Hookle Privacy Policy

 

Last Updated: September 17, 2019

 

This Privacy Policy describes how we collect, use and share personal information received from users of this website, located at https://www.hookle.net/ (the "Website"), Hookle's mobile application (the "App"), as well as all related websites, applications, and other services provided by Hookle (collectively, together with the Website and the App, the “Service”). This Privacy Policy is incorporated into and is subject to the Hookle Terms of Service.

 

By using the Service, you consent to the collection, transfer, storage, disclosure, deletion, combination, and use of your personal information as described in this Privacy Policy now and as amended by us. 

 

We operate in accordance with the General Data Protection Regulations (GDPR), and we fulfill the requirements of the Personal Data Act §26 of the Finnish law. The Service is hosted in Finland. You have control over your personal information: you decide, how much of your personal details you want to share with others. You can control your privacy level from Hookle’s settings.

Information Collection and Use

 

Our main purpose in collecting information from you are to provide you with the products and services made available through the Service, to communicate with you, and to manage your registered user account, if you have one. We may also use your information to operate, maintain, and enhance the Service and its features, and to provide customer support to users.

 

You provide us with information when you register for an account, use the Service, make a purchase on the Service, or send us customer service-related requests. The use of certain parts of the Service requires you to become a registered user and to submit certain personally identifiable information to Hookle. Information that we collect may include your IP address, full name, user name, password, email address, city, time zone, credit card and other billing information, preferences, telephone number, and other information that you decide to provide us with. We may link such information with other information you provide about yourself.

 

When you visit the Website, our servers may automatically record information that your browser, computer, or mobile device sends, including your IP address, access time, browser and device type, the web pages you visit, the search terms you use, the advertisements on which you click, the region from which you access the Website, and other similar information, in order to monitor the use of the Website and the Service, and for any kind of technical administration.

 

The following information on each user of the Hookle App is recorded in our database to facilitate the provision of the Service: username(s), access token(s), profile picture(s), user actions, and the posts, posts insights and their attached content (such as pictures and/or videos), for each of the social media accounts that you use the App for (including but not limited to Facebook, LinkedIn, and/or Twitter). We log your IP address for security reasons and the analytics data for usage feedback when you use the App. You can delete your account information from our databases, if you so choose, by using the "Delete profile" function in the App or by emailing us. You also have the right to see what information we hold about you; you can request this information by emailing us (contact info below).

 

If you participate in our surveys, ambassador program, contests, events (such as webinars and in-person events), or those in which we are affiliated, or request information from us about our Services, we may collect information about you related to the survey, contest, or event; your contact information, such as your name, email address, telephone number, organization name and address; and general information about your organization that you choose to provide, such as annual company revenue, number of employees, and industry.

 

In addition, we may collect information on email open and click rates, including whether individuals clicked on links, and which web pages are visited after opening the email.  

 

We collect information you choose to provide to us when applying for employment, which may include contact information, education and employment history, credentials, your CV and LinkedIn profile information.
 

Use of Contact Information for Marketing Communications

 

We may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to the Service. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or send your opt-out request to us by email provided below. Even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

 

Cookies and Automatically Collected Information

 

Hookle uses "cookie" tracking technology to help us recognize you across the Service, to collect additional website usage data, and to improve the Website and the Service. A cookie is a small text file placed on your device. Hookle may use both session cookies and persistent cookies. A session cookie enables certain features of the Website and the Service and is deleted from your computer when you disconnect from or leave the Website. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. Persistent cookies can be removed in your web browser settings. You can also instruct your browser to not accept cookies or to prompt you before accepting a cookie. If you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. Hookle does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use the Service.

 

We may also automatically record certain information about your device, activity, and use of the Service by using various types of technology, including but not limited to “web beacons” and "software tokens." This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information may be connected with other information about you.

 

We may display third-party content on the Service, including third-party advertising. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing or accessing of the third-party content on the Service. Information collected through third-party web beacons and other mechanisms is collected directly by these third parties, not by Hookle. Information collected by a third-party in this manner is subject to that third-party’s own data collection, use, and disclosure policies.
 

Information Sharing and Disclosure

 

Our primary purpose for using your information is to publish and/or monitor your content on social platforms such as, but not limited to, Twitter and Facebook. In addition, we may share and disclose your information for the following reasons:

 

Service Providers. We may engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, billing, customer relationship management, database storage and management, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

 

Compliance with Laws and Law Enforcement. Hookle cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Hookle or a third-party, to protect Hookle against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service and any equipment used to make the Service available, or to comply with the law.

 

Business Transfers. Hookle may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt-out of any such transfer if the new entity's planned processing of your information differs materially from that set forth in this Privacy Policy.

 

Other Third Parties. We may make certain aggregated or otherwise non-personal information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.
 

Changing, Deleting and Retaining of Information

 

If you are a registered user of the Website, you may access, update, correct, or delete the information you provided to us by emailing us. Any changes you make will be reflected in active user databases within a reasonable period of time. However, we may retain all information you submit as long as required to provide the Services requested by you, for record keeping purposes, for backups, archiving, prevention of fraud and abuse, analytics, to comply with our legal obligations, resolve disputes, and enforce the terms for the Services or where we otherwise reasonably believe that we have a legitimate reason to do so.

 

After it is no longer necessary for us to retain information about you, we will dispose of it in a secure manner or anonymize the information.

 

Our Services retrieve and display content from social networks. Beyond temporary storage for performance reasons, we do not store content unless you take specific action in relation to such content (such as using our Services to prepare draft content for publication on social networks). In some cases, content may continue to exist on the social networks even after you or we delete it from our Services, and you will need to contact the relevant social network directly if you want to delete such content.

 

Security

 

The security of your personal information is important to us. We employ various measures designed to protect your information from unauthorized access. Please be aware that no security measures are perfect or 100% bulletproof. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or through the Website without unreasonable delay, consistent with the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

 

Links to Other Websites

 

The Service contains links to other websites. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third-party. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to read the privacy policies or statements of the other websites you visit.

 

Our Policy Towards Children

 

The Service is not intended for persons under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe that a child under 13 has provided us with personally identifiable information, please contact us by email provided below. If we learn that we have received personal information from a child under 13, we will delete such information.

 

Legal bases for processing when Hookle is a data controller

 

The legal bases for processing information about you include:

 

a) Your consent (for example, when you have provided your information to sign up for an account or you have provided employment history when applying for a job). Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time. 

 

b) It is necessary to perform a contract (for example, we may need your information to comply with our obligations of providing Services to you under the terms relevant to the Services you have acquired).


c) Legitimate interest (for example, to provide and maintain the Services to you, to maintain the security of the Services, and to attract new customers to maintain demand for the Services).

 

d) In some cases, we may have a legal obligation to process your personal data to comply with relevant laws (for example, processing payroll and tax information to comply with relevant employment and tax legislation).

 

Changes to the Privacy Policy

 

This privacy policy is effective as of May 24, 2018. We reserve the right to update this Privacy Policy at any time; the most recent version of the Privacy Policy is available at https://www.hookle.net/privacy. We will notify you of any modifications to our Privacy Policy by posting the new Privacy Policy on our Website and indicating the date of the latest revision. You are advised to check this Privacy Policy regularly for any changes. In the event that the modifications, in our sole discretion, materially alter your rights or obligations regarding your use of the Service or the treatment of your personal information, we will make reasonable efforts to notify you of the change via email or other electronic communication methods. Your continued use of the Service after the revised Privacy Policy has become effective constitutes acceptance of the latest version of this Privacy Policy.

 

How to contact us

 

If you have any questions, concerns or feedback, please email us: contact[at]hookle.net / Data Protection Officer. Or send a letter to:

 

Hookle Inc.
Mannerheiminaukio 1 A, 00100 Helsinki 
FINLAND
Attn: Data Protection Officer

 

If we are unable to resolve your concerns, you also have the right to contact your local data protection authority.