– Privacy Statement
Last Updated on 27/001/2019. You can access the previous version of the Privacy Statement here.
We respect your privacy and we undertake to protect your personal data. This privacy statement will tell you how we handle your personal information, your privacy rights, and how you protect the law. Please read this Privacy Statement carefully before using our Services.
In this privacy statement:
Services means any products, services, content, features, technologies or features and all the relevant web pages, applications, and services that we offer.
Platform means websites, mobile apps, mobile web pages, or other online properties through which we offer our Services.
1. Who are HereYoGo.net, an authorized person, based in Cambridge 16 Peverel Road, CB5 8RH, United Kingdom. (HereYoGo.net, “us”, “us” or “us” in this Privacy Statement). The legal entities in the HereYoGo.net group, which deliver your services in accordance with the Terms and Conditions of Use (collectively “HereYoGo.net” the HereYoGo.net group, are also considered as data operators for the local services they provide.
The local administrator who processes your personal data is: HereYoGo.net.
Our contact details can be found in section 13.
2. What data do we collect about you?
2.1.1 Data provided through direct interactions
Registration and other account information
When you register to use our Services, we can collect the following information about you:
• if you register using your Google Account: first name, first name and email address;
• If you are registering with your Facebook account: first names and names, as they appear in your Facebook account and your Facebook ID. If you’ve given Facebook permission through the privacy feature of your app (which appears before you can log in to our platform), we can also collect information about gender, age or email based on your permissions; and
• If you register using your mobile phone number: We will collect your mobile phone number.
Depending on the choices you make while logging in to our Services or during the hiring process of our Services, you may opt for the following additional personal data:
• Your Name.;
• Email Address;
• mobile phone number;
Chat communication (if applicable) on our Platform
When using chat to communicate with other users, we collect the information you choose to share with other users through this feature.
2.1.2 Data that we automatically collect when using our Services
When you interact with our Platform or use our Services, we automatically collect the following information about you:
• We collect device-specific information, such as the operating system version, unique identifiers. For example, the name of the mobile network you are using. We associate the device identifiers with your account.
Information about the place
• Depending on your device’s authorizations, if you publish an item on our Platform, we automatically collect and process information about your current location. We use various technologies to determine the location, including IP address, GPS, Wi-Fi access points and mobile towers. Your location data allows you to see user articles next to you and helps you post articles in your place.
Client and Authentication data
• Technical details, including the Internet Protocol (IP) address of the device, the time zone, and the operating system. We will also keep your login information (registration data, last password change date, last successful login date), browser type and version.
• We collect information about your activity on our Platform, including the webpages you accessed our Platform, the date and time of each visit, the advertising banners, or the content you clicked, your interaction with these types of advertising, the length of the visit and the order in which you visit the content of our Platform.
Our Services / Platforms may become inaccessible or may not work properly. For more information on the cookies we use, please refer to the Cookies Policy.
2.1.3 Data from third parties or publicly available sources.
We receive personal data about you from various third parties [and public sources] as follows:
1. Certain technical and usage information from analytics providers such as Google, Mix Panel, Cxsense;
2. IP address, geolocation, navigation history from advertising networks such as Google, Criteo, OpenX, SATI, Cxsense;
3. Do we collect data from children?
Our services are not intended for people under 18 and we do not knowingly collect data from people under 18. If we find that a person under 18 has provided us with personal data, we will delete it immediately
4. Why do we process your personal information?
We will use your personal data only when the law allows us. Most often, we will use your personal information in the following situations:
• If we have to execute the contract that we are about to end or have concluded with you.
• Where it is necessary for our legitimate interests to improve our Services and provide you with a secure and secure platform.
• When we have to comply with a legal or regulatory obligation.
Under certain circumstances, we may also process your personal data with your consent. If we do, we will notify you of the purpose and the category of personal data that need to be processed when we request your consent.
We have described below how we use your personal data (and the legal bases we rely on). We also identified what our legitimate interests are, where appropriate].
4.2 To improve your platform experience
i. We use clickstream data for
• provide you with customized content, such as providing you with more relevant search results when using our Services.
• determine how long you stay on our Platform and how you navigate through our platform to understand your interests and improve our Services based on this data. For example, we can give you suggestions on the content you can visit based on the content you clicked on.
• Monitor and report on the effectiveness of providing our business partners with campaigns and internal business analysis.
• prevent too much from showing the same creative to the same user.
ii. We use your location data for the following purposes:
• to compile anonymous and aggregated information about HereYoGo.net users’ characteristics and behavior, including business analysis, segmentation, and anonymous profiles development.
• to improve the performance of our Services and to customize the content we target to you. For example – with location data, we show the ads that are in your neighborhood to improve your buying experience.
• to measure and monitor your interaction with third-party ad banners placed on our Platform.
iii. With your site registration information, including email and phone number, we determine the different devices (such as personal computers, mobile phones, tablets) through which you access our platform. This allows us to associate your activity on our platform on different devices and helps us provide you with an appropriate experience no matter what device you are using.
We process the above information based on our legitimate interest in improving your experience on our Platform and adequately fulfilling your agreement with you.
4.3 To Provide You with a Safe and Secure Platform
i. We use your mobile phone number, log data, and unique device identifiers to manage and protect our Platform (including debugging, data analysis, testing, fraud prevention, system maintenance, support, reporting, and data hosting).
ii. We analyze the communications made through our chat feature to prevent fraud and to promote security by blocking spam or abusive messages that can be sent by any other user to you.
We process the above information for the proper performance of our contract with you, in order to improve our services and on our legitimate interest in preventing fraud.
5. How will we tell you about the changes to our privacy statement?
We may occasionally modify this Privacy Statement. We will post changes on this page and we will inform you by email or through our Platform. If you do not agree with the changes, you can close your account by accessing your account setup and choosing to delete your account.
6. Your Rights
Under certain circumstances, you have rights under data protection laws with respect to your personal data.
If you wish to exercise any of the rights below, go to your account / privacy settings or contact us using the Contact Form
The right to request access to your personal data (commonly referred to as “request for access to the data subject”). This allows you to receive a copy of the personal data we hold about you and verify that we process it legally.
The right to request correction of any data we have about you. This allows you to have any incomplete or inaccurate data we have about you corrected, although it may be necessary to verify the correctness of the new data you provide us.
The right to request the restriction of the processing of your personal data. This allows us to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want to establish the accuracy of the data;
(b) if we use illegal data;
(c) if you need to keep the data, even if we no longer need it, because you need to establish, exercise or defend legal claims; or (d) you have opposed your use of your data, but we need to verify that we have imperative legal grounds for using it.
The right to request the deletion of your personal data. This allows you to ask us to delete or remove your personal information where there are no good reasons to continue processing it. You also have the right to ask us to delete or remove your personal data if you have successfully exercised your right to object to processing (see below) if we have processed your information illegally or if we are required to delete your personal data to comply with local law. Please note that for some purposes we are legally bound to keep your data. See section 10.
The right to oppose the processing of your personal data if you rely on a legitimate (or third party) interest and there is something about your particular situation that makes you want to object to processing for this reason as you feel it has an impact on fundamental rights and freedoms.
You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate reasons to process your information beyond your rights and freedoms. The right to request the transfer of your personal data to you or to a third party. We will provide you or a third party that you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right applies only to the automated information you originally gave your consent to use or if we used the information to enter into a contract with you. The right to withdraw your consent to the processing of your personal data at any time. This does not affect the lawfulness of any processing we have already done on the basis of prior consent. Response deadline: We try to respond to all legitimate requests within one month. Occasionally, it may take more than a month if your request is particularly complex or you have made more requests. In this case, we’ll let you know and we’ll keep you up to date.
In addition, you have the right to complain at any time to the data protection authority. However, before we complain to the data protection authority, we appreciate the opportunity to deal with your problems first and foremost. In this regard, please contact the Data Protection Officer using the Contact Form.
7. Communication and Marketing we will communicate with you via email or application notification about our Services / Platform to confirm your registration, to let you know if your ad is on / expired and other related transactional messages with our Services. Because it is imperative that we provide you with such transactional messages, you may not be able to give up such messages. However, you may ask that we no longer send your marketing communication at any time by accessing the deactivation link in the sent email or by changing the communication settings in your account. If you have trouble modifying these settings, please contact us using the Contact Form. You may receive marketing communications from us if:
• You have requested such information from us;
• use our Platform or services;
• you provided the details when you entered a competition; or
• You have registered for a promotion.
8. With whom do we share your data?
We may share personal data with the parties listed below for the purposes set out in section 4 above.
Affiliated Companies – We can share your data with other HereYoGo.net Group companies that are both inside and outside the EEA and help us deliver business operations such as product improvements, customers and fraud detection mechanism. Any sharing of personal data with the HereYoGo.net group of companies located outside the European Economic Area (“EEA”) will always be subject to the safeguards described in Section 9 or a data transfer agreement that clearly defines the obligations parties and provides technical and organizational measures to protect your data.
Third-party service providers: We use third-party service providers to help us deliver certain aspects of our Services, such as cloud storage such as Amazon Web Services and Microsoft Azure. Service providers may be located inside or outside the “SEE” area.
We perform controls on third-party service providers and ask them to respect the security of your personal data and treat them in accordance with the law. We do not allow them to use your personal data for our own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.
Advertising and Analysis Providers: To improve our services, we will sometimes distribute your unidentifiable information to analytics providers that help us analyze how people use our Platform / Service. We share your information with them in an unidentifiable format for monitoring and reporting the effectiveness of our campaign delivery to our business partners and for internal company analysis. For more details about advertisers and analytics providers, please see our Cookies Policy.
Law enforcement, regulators and others: We can divulge your personal data to law enforcement, regulatory, governmental or public authorities and other interested parties that comply with legal or regulatory requirements.
We can choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If there is a change in our company, new owners may use your personal information in the same way as described in this privacy statement.
Publicly Available Information: When posting an item for sale using our Services, you can choose to make certain personal information visible to other HereYoGo.net users.
These may include your first name, last name, your email address, your location, and the contact number. Please note that all information you provide to other users may always be distributed by others to others, so please exercise your discretion in this regard.
9. International transfers
Every time we transfer your personal data from the EEA, we ensure that a similar degree of protection is provided by ensuring that at least one of the following protection measures is implemented:
• We will transfer personal data only to countries that were considered to provide an adequate level of protection of personal data by the European Commission. For further details, see the European Commission: Adequacy of the protection of personal data in non-EU countries.
• If we use certain service providers, we may use specific contracts approved by the European Commission that offer personal data with the same protection as in Europe. For more details, see the European Commission: Model contracts for the transfer of personal data to third countries.
• If we use US-based service providers, we may transfer data if they are part of the Privacy Protection which requires them to provide similar protection to personal data shared between Europe and the US. For more details, see the European Commission: EU-US Privacy Shield.
You can obtain a copy of relevant and implemented protection measures by contacting us using the Contact Form.
10. Where do we store your data and for how long?
The data we collect about you will be stored and processed both inside and outside the EEA in secure servers to provide the best possible user experience. For example – to quickly build websites or mobile apps.
We will retain your personal data for as long as it is necessary to meet the purposes we have collected, including for the purposes of meeting any legal, accounting or reporting requirements.
In order to determine the appropriate retention period for personal data, we take into consideration the value, nature and sensitivity of your personal data, the potential risk of harm caused by unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and legal requirements applicable.
If you have questions about the retention period of your data, please contact us using the Contact Form.
11. Technical and organizational measures and security of processing
All the information we receive about you is stored on secure servers and we have implemented appropriate technical and organizational measures to protect your personal data. HereYoGo.net, continuously assesses the security of the network and the adequacy of its internal information security program, which is designed to: (a) help you secure your data against accidental or unlawful loss, access or disclosure; (b) Identify reasonably foreseeable risks for HereYoGo.net security, (c) minimize security risks, including risk assessment and periodic testing. In addition, we ensure that all payment data is encrypted using SSL technology.
Please note that despite the measures we have implemented to protect your data, data transfer over the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.
When you leave our Platform, we encourage you to read the privacy notice of each website you visit.
13. Contact details for any additional information or to exercise your rights, please check your account settings or contact our Data Protection Officer using the Contact Form or the Help section on our Platform.
14. Data Protection Authority the Local Data Controller is: “Berliner Beauftragte für Datenschutz und Informationsfreiheit”
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