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Hooha Advocacy Technology Limited – Privacy Policy

This privacy policy has been compiled to serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully.  It provides clear guidelines as to how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website and app.

Who we are and how to contact us

Where Hooha Advocacy Technology Limited collects and processes your personal data, it is the data controller for the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679) and / or any applicable legislation adopted by the United Kingdom post the United Kingdom ceasing to be a Member State of the European Union (“Data Protection Legislation”).

If you have any questions regarding the Privacy Statement you can contact us at:

  • Hooha Advocacy Technology Limited, 126 Drymen Road, Bearsden, Glasgow, Scotland, G61 3RB; and / or
  • [email protected].

If you are unhappy with how we handle your personal information you can:

  • submit a complaint in writing for the attention of Craig at Hooha Advocacy Technology Limited, 126 Drymen Road, Bearsden, Glasgow, Scotland, G61 3RB or by email to [email protected]; or
  • notify the Information Commissioner’s Office (ICO) by calling their helpline on: 0303 123 1113.

What personal information do we collect about you?

Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address.

We will collect the personal information that you provide to us when registering for the Buzzl App:

  • Full Name;
  • Email Address;
  • Your password;
  • Mobile Number;
  • Date of Birth;
  • Your Full Address and Postcode (and geolocation information);
  • Your Sex or Gender;
  • Your likes and interests and preferences;
  • Information about your contacts in the Buzzl App (eg. friend interactions, messages, referrals, and other user generated content);
  • Your interactions and communication with any third party brands through our Buzzl App, including content reviewed;
  • Photos, reviews, forum and social posts and videos you may have provided to us.

We will also collect personal information that you may provide to us when we provide our services to you, by corresponding with us by phone, e-mail, post, or otherwise.

We also may receive personal data and other online and offline information from third parties with whom we conduct business, such as merchants, co-marketers, distributors, resellers, and other companies or organizations with whom we enter into agreements to support our business and operations, including advertising partners and third party data providers that provide us with supplemental or additional information about our customers (collectively “Partners”).

We will only receive data from our Partners where they are legally permitted to share such data, and we will only process that data for the purposes described below.

Please contact us at  [email protected] as soon as possible after there is any change to your personal details, including your contact details. You can also update your information directly through the Buzzl App.

How do we use personal information?

Services: Hooha Advocacy Technology Limited will use your personal information to:

  • register and manage your account, including to allow you access to and use of our Buzzl App;
  • notify you about special offers and products or services available from our affiliates, or our Partners that may be of interest to you;
  • allow you to enrol or participate in any programs provided on behalf of or together with our Partners, with your consent or as necessary to provide the services you requested;
  • send you vouchers or other promotions;
  • make inferences about your likes, interests or preferences;
  • help you receive an offer or promotion with the relevant partner or affiliate for the products or services;
  • communicate with you in relation to the services we are providing;
  • enable communication between registered users and owners/representatives of listings on our Buzzl App;
  • create more personalised and customised experience for you, for example, based on your location to provide you reviews and promotions for brands near where you are;
  • understand how our merchants are performing;
  • enable us to publish your reviews, posts, photos, videos and other content; and
  • provide ongoing service and support, answer your questions and comments, resolve disputes or troubleshoot problems.

Surveys: Occasionally we may also use your information to contact you to complete surveys that we use for quality assurance purposes. Third party brands may wish to contact you to complete surveys for quality assurance purposes, please refer to their Privacy Policies as noted below.

What legal basis do we rely on?

Services: We will use your personal information for the above services purposes as is it necessary for the performance of a contract that we have with you (the Terms of Use Agreement). If you do not wish to provide the personal information requested you may not be able to proceed with the services offered on our Buzzl App or the Terms of Use Agreement.

Surveys: We will use your personal information to contact you to complete surveys on the basis of our legitimate interest. Our legitimate interest is ensuring that our products / services remain of quality standard. You have the right to object to us using your personal information in this way and you can do this by contacting us at [email protected].

With whom do we share personal information?

Hooha Advocacy Technology Limited contracts with third party goods and service providers, Partners and suppliers to deliver complete services and customer solutions and create more customised offers and services for each customer. We may share personal information (on an anonymised basis) with service providers and suppliers for the sole purpose and only to the extent needed to support the customers’ needs based on the customer’s interactions with the third party goods and service on the app. Service providers and suppliers are required to keep confidential the personal information received from Hooha Advocacy Technology Limited and may not use it for any purpose other than as originally intended.

The personal data we share with our Partners will not include your basic personal details, contact details, device details, profile inputs, and will we will only share with our Partners the following on an anonymised basis:

  • demographic information, (e.g. details about age brackets);
  • location data (e.g. information about postal code); and
  • promotion and deal information from third party sites (e.g. information about acceptance of offers and deals on other sites).

The following third parties may have access to your personal information for the purposes noted below:

  • the Partners that join Buzzl App and provides us with offers, promotions and vouchers that are relevant to you;
  • other users of the Buzzl App;
  • any other person who is authorised to act on your behalf;
  • the party that provides us with the online chat functionality and emails services, who is currently Twillio, Inc (processing data in the US which is covered by Standard Contractual Clauses);
  • the party that provides with our search functionality, who is currently Algolia, Inc (processing data in the EU (France));
  • the party that provides authentication platform Firebase, who is currently Google, Inc (processing data in the US which is covered by Standard Contractual Clauses);
  • regulators, government departments, law enforcement authorities, tax authorities and insurance companies;
  • any relevant dispute resolution body or the courts; and
  • persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business.

Some of these entities may also be data controllers under the Data Protection Law. However in the first instance you should contact Hooha Advocacy Technology Limited using the contact details above if you have any queries.

Except as provided above, Hooha Advocacy Technology Limited will not share personal information with any other third parties without your permission, unless required by, or in connection with, law enforcement action, subpoena or other litigation, regulation, or applicable law.

Hooha Advocacy Technology Limited will not sell, trade or lease your personal information to others.

European Economic Area

The data that we collect from you will usually be stored inside the UK or the European Economic Area (EEA).

However, if you live or work outside of the UK or the EEA, we may need to transfer your personal data outside of the UK or the EEA to correspond with you.  Where this applies, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

We also may transfer data outside the UK or the EEA where our, service providers host, process, or store data outside the UK or the EEA. Where we do this, we will ensure that the transfer is to a country covered by a decision of the European Commission or is otherwise made in circumstances where we have put appropriate safeguards are in place to protect your data in accordance with the Data Protection Law, such as entering into Standard Contractual Clauses..

By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Statement.

Retention Periods

We will not hold your personal information for any longer than is necessary for the “uses” outlined above, unless we are required to keep your personal data to comply with the law and any regulatory requirements.

We will retain your information in accordance with the following retention periods:

Data subjects rights

You have certain rights under the Data Protection Legislation which can be exercised by contacting [email protected], including:

  • the right to access the personal data held about the you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive;
  • the right to have your personal data rectified if it is inaccurate or incomplete;
  • the right to have your personal data deleted in certain specific circumstances as set out in the Data Protection Legislation;
  • the right to restrict the processing of your personal data in certain specific circumstances as set out in the Data Protection Legislation;
  • the right to ask us not to process your personal data for marketing purposes or for purposes based on our legitimate interests; and
  • where you have provided consent, to withdraw such consent at any time.

Further details about your rights can be found on the ICO’s website at https://ico.org.uk/.

Please note that if you choose to exercise your rights to have personal data restricted or deleted, then we may not be able to customise the relevant offer or services under the Buzzl App or provide you with our services.

Security of personal information

To protect the privacy of any personal information you may have provided, Hooha Advocacy Technology Limited employs industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring.

Links to the other websites and third parties

Where applicable, we may provide links to third-party web sites or social networking sites for your convenience and information or to offer you an opportunity to interact with friends and share on social networks. If you access those links, you will leave the Hooha Advocacy Technology Limited website and Buzzl App. Our Partners may also have their own privacy statements. Hooha Advocacy Technology Limited does not control those sites or their privacy practices, which may differ from ours. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the Hooha Advocacy Technology Limited Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third party companies may choose to share their personal data with us; that sharing is governed by that third party company’s privacy policy.

Verification

Hooha Advocacy Technology Limited will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

Hooha Advocacy Technology Limited
126 Drymen Road
Bearsden
Glasgow, Scotland
G61 3RB

Reg: 559771

[email protected]