Privacy Policy HOPLR
Date of last revision: 25 May 2018
1. General
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 “Web Application”) or via the official Android and iOS applications (the “Mobile applications”). Please read this Privacy Policy carefully before using our Web Application and/or Mobile Applications (hereinafter together referred to as the "Application") (“Services”).

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.

We consider the protection of your privacy to be very important and want to be very clear about this, therefore we have prepared this Privacy Policy. HOPLR shall solely use your Personal Data for purposes mentioned in this Privacy Policy and we shall not disclose your Personal Data to any natural or legal person or entity other than HOPLR (“Third Party”), unless stated otherwise in this Privacy Policy.

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.

This Privacy Policy applies to the relationship between HOPLR and the User. HOPLR undertakes to process, store and utilize the User’s Personal Data in accordance with this Privacy Policy and in accordance with the provisions of the Privacy Act.

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 with this Privacy Policy.
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;
  • complying with and enforcing any applicable legal obligations, our Terms of Use and Privacy Policy.
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;
  • to enforce the HOPLR Terms of Use or Privacy Policy;
  • 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 Application or his Account, including Personal Data (“Data”) in accordance with the Terms of Use.

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.

To gain access to the closed group of your local neighbourhood on the Platform, you must first provide your home address. In the event that you have received an access code ("Access Code") via an invitation letter, you can speed up the registration process. 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 Hoplr or;
  • after sending a letterhead that proves your address to verify@hoplr.com.
Please be aware that any Data provided by you on the Platform is also accessible and visible towards other Users in your neighbourhood. Always be careful about what you share online.
5. Security
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.
6. Cookies
When using the Application, 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 Application, increase security, measure use and effectiveness of the Application, identify and resolve issues and marketing purposes. We may also use cookies and other automated means for purposes such as management of the Application 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 Application (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 your browser to disable, clear, reset or block the use of cookies or similar technologies. Please note, however, that without cookies the Application may not work properly or you may not be able to use all of its features.

Third Parties may also use cookies to collect information about User’s activities on our Application to understand and continue improving the performance of our Application. Please check the relevant Third Party’s website for more information about their use of cookies as they will use cookies in accordance with their own cookies policy, which may differ from our policy.

7. Disclosure to Third Parties
Other than as set out in this Privacy Policy, we do not sell, transfer or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent, unless this is necessary for the Purpose set out in this Privacy Policy, or unless we are required to do so by law.

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 Party to use any Personal Data strictly consistent with this Privacy Policy.

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.

In any event, such Third Party service providers shall be obliged to treat your Personal Data in accordance with this Privacy Policy. However, we cannot be held liable for any damages, 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.

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.

The User shall be able to exercise the above mentioned rights, or pose any questions concerning this Privacy Policy, through a signed, written request to HOPLR, by post to Hoplr NV, Waterhoenweg 3, B-9160 Lokeren, or by e-mail at info@hoplr.com.

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
We may retain information regarding you and your use of the Application, including Personal Data, for as long as reasonably needed to provide you with the Services and the Purpose described in this Privacy Policy. Afterwards, the Personal Data of the User shall be deleted.

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.
11. Updates or changes to our Privacy Policy
It is possible that our Privacy Policy is subject to future modifications and amendments to allow 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 collection, we will provide you with a notice on our Application indicating that the Privacy Policy has been changed or updated.
Data Controller:
Hoplr NV
Waterhoenweg 3
B-9160 Lokeren
Email: info@hoplr.com