Last updated March 26, 2020
Feel Technologies Limited (“HAAAA”) is designated for users around the world and understands the importance of privacy and its compliance with various regulations amongst various jurisdictions.
1. When Does HAAAA collect Personal Data?
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
When Users register on the App: If you want to become a User of the Service, You need to register and open your personal HAAAA account. At the time of such registration, HAAAA will ask you to provide HAAAA with a certain amount of personal information. Submission of such personal information is voluntary, but without it you may not be able to (i) register on the App and/or open your HAAAA account, and/or (ii) use any features of the Service.
When Users answer HAAAA questions: User’s submission of personal information in response to HAAAA questions shall be voluntary, and Users may decline to answer any HAAAA questions at any time. By providing their personal information, Users consent to HAAAA using their details for the purposes of improving and delivering HAAAA Services.
2. What Does The Personal Information We Collect Include?
Personal Information Provided by You: HAAAA collects first name, surname name, birth year, gender, suburb, city, region, country (location/ time zone) email address and password. Providing Birth year, gender and location are optional. HAAAA may also invite you to provide additional information that will be publicly visible on our services, such as a profile picture. Such invites are optional.
Loading Contacts: When a User loads their personal phone contacts, only an invited friends’ phone number, and name are saved on HAAAA servers, to provide a high quality service and effective user experience for requesting and accepting friends. No information for uninvited friends is saved on HAAAA databases.
3. How does HAAAA use personal data?
To provide and enhance the Service: We may use personal information data in-house in order to provide and enhance the Service, to improve the Users’ interface.
To check compliance: HAAAA may inspect User account information and its responses, which may contain the personal information of Users, in order to (i) ensure compliance by any User with the App’s Terms and Conditions, (ii) to identify, contact or take action against a User whom we reasonably believe is in breach or has been in breach of the App’s Terms and Conditions, or (iii) to identify a User whom we reasonably believe has caused or is causing damage to or an infringement upon the rights or property of HAAAA, another User, or any third party.
4. To which extent and to whom does HAAAA disclose your personal data?
HAAAA uses personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and login process. We use the information you allowed us to collect to facilitate account creation and login process for the performance of the contract.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, made through the App.
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. HAAAA may disclose aggregate information about Users.
- To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- To deliver services to the user. We may use your information to provide you with the requested service.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
5. Will your information be shared with anyone?
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
When you create an account with HAAAA you give your consent that we may process or share data based on the following legal basis:
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
6. How Long Do We Keep Your Information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you claim your personal information to be deleted and your account with our Services to be cancelled, we will cancel your account and information associated with it to exercise your right “to be forgotten”.
7. What Are Your Privacy Rights.?
In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account according to our Terms and Conditions at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided herein. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however that this will not affect the lawfulness of the processing before its withdrawal.
8. Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account.
9. Opting out of email marketing.
You can unsubscribe from our marketing email list at any time by contacting HAAAA via its Help Center by email at firstname.lastname@example.org . You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.
10. Information From Minors Regulation
Our App and services are not directed to children. Access to and use of HAAAA is only for those over the age of 16.
11. Data Breach:
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when HAAAA believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that HAAAA becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information HAAAA will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
12. California Residents Privacy Rights
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
13. Contacting HAAAA
What data breach procedures we have in place
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), M Walmsley by email at email@example.com