HOPLR (“HOPLR”, “we”, “us”) offers a private social network platform for your local
neighbourhood, focusing on social interaction and engagement between residents in a certain
neighbourhood, and with limited access on such platform solely to the local neighbourhood
relevant for you (the “Platform”) via www.hoplr.com (the “Website”) (“Services”). A User of the
Website (“User”, “you”) may exchange goods or services with other Users, launch initiatives,
announce activities, submit reports or get to know other Users better by registering a personal
account on the Website (the “Account”).
You might not always be aware, but using our Website implies sharing some Personal Data with
HOPLR. According to the legal definition, personal data is any data related to an identified or
identifiable natural person (“Personal Data”). It is sufficient to qualify as Personal Data if the
data allow us to lay a, direct or indirect, link between one or more data pieces and a natural
We consider the protection of your privacy to be very important and want to be very clear about
to any natural or legal person or entity other than HOPLR (“Third Party”), unless stated
The collection and processing of Personal Data is governed by strict legislative conditions in
order provide you, as a User, the necessary guarantees that your Personal Data will not be
inappropriately disclosed. Each processing shall therefore always be consistent with the
applicable privacy legislation, this is the Belgian Privacy Act of 8 December 1992 on the
protection of privacy regarding the processing of Personal Data (“Privacy Act”).
undertakes to process, store and utilize the User’s Personal Data in accordance with this
While using HOPLR and its Services, we assume that each User has taken note of this Privacy
Policy and accepts the collection and processing of Personal Data by HOPLR in accordance
2. Personal Data we collect
We may collect several types of Personal Data from the Users of our Website, and store it on
our servers such as:
Contact information (e.g. your name, postal address, e-mail address);
The profile data provided by you on your Account (e.g. profile picture, date of birth,
gender, personal and professional interests, social network profile, job, pets,
demographics, and password);
The profile data as provided by you on your social network profile and as collected by
HOPLR upon registration of the User through this social network profile, as well as
afterwards upon synchronisation, for as long as the User consents hereto (e.g. User
likes, User activities, User friends);
Information in helpdesk support inquiries;
Web behaviour information such as information related to how the Users use the
Website (e.g. browser type, domains, page views) collected through cookies and other
automated technology (section 7 ‘Cookies’);
Location information allowing HOPLR to determinate a User’s location.
We shall solely store your Personal Data on our servers located in the European Economic
3. What are the purposes of the data collection and processing?
HOPLR (i) collects, (ii) uses, (iii) maintains and (iv) may share the Personal Data provided by
the User or collected by HOPLR with its affiliates, parent companies or other related companies
for all purposes necessary to ensure the proper functioning and operation of the Accounts
and/or the proper (technical) functioning of the Website. HOPLR may share Personal Data
provided by the User or collected by HOPLR for all purposes necessary to provide the Services.
In general, HOPLR collects your Personal Data for an overarching goal: offering each User of
the Website a safe, optimal and personalized experience. Dependent on whether the User
makes intensive use of the Website or relies on certain Services, the collection of Personal Data
may be more extensive.
The purposes for data collection and processing may include (collectively the “Purpose”):
providing you access to and participation on the Website, the Platform and the Account,
and the use of the Services;
creating and managing your Account in order to use the Website;
providing you with information from HOPLR such as notifications on use, maintenance
and warnings, but also personal messages;
diagnosing technical problems and managing technical support and processing inquiries
concerning the Website;
contacting the Users to (i) send promotional materials or other communications,
communicate about, and organize your participation in market research or (ii) obtaining
testimonials or other promotional material;
performing data analyses (including anonymization and aggregation of Personal Data);
the operation, evaluation and improvement of the Website (including the development of
additional products and/or services, enhancing and improving the current Website,
analysis of our Website, quality control activities and performing internal business
functions such as accounting and auditing);
protecting against, identify and prevent fraud and other unlawful activity, claims and
Furthermore, you agree that HOPLR is free to access, retain, and disclose Personal Data in the
in order to be in compliance with any applicable legislation or regulations;
if a law enforcement authority or other government official requests so;
the investigation of any suspected or actual fraudulent or illegal activity; and
to protect User’s or HOPLR’s safety and/or rights.
4. User registration
HOPLR requires Users to register an Account in order to participate on the Platform. Every User
is and remains in control with regards to all information, data, texts and images uploaded on the
You may register on the Website by signing up via your e-mail, or through any of your social
network profiles, such as Facebook. We shall collect your Personal Data from such social
network profile solely for the purpose of creating your Account and providing information on the
Account, as well as keeping your Personal Data up-to- date by regular synchronisation.
In order to get access to your local neighbourhood group on the Platform, we must ask your home address in order to ascertain that you actually live in that particular neighbourhood. Then, a one-time access code (“Access Code”) is requested that was sent to your home address through an invitation letter. Access to the closed group of your local neighbourhood on the Platform shall be solely granted after validation of your Access Code on the Website or after approval by one of the founders.
Please be aware that any Data provided by you on the Platform is also accessible and visible
towards other Users, unless you have indicated that you do not wish certain Data to be public.
HOPLR shall take appropriate administrative, technical and organizational measures against
unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or
damage, access, disclosure or use.
In the event of and following discovery or notification of a breach of the security of the Personal
Data, or access by an unauthorized person, HOPLR is required by law to notify the User if the
breach is likely to affect your privacy.
When using the Website, HOPLR may collect certain information by automated means, such as
cookies (small text files stored in your browser) and similar technologies, including mobile
application identifiers, to improve User’s experience of the Website, increase security, measure
use and effectiveness of the Website, identify and resolve issues and marketing purposes. We
Website and other aspects of the commercialization of our business.
The information we collect in this manner includes IP address, browser characteristics, device
characteristics, operating system version, information on actions taken on our Website (such as
usage, activity logs and click-throughs), and dates and times of visits. Log data is promptly
deleted on a regular basis.
You can control cookies through your browser settings and other tools. You may be able to set
note, however, that without cookies the Website may not work properly or you may not be able
to use all of its features.
to understand and continue improving the performance of our Website. Please check the
cookies in accordance with their own cookies policy, which may differ from our policy.
7. Disclosure to Third Parties
Personal Data to Third Parties without obtaining your prior explicit consent, unless this is
In the event of full or partial merger with, or acquisition of all or part of HOPLR, HOPLR may
transfer your Personal Data to a Third Party. In such event, HOPLR shall impose this Third
We may also share Personal Data with Third Party cloud providers and service providers who
help us to provide, understand, commercialize and improve the Website. We do not authorize
these Third Party service providers to use or disclose your Personal Data except as strictly
necessary to perform any services under our supervision or to comply with applicable
legislation. We seek to provide any such Third Party service provider with only the Personal
Data they need to perform their specific function.
In any event, such Third Party service providers shall be obliged to treat your Personal Data in
whether direct or indirect, that may result from the misuse of your Personal Data by such Third
Party service providers.
8. My rights as a data subject?
Ensuring a safe and lawful processing of Personal Data, each User can be assured that his
Personal Data is being processed in a fair and lawfully manner. This means that the Personal
Data will only be processed for the above explicit and legitimate Purpose. HOPLR also ensures
that the processed Personal Data is always adequate, relevant and not excessive.
Each User can oppose the processing of his Personal Data by HOPLR at any time.
We may solely use your Personal Data to contact you through mail for direct marketing
purposes in the event that you have explicitly consented hereto. If you have consented
hereto in the past, and you no longer want to receive suggestions and/or direct
marketing through mail, you may at any time unsubscribe.
If you are concerned or have any questions about your Personal Data, and you can
prove your identity, you have the right to request access to your Personal Data which
HOPLR holds or processes about you. We will then provide you with information about
the Personal Data that is being processed and on the source of such Personal Data.
You have the right to request us, free of charge, to correct, erase or block any
inaccuracies in your Personal Data, if such Personal Data would be incomplete,
inaccurate or processed unlawfully.
Please note that you can change your Account Information at any time through the settings on
You have the right to request us, free of charge, to erase all your Personal Data collected,
stored and processed by us, without unreasonable delay. The erasure is mainly related to the
visibility, so it is possible that the deleted Personal Data remains temporarily stored, however
HOPLR shall take all reasonable steps to erase all Personal Data to the maximum extent
The User shall be able to exercise the abovementioned rights, or pose any questions
NV, Waterhoenweg 3, B-9160 Lokeren, or by e-mail at firstname.lastname@example.org.
9. Data retention and deletion
We may retain information regarding you and your use of the Website, including Personal Data,
for as long as reasonably needed to provide you with the Services and the Purpose described in
In the event that you have registered for an Account, please note that we retain your Personal
Data even if you temporarily stop using such Account, until you permanently delete your
Account. Up until deletion of the Account, we may retain and continue to use your Personal
10. Third Party websites or applications
You acknowledge and agree that certain content or services provided by Third Parties may be
made available to you through the Website or your Account. You agree that such linked content
or services may have their own privacy policies for which HOPLR cannot be held responsible.
HOPLR does not in any way review or endorse the privacy practices of such Third Parties.
us to use or share your previously collected Personal Data for other purposes. If HOPLR would
use your Personal Data in a manner materially different from that stated at the time of the
been changed or updated.