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Privacy Policy

Last Updated December 28, 2024

Introduction

This Privacy Policy for Hoongry Srls ("Company", "we", "us", or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as:

  • Visiting our website at https://www.hoongry.com/ or any website of ours that links to this privacy policy

  • Downloading and using our mobile application (Hoongry) or any other mobile application of ours that links to this privacy policy

  • Engaging with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@hoongry.com.

Key Points Summary

This summary provides the key points of our privacy policy, but you can find out more details about any of these topics by clicking on the link following each key point or by using our table of contents to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Hoongry Srls and the Services, the choices you make, and the products and features you use.

Do we process sensitive personal data?

We do not process sensitive personal data.

Do we receive information from third parties?

We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We will only process your information when we have a valid legal reason to do so.

In what situations and with what parties do we share personal information?

We may share information in specific situations and with specific third parties.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights?

The easiest way to exercise your rights is to contact us at info@hoongry.com. We will consider and act upon any request in accordance with applicable data protection laws.

Summary

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. ON WHAT LEGAL BASES DO WE RELY TO PROCESS YOUR PERSONAL DATA?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. DO WE COLLECT INFORMATION FROM MINORS?
  11. WHAT ARE YOUR PRIVACY RIGHTS?
  12. CONTROLS FOR DO-NOT-TRACK FEATURES
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names
  • Phone numbers
  • Email addresses
  • Usernames
  • Billing addresses

Payment data

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Stripe. You can find their privacy policy link here:

https://stripe.com/en-it/privacy

Social media login data

We may offer you the ability to register with us using your existing social media account details, like Facebook, Twitter, or other social media accounts. If you choose to register in this way, we will collect the information described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.

Application data

If you use our applications, we may also collect the following information if you choose to provide us with access or permission:

  • Geolocation information
  • Mobile device data
  • Push notifications

Information collected automatically

In short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

  • Log and usage data
  • Device data
  • Location data

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide you with marketing, offers, and services relevant to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties. These information sources may include postal addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and customized profiles, for targeted advertising and event promotion purposes. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log into your account, as well as keep your account in working order.

  • To provide and facilitate the provision of services to the user. We may process your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.

  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, consultants, and other third-party service providers

We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protecting the data they hold on our behalf and to retaining it for the period we instruct. The third parties we may share personal information with are as follows:

  • Advertising, Direct Marketing, and Lead Generation (Google AdSense, Facebook Audience Network, AppsFlyer e TikTok)
  • Allow users to connect to third-party accounts (Account Google, Apple Sign in)
  • Cloud computing services (Google Cloud Platform, Amazon Web Services (AWS), Azure)
  • Communicate and chat with users (Sendgrid, Zendesk)
  • Infrastructure functionality and optimization (Cloud Firestore, Termly.io, Firebase Legacy e SiteGround Hosting)
  • Billing and invoicing (Stripe)
  • Retargeting platforms (Remarketing di Google Ads, Pubblico personalizzato di Facebook e Remarketing di Facebook)
  • User account registration and authentication (Accedi con Google, Accedi con Apple)
  • Web and mobile analytics (Google Analytics e Google Analytics per Firebase)
  • Website hosting (Google Cloud)
  • Website performance monitoring (Crashlytics, Sentry, Hotjar)
  • Website testing (Google Play Console, TestFlight e Appcenter)

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may need to share your personal information in the following situations:

When using Google Maps Platform APIs

We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To learn more about Google’s Privacy Policy, please refer to:

https://policies.google.com/privacy

Offers

Our applications may display an 'offers wall' hosted by a third party. Such an offers wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in exchange for accepting and completing an advertisement offer. Such an offers wall may appear in our applications and be shown to you based on certain data, such as your geographic area or demographic information. When you click on an offers wall, you will be redirected to an external website owned by other persons and will leave our applications. A unique identifier, such as your user ID, may be shared with the provider of the offers wall to prevent fraud and properly credit your account with the appropriate reward.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our:

Cookies Policy

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). If you choose to do this, we will receive certain profile information from your social media provider. The profile information we receive may vary depending on the concerned social media provider, but will often include your name, email address, friend list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

7. CAN YOUR INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Europe and the United States. If you access our Services from outside of these regions, please be aware that your information may be transferred to, stored, and processed by us and by those third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in the United States and other countries.

If you reside in the European Economic Area (EEA) or United Kingdom (UK), these countries may not have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

European Commission Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for data transfers between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal data they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than nine (9) months after the user's account is closed.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and collect, access, steal, or modify your information.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to the use of the Services by such minor dependent. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@hoongry.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In short: You may review, change, or terminate your account at any time.

Below is a summary of your rights regarding the protection of personal data you provide:

(i) You may request access to and obtain a copy of your personal information, (ii) You may request rectification or erasure; (iii) You may restrict the processing of your personal information; and (iv) If applicable, you have the right to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

Withdrawing your consent: You have the right to withdraw your consent at any time by contacting us using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or by updating your preferences.

Marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, by contacting Hoongry directly, or by using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from marketing lists. However, we may still communicate with you, for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If at any time you would like to review or change the information in your account or terminate your account, you can:

  • Access your account settings and update your user account.
  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can choose to configure your browser to remove cookies or reject them. If you choose to remove or reject cookies, this may affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services, visit:

If you have questions or comments about your privacy rights, you can email us at info@hoongry.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Matteo Antolini, by email at info@hoongry.com or by post at:

Hoongry Srls Matteo Antolini Via Caselle, 5, 37054 Nogara VR, Italy Nogara, Veneto 37054 Italy

If you are a resident in the European Economic Area, the 'data controller' of your personal information is Hoongry Srls. Hoongry Srls has appointed Matteo Antolini as its representative in the EEA. You can contact them directly regarding the processing of your information by Hoongry Srls, by email at info@hoongry.com, or by post at: Via Caselle 5 Nogara, Verona 37054 Italy

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form to:

info@hoongry.com