PRIVACY POLICY
OF HYPERLOCAL INC.

General premise

Below is a detailed privacy policy nevertheless we want to assure you that we collect data about your interests, activities, inquiries and services in order to best match our offerings to your needs. We may provide this data to subcontractors (e.g., for the purpose of sending out mailings), to the manufacturer of the merchandise to which the collaboration relates, or to the HYPERLOCAL partner that we believe can best and most efficiently serve you. If you do not wish us to further process your data, notify us at the address indicated in the regulations - we will stop processing it in accordance with applicable regulations.

This cookie policy applies to all websites and mobile apps owned by Hyperlocal Inc.

The Privacy Policy contains information on who is the administrator of your personal data, for what purpose, scope and for what period they will be processed, and to whom and on what terms we can disclose your data, and what rights you have in connection with their processing.

We publish this Privacy Policy in order to provide the information required by the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data, effective from May 25, 2018. ("GDPR"). Whenever we talk about data below, we mean your personal data provided to us or obtained by us from other sources, e.g. name and surname, e-mail address, home address, tax identification number, data on the method of payment and telephone number.

The controller of your personal data is Hyperlocal Inc. 162 N Franklin St, STE 696, Chicago IL 60606, USA (also referred to as "HYPERLOCAL", the "Company" or the "Administrator")

You can contact the Administrator at: rodo@feneste.com

Data provided by the User

We process data from activities such as: recording activities made while browsing the site (pages visited, interests, etc.) this includes cookies and similar technologies or applications, data left when contacting us (via contact form, chat, phone, instant messenger, etc.). In this way, we collect contact details, such as name, surname, telephone number, e-mail address, address (city, postal code, apartment number). We process the described data in order to enable HYPERLOCAL to send you advertising or demonstration materials, to establish contact including sending you a business offer, or to answer your question.

Providing personal data is voluntary, however, the consequence of failure to provide data may be, depending on the case - no answer to the question asked or refusal to present an offer or information about products.

The User (the person using the HYPERLOCAL service) should not provide the Administrator with personal data of third parties. If, on the other hand, he/she provides such data, it is tantamount to providing an assurance to HYPERLOCAL that he/she has the relevant consent of third parties to provide the data to the Administrator.

As the Administrator, we collect personal data provided by the User, such as e-mail address, first and last name, telephone number, place of work or business data - if you contact us as part of work or business, residence address, tax identification number, data on how to making payments.

Other data of visitors to HYPERLOCAL websites

The administrator collects data contained in system logs (this is information that the visitor's computer transmits to the server each time he/she connects to the website, it may contain various data, e.g. IP address) and also data resulting from cookies (about which see below). The data comes from the user's browser (Chrome, Edge, Mozzilla, Opera, etc.) and is also transferred by Facebook and Google. IP addresses are used by the Administrator to collect general, statistical information (e.g. about the place from which the connection is made). In addition, data on visitors to the website and their preferences may be captured and disclosed in the form of statistics, but such statistics remain anonymous and do not contain data and features that allow for the identification of individual persons. The data described in the previous sentence are not combined with the personal data of people browsing the Website.

By using the websites and applications, you consent to the use of cookies in accordance with this policy. If you do not agree to our use of cookies, you should change your browser settings appropriately or opt out of using websites and applications.

Cookies

Cookies are small files that are saved and stored on your computer, tablet or smartphone as you visit various sites on the Internet. A cookie usually contains the name of the website it comes from, the "lifetime" of the cookie (that is, its lifetime) and a randomly generated unique number used to identify the browser from which the website is connected. The company may also use other technologies with functions similar or identical to cookies.

The HYPERLOCAL website uses Facebook, FreshMail, GetResponse and also Google. Facebook and Google provide web analytics services.

You can refuse your consent or withdraw it at any time by changing the appropriate browser settings or software installed on the device you are using. Therefore, we recommend that you check your settings and possibly make changes in line with your privacy preferences. Remember that you can change the settings in such a way as to block the automatic handling of cookies. If you give your consent that the settings of the software you are using enable the handling of cookies, it is tantamount to your consent to their use in accordance with the principles described in this Privacy Policy. In this case, we will be entitled to use cookies and similar technologies to store information or access information stored on your device. If you disable cookies, you may have difficulties using some of the functionalities of our websites.

The administrator may use personal data for automated decision making, including profiling. As a result of such activities, the Company does not make decisions that are based solely on automated decision making, including profiling, which would cause legal effects. The use of this data may be used for advertising activities, which will most often be based on statistical data, not constituting personal data. This means that visitors to the Administrator's websites may be displayed advertising content about the Company while visiting other websites.

What do we use cookies for?

HYPERLOCAL uses cookies for a variety of purposes: to make sites and applications run faster and easier to use, to better tailor content and advertising to your expectations and interests, and to collect anonymous, aggregate statistics that help improve the functionality and content of sites and applications. "Cookies" may also be used to maintain user sessions, authenticate people using the website and provide Users with personalized advertising content and measure the effectiveness of advertisements, obtain information about the source from which a given person came to our website (for example, a link displayed on a foreign website ). By using cookies in the manner described above, we never identify the identity of users on the basis of information stored in cookies.

Data retention period

Personal data will be retained only for the period necessary to fulfill the specific purpose for which they were sent or for the purpose of compliance with the law.

For individual cases, the data processing time is as follows: a) if we process your data on the basis of a contract, the processing will continue as long as the contract is in force and the period of limitation of any claims, b) if you have consented to the processing for a specific purpose, we will process your personal data until you withdraw your consent, c) information that we process as part of the implementation of a legitimate interest, we will process as long as this interest lasts.

In special cases, which are data processing for direct marketing purposes, including profiling, we may process your data until you object. We will process the data processed in order to fulfill our obligations under applicable law as long as it results from these provisions.

Sharing personal data

We provide your personal data to third parties only to manage your online purchases. They are only received by: our partners (e.g. product distributors, service technicians), window manufacturers as well as communication agencies that send order confirmations, warehouses and courier companies that deliver orders, entrepreneurs who make payments, banks that check your identity and creditworthiness when you buy in installments, debt collection companies and law firms, if necessary to obtain receivables or verify claims. Personal data may be transferred to entities processing them at the request of the Administrator, namely persons providing technical services, in particular in the field of maintaining IT systems and websites. Personal data may be transferred to a third country.

Google Analytics performs an analysis of the viewership of websites indicated by Google, Inc. . Google Analytics uses "cookies". The information generated by the cookie about the User's use of the website (including its IP address) will be transferred to Google. The above information is usually transferred to a Google server, which may be operated in the USA and stored there. On this website, the IP anonymization function is activated. This means that only an approximate location is possible. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and network usage.

User permissions

HYPERLOCAL uses appropriate technical and organizational security measures designed to ensure confidentiality, protection against unauthorized or unlawful processing and accidental loss, destruction or damage of data. Data is protected through the use of appropriate technologies, we comply with applicable law, and we use and develop solutions that will ensure the security of your data. The basic means of protection is the use of secure connections (e.g. SSL protocols), data encryption and the use of other technical, programming or organizational solutions (e.g. limiting and controlling access to data). We assure you that your data is processed only by authorized persons and entities.

The user whose personal data is processed by the Administrator has access to his data and the right to rectify, delete, limit processing, the right to transfer data, the right to object to data processing, the right to withdraw consent at any time without affecting the lawfulness of processing (if the processing takes place on the basis of consent), which was made on the basis of consent before its withdrawal.

Exercising the rights set forth in the paragraph above can be done by sending an appropriate request to rodo@feneste.com to the Administrator's mailing address, together with the User's name and electronic mail (e-mail) address. Alternatively, an employee of HYPERLOCAL may be contacted.

We reserve that if you exercise the rights indicated above, it is possible that we will cease to provide certain services or cease delivery of goods (in whole or in part), if the processing of certain personal data is necessary to perform the service.

The user has the right to lodge a complaint with the supervisory body if he considers that the processing of his personal data violates applicable regulations. The competent supervisory authority is: President of the Personal Data Protection Office, Stawki 2, 00-193 Warsaw.

Changes to the privacy policy

HYPERLOCAL's Privacy Policy is subject to change. Any changes to the Privacy Policy will be published on the Company's website. In the case of significant changes, we will mark the modified fragments in the published consolidated text.

The previous versions of the Privacy Policy will be kept in the Company's archives.