Connecthings, Corp., and its parents and affiliates (collectively “HEROW”, “we”, “us”, or “our”), are committed to keeping any and all personal information collected from individuals that visit our website and who use our products, software and services (collectively, “Services”) confidential, secure and private.
INFORMATION WE COLLECT
We collect and use the following information from Customers to provide, improve and protect our Services:
We may collect certain information that Customers specifically and intentionally provide to us. For example, when a Customer places an order with us, we may collect personal information about you such as the name of your business entity, a contact email address and phone number, and physical address. When a Customer voluntarily consents to receive our newsletter, we may collect personal information to deliver the newsletter to the Customer. Additionally, as part of our Services, you will have the ability to upload, store and share certain files with us, along with data and information related to them. We may also collect financial information that you choose to share with us, such as your business entity’s credit or debit card number, billing address, and other billing information. Other unique information that we may collect includes product and service preferences, and contact preferences. To the extent that an individual, and not a business entity, is a Customer, we may collect all of the above information about the individual Customers, as well as your age, sex, educational and employment background. To the extent that the Customer is a business entity, the data above may be provided to HEROW by a designated entity within your company (such as a member of your Purchasing/IT/Facility Management department). For the avoidance of doubt, all information collected from a Customer hereunder shall be known as “Customer Information.”
End User Information
We may collect certain information that End Users specifically and intentionally provide to us. For example, an End User may provide us with their name, email address, phone number, age, sex, and physical address.
We collect certain information about End Users when such End Users receive Content from Customers and otherwise use the Services. HEROW relies on unique mobile device identifier to collect information about an End User’s location (which includes, without limitation, the End User’s geographical location and GPS coordinates), the time of day and the device the End User is using to access the Services, the End User’s Internet protocol address, browser type, language, and metrics regarding the End User’s behavior with respect to certain pieces of Content. For the avoidance of doubt, all information collected from End Users hereunder shall be “End User Information”. HEROW may use the End User Information as set forth herein.
End Users that do not wish to be identified may disable location services of their mobile device or disallow permission to access location for the mobile application installed with Connnecthings’ SDK. However, this may cause the Services to function improperly or prevent the End User from accessing the Services.
PERSONAL INFORMATION OF CHILDREN
WE DO NOT AND WILL NOT KNOWINGLY ALLOW ANYONE UNDER 13 YEARS OF AGE TO PROVIDE US ANY PERSONAL IDENTIFYING INFORMATION. USERS OF THE SERVICES WILL BE DEEMED TO HAVE FULL CONTROL OVER THEIR PRODUCTS AND USER ACCOUNTS, AND MUST ENSURE THAT NO CHILDREN UNDER THE AGE OF 13 USE OUR SERVICES IN ANY MANNER WHICH WOULD PROVIDE US OR ANY THIRD PARTY WITH ANY PERSONAL INFORMATION OF A CHILD. IF WE LEARN THAT WE HAVE COLLECTED PERSONAL INFORMATION FROM A CHILD UNDER AGE 13, WE WILL DELETE THAT INFORMATION AS QUICKLY AS POSSIBLE. IF YOU BELIEVE THAT WE MIGHT HAVE ANY PERSONAL INFORMATION ABOUT A CHILD UNDER AGE 13, PLEASE CONTACT US USING THE CONTACT INFORMATION PROVIDED BELOW.
HOW WE COLLECT INFORMATION
ACCESS TO AND CONTROL OF PERSONAL INFORMATION
Customers can access, review and/or update their user profile and settings at http://herow.io, which will allow the Customers to modify, update, or restrict access to certain information.
USE OF INFORMATION
We may use your information to:
- Enhance or improve End User experience, our Software Development Kit or “SDK” that End Users install in their mobile applications, website, or our Service.
- Process transactions.
- Send e-mails about our website or respond to inquiries.
- Send e-mails and updates about HEROW, including our e-mail newsletter.
- Send third party offers.
- Deliver our Service to you, such as by tracking customer service, contact, historical, and locational data relating to you and the End Users.
- Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our website or Service.
THIRD PARTY ACCESS TO YOUR INFORMATION
- To provide Customer Information or End User Information to trusted third parties to help us provide, operate, maintain and improve the Services.
- To use Customer Information or End User Information to help personalize or improve the Customers’s experience using Services.
- To use Customer Information to process transactions and assist you in completing a transaction or order.
- To use Customer Information to keep Customers apprised of HEROW’ latest product announcements, software updates, and upcoming events – however, you can opt out of receiving these messages at any time by updating your profile.
- To use Customer Information or End User Information to administer contests, promotions, surveys, or other features of our Services.
- To release certain information to our attorneys, accountants and professional advisors in order to help us comply with applicable laws, and to third parties as we deem necessary to enforce our website policies, or protect our rights, property, or safety, and/or the rights, property or safety of others.
- If HEROW ale of all or substantially all of our assets, all information collected hereunder may be transferred as part of such transaction. In such event, we will notify you of any such transaction, and explain your options in such event.
- To provide you with the Services, we may store, process and transmit information in locations around the world – including those outside your country. Information may also be stored locally on the devices you or End Users use to access the Services.
CONTENT AND THIRD PARTY WEBSITES
We expect our Customers to use our Services responsibly, and deliver appropriate Content. Accordingly, Content posted by Customers is subject to our Acceptable Use Policy and other content restrictions. If you are an End User and you see any Content which you believe violates this Acceptable Use Policy, please contact us immediately. Notwithstanding the foregoing, HEROW disclaims any responsibility to End Users for Content posted, transmitted, or otherwise disseminated by Customers via the Services.
HEROW uses reasonable security controls to protect your data and information from loss, misuse, unauthorized access, disclosure, alteration and destruction. The personal information you provide us is stored on computer systems located in controlled facilities which have limited access, and only carefully selected, authorized personnel have access to unencrypted user information. When collecting or transferring sensitive information such as credit card information, we use a variety of additional security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. When we transmit sensitive information over the internet, we protect it through the use of advanced encryption techniques, such as the Secure Socket Layer (SSL) protocol, and firewall.
Additionally, as part of real-time payment processing, HEROW may subscribe to fraud management services. These services provide HEROW with an extra level of security to guard against credit card fraud and to protect your financial data. Despite these precautions, no security safeguards guarantee 100% security all of the time, and no guarantees are made with respect to the same.
HOW LONG WE KEEP YOUR INFORMATION
We retain your personal information in accordance with our data retention policies and practices. The length of time we keep your information depends upon a number of factors, including the type of information. In general, we retain personal information for as long as we have an ongoing business need to retain it. Following that period, we will delete it.
USERS FROM THE EUROPEAN ECONOMIC AREA
LEGAL BASIS FOR PROCESSING.
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable European Union laws. The legal bases depend on how you use the website or the Services:
- We need to collect and use the information for you to use the website;
- Our collection satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us informed consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the website.
HOW TO ACCESS OR CONTROL YOUR INFORMATION
The General Data Protection Directive (GDPR) provides individuals in the EEA certain rights with respect to their information. These include the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You can exercise these rights by contacting us at the address in the Contact Section below.
The GDPR provides that we may limit or deny your requests in certain cases. For example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we have compelling legitimate interests to keep, including as required by law. You may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed if you have concerns about your rights.
YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY)
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of customers’ personal information with third parties. These businesses are required to accept requests for disclosures of these policies from customers but are only required to honor one request per calendar year. Businesses have thirty (30) days to respond to each inquiry to the designated address. Each inquiring customer will receive an explanation of the categories of customer information shared and the names and addresses of any third-party businesses. In limited circumstances, customers’ failure to submit requests in the manner specified will not require a response from the business.
If you are a California resident, you may request such information from us by sending a letter to the address listed below. In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that HEROW provide its third-party information sharing disclosures required by section 1798.83 of the California Civil Code.”
188 GRAND STREET
NEW YORK, NY 10013
ENFORCEMENT AND DISPUTE RESOLUTION
If you have any questions, complaints or disputes regarding the manner in which we use or protect your information, please contact us using the contact information provided below. We will investigate and attempt to resolve any complaints and disputes in a reasonable time and in a manner that complies with the principles described in this Policy.
Any dispute that might arise will be subject to the exclusive jurisdiction of the Court of Paris.
CHANGES TO THIS POLICY