A User of the Application (“User”, “you”) may exchange goods or services with other Users, launch initiatives, announce events, submit reports or get to know other Users better by registering a personal account on the Application (the “Account”).
You might not always be aware, but using our Application 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 person.
The collection and processing of Personal Data is governed by strict legislative conditions in order to 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 European legislation concerning data protection (“GDPR” or “General Data Protection Regulation”) in order to protect everybody’s privacy with regard to automatic registration of personal data, which applies from 25th May 2018 onwards.
2. Personal Data we collect
We may collect several types of Personal Data from the Users of our Application, and store it on our servers such as:
Contact information (e.g. your name, postal address and 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;
Information in helpdesk support inquiries;
Web behaviour information such as information related to how the Users use the Application (e.g. browser type, domains, page views) collected through cookies and other automated technology (section 6 “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 Area.
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 Application. 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 Application a safe, optimal and personalized experience. Dependent on whether the User makes intensive use of the Application 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”):
creating and managing your Account in order to use the Application;
providing you access to and participation on the Application, the Platform and the Account, and the use of the Services;
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 Application;
contact users to obtain testimonials, user and/or neighbourhood stories;
performing data analyses (only through anonymization and aggregation of Personal Data);
the operation, evaluation and improvement of the Application (including the development of additional products and/or services, enhancing and improving the current Application, analysis of our Application, 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 other liabilities;
Furthermore, you agree that HOPLR is free to access, retain, and disclose Personal Data in the following events:
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
You may register on the Application 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 private neighbourhood group on the Platform, we must verify your home address in order to ascertain that you actually live in that particular neighbourhood. Therefore, a one-time unique access code (“Access Code”) shall be 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 Application or;
after approval of your request by one of the neighbourhood ambassadors or;
after sending a letterhead that proves your address to firstname.lastname@example.org.
Please be aware that any Data provided by you on the Platform is also accessible and visible towards other Users in your neighbourhood.
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.
The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Application (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is promptly deleted on a regular basis.
7. Disclosure to Third Parties
We may also share Personal Data with Third Party cloud providers and service providers who help us to provide, understand and improve the Application. 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.
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.
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 possible.
Please note that you can change your Account Information at any time through the settings on your Account.
Information can be provided to the data subject in writing, electronically or verbally as per Art. 12(1), depending on the circumstance. According to Art. 12(3) GDPR information must be provided without undue delay but at latest within one month. Only in reasoned cases may this one-month deadline be exceptionally exceeded. As a rule, the information has to be provided free of charge.
9. Data retention and deletion
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 Data.
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 Application 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.