processing that takes place. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Notwithstanding this, the user has a right to information about these recipients.

Likewise, users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by the provider. In particular, an objection to data processing for the purpose of direct advertising is permissible.

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal Personal Data about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your Personal Data.

If you wish to exercise your right to object, simply send an e-mail to us.

Access and correction

Applicable Data Protection Law gives you the right to access your Personal Data. Your right of access can be exercised at any time without detriment. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.

In the event that you wish to correct and/or update your Personal Data in our records, you may inform us in writing of the same by contacting us. In certain cases, Personal Data may also be corrected or updated via the Platform.

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable Data Protection Law).

Accuracy

We endeavor to ensure that all decisions involving your Personal Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Personal Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Personal Data.

Retention

We may retain your Personal Data for at least five (5) years, or such other longer or shorter period as may be necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.

Data Intermediary

Where we process your Personal Data as a data intermediary on behalf of a third party, we will process your Personal Data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Personal Data will be protected and retained in accordance with this privacy policy.

We will take steps to inform the third party of any requests, complaints or questions that you may have regarding such Personal Data.

Security

State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.

Data Breaches/Notification

Databases or data sets that include personal information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, Humanize will notify all affected individuals whose personal information data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after the breach was discovered.

Confirmation of Confidentiality

All company employees must maintain the confidentiality of personal information as well as company proprietary data to which they may have access and understand that such personal information is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgment reminders annually attesting to their understanding of this company requirement.

Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

External Links

Our platform contains links to the online services of other providers. We hereby point out that we have no influence on the content of the linked online services and the compliance with data protection regulations by their providers.

Personal information and children

Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.

Changes and updates to the privacy policy

We kindly ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Concerns and Contact

If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us.