Last updated: September 11, 2019
For the purposes of the European General Data Protection Regulation 2016/679 (the “GDPR”), HYPR Corp. is the “data controller” of, and is responsible for, European personal information collected through the HYPR Site.
By post: HYPR Corp., 1001 Ave of the Americas, New York, NY 10018
By email: email@example.com
HYPR Products can enable you to use applications developed by third parties, individually and collectively referred to as “Third Party Apps” on a Device, such as an Android App on a Device running either the Microsoft Windows, Apple OS X or Linux operating systems.
We believe that you have the right to understand how your information is stored and used. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or web sites.
Information We Gather
Information You Provide:
In general, you can visit the HYPR Site without telling us who you are or revealing any information about yourself. If you wish to obtain information about our products or services you can contact us.
You may provide your personal information to us in a number of ways, for example by filling in online feedback and contact forms, requesting information, subscribing to materials and newsletters, participating in surveys, registering for a HYPR account, downloading or using our HYPR Products, corresponding with us by post, phone, email or otherwise, or as part of the general enquiry process. Such personal data may include:
- Company name;
- Email address;
- Telephone number;
- Street address;
- Taxpayer and immigration information;
- Payroll data;
- Insurance information;
- Banking information;
- Password; and
- Other personal information you may choose to submit.
Furthermore, when you contact us (online or offline) in connection with a request for information, to access our products or services and to provide you with support, we collect personal information necessary to fulfil your request, to grant you access to the product or service, to provide you with support and to be able to contact you.
Information Automatically Collected:
We (or our service providers acting on our behalf) may collect information about the HYPR Products that you use and how you use them (“Usage Information”). This information includes information that may identify you as well as statistical information (“Analytics”) that does not identify you. Some Analytics may be correlated with your personal information. Usage Information may include:
- Device Information:
We may collect Device-specific information (such as your hardware model, operating system version, unique Device identifiers and mobile network Information including phone number). We may associate your Device identifiers or phone number with your HYPR Account.
- Log Information:
When you use HYPR Products, we may automatically record or log information from your Device, its software, and your activity using the HYPR Products. This may include:
- The Device’s Internet Protocol (“IP”) address;
- Identification numbers associated with your Devices;
- Device event Information such as crashes, system activity and hardware settings;
- Locale preferences;
- Application activity such as app upload, app download, app installation, app uninstallation, app start, app play duration, app stop, app crashes, app network activity and app resource consumption;
- Date and time stamps associated with transactions;
- System configuration Information;
- Metadata concerning your Android apps; and
- Other interactions with the HYPR Products.
Further general information about cookies and how they work is available at www.allaboutcookies.org.
To help us make e-mails more useful and interesting, we may receive a confirmation when you open e-mail from the HYPR Site, if your computer supports such capabilities. In an effort to avoid sending unnecessary messages to our customers, we also compare our customer list to lists received from other companies.
Information from Other Sources:
We might receive information about you from other sources and add it to our account information.
Use of Information
- To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
- To administer your HYPR account;
- To provide the HYPR Products;
- To assist you in completing a transaction or order;
- To prepare and process invoices;
- To respond to queries or requests and to provide services and technical and sales support;
- To provide aftersales customer relationship management;
- To create and manage our customer accounts; and
- To notify you about changes to the HYPR Sites or HYPR Products.
- We will process your personal information for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing if required by applicable law (such consent can be withdrawn at any time):To display content based upon your interests and to offer the HYPR Products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly;
- To send you personalized marketing communications, in order to keep you informed of our own, our affiliates’ or third-party products and services that we think you may find of interest; and
- To allow you to participate in contests and surveys and benefit from personalized promotional offers.
We will process personal information for the following purposes as is reasonably necessary in our legitimate business interests, provided such interests are not overridden by your interests or fundamental rights:
- To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
- To detect and prevent fraud, other financial crime, malicious activity and as part of our efforts to keep the HYPR Sites safe and secure, for example, by requesting verification information to confirm your identity, in order to reset your account password (if applicable);
- To monitor and protect the security of our information, systems and network;
- To create products or services that may meet your needs;
- To develop and improve our HYPR products and services, for example, by reviewing visits to the HYPR app, the HYPR Site and its various subpages, demand for specific products and services and user comments;
- To measure performance of marketing initiatives; and
- To ensure that content from the HYPR Site is presented most effectively for you and your Device.
We may use aggregated and anonymized data (independent of any personal identifiers) for research and commercial purposes. This information includes what areas our users visit most frequently and what services they access most often. This information helps us develop a better site that is more useful and accessible to you.
Before sending you marketing communications we will generally ask for your consent in line with the applicable law when you first provide your personal information. Our subsidiaries and contractors will be required to use any personal information we provide them only for that intended purpose.
You can elect not to receive emails from us either by “unsubscribing” to an email you receive or by contacting us as indicated below.
As of January 1, 2014, online operators must disclose (1) how the operator responds to web-browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an consumer’s online activities over time and across third-party websites or online services; and (2) whether other parties may collect personal information about a consumer’s online activities over time and across different websites when he or she uses the operator’s website or service.
We do not use technology that recognizes a “do-not-track” signal from your web browser. This technology allows us to exclude you from any analytics that collect information about your online activities over time and across third party websites.
Disclosing Your Information
We may share personal information about you in the following ways:
- If you request or authorize it;
- If necessary to complete a transaction for you;
- If the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
- If the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.), who are bound by law and contract to protect your personal information and only use your personal information in accordance with our instructions;
- To allow marketing to you, in line with the applicable law; or
We may disclose your non-private, anonymized, aggregated, or otherwise non-personal information, such as usage statistics of our Products, to our affiliates and third parties.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us at the address indicated at the end of this policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your account or transactions with us.
Accessing Your Information
You are required to provide us with accurate and up to date information. HYPR gives you the ability to amend your personal information at any time by accessing your account on the HYPR Site and modifying the information. Any changes will affect only future uses of your personal information.
You can ask us whether we are keeping personal information about you and you can ask to receive a copy of that personal information. Before sending you any personal information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity to our sole satisfaction, we reserve the right to refuse to send you any personal information. We will respond as quickly as we can to your requests for details of personal information we hold about you, in line with the applicable law.
We have security measures in place in our physical facilities and in our computer systems, databases, and communications networks that are reasonably designed to protect information contained within our systems from loss, misuse or alteration.
WE ARE NOT RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF ANY NON-PUBLIC INFORMATION THAT YOU PROVIDE US. IF THERE IS INFORMATION THAT YOU WISH TO PROTECT FROM DISCLOSURE TO OTHERS, DO NOT PROVIDE IT TO US.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal information. You also play a role in protecting your information. Please safeguard your username, email address and password and do not share them with others. If we receive instructions using your log-in information we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We reserve the right to refuse service, terminate accounts, or remove or edit content in our sole discretion.
Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent as set forth in this Policy.
We may disclose your personal information to our affiliates or other third parties, including Google, who may use that information to market to you directly. Pursuant to California’s “Shine the Light Act”, California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please email us at california@Hypr.com to request a copy of our disclosure pursuant to California law.
If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to your personal information that we hold about you—specifically:
- Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
- Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
- Request erasure of your personal information. You may have the right to request that personal information held about you be deleted.
- Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
- Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.
- Right to object. You may have the right to object to the processing of your personal information when you have legitimate reasons to do so.
- Withdraw consent. Where processing is based on consent, you may have the right to withdraw such consent.
You can exercise any of these rights by emailing us at firstname.lastname@example.org.
Children’s Online Privacy Protection Act
We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people who are at least 18 years old or older.
Links to Third-Party Sites
If you are visiting the HYPR Site and/or using our HYPR Products or services or otherwise providing personal information to us from outside the U.S., be aware that the personal information we receive may be held on our computers and systems in the European Union and in the computers and systems of our offices and datacenters in the United States and may be accessed by or given to our staff working outside the European Union. Your information may be processed by us in the United States, where laws regarding data protection may be less stringent than the laws in your country. [By using the HYPR Site and by providing any personal information to the HYPR Site, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such information in the United States.] [Note: As discussed, there is an issue around consent for this meeting the required standards.]
Where personal information is transferred from the EU to a third party located in a non-EU jurisdiction that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, to transfer the personal information.
[Note: Regulators do not like different standards or policies applying or anything which can cause confusion – they look for there to be one policy that users can refer to.]
We may also collect information from our customers in connection with any Customer Agreement which may be applicable to that customer.
This site is owned and operated by HYPR. If you have any questions or suggestions with respect to this policy, or if you wish to ask us to delete, correct, or show you your information as provided above, you can write to us at email@example.com or 1001 Ave of the Americas, 10th Floor, New York, NY 10018 – or you can simply send us an email.