HILO ANALYTICS PLATFORM PRIVACY POLICY

In this Privacy Policy, HiLo Analytics Ltd, a private limited company organized and existing under the laws of England and Wales, whose registered office is at Suite 7, Hadfield House, Library Street, GX11 1AA Gibraltar (“HiLo Analytics”), states its practices regarding information that it collects from you or through your use of the website hosting the Platform, which is accessible via www.hiloanalytics.com (“Website”), how that information may be used, and with whom it may be shared (the “Privacy Policy”). User privacy is HiLo Analytics’ top priority. HiLo Analytics may use Personal Information and/or Cookies, as defined below, for the purpose of making the Website and/or Platform available to you in accordance with the Agreement. The data controller of your Personal Information is HiLo Analytics Ltd of Suite 7, Hadfield House, Library Street, GX11 1AA Gibraltar.

The Privacy Policy will be revised from time to time. HiLo Analytics Ltd will notify you of any revisions by posting the updated version of the Privacy Policy on the Website and/or the Platform. Revised terms become effective on the first date that you access or use the Website and/or Platform after the updated Privacy Policy has been posted. HiLo Analytics advises you to periodically check the Privacy Policy for any such modifications or revisions. In the case of any material changes to the Privacy Policy, we will also notify you via email at the email address you provided upon registration. You represent that you have read and understood the Privacy Policy.

Unless otherwise provided herein, defined terms shall have the meaning ascribed to them in the Terms of Use. The Terms of Use and the Privacy Policy constitute the entire agreement between you and HiLo Analytics (the “Agreement”). For purposes of this Privacy Policy, “use” shall mean any operation or set of operations performed on information provided by you, such as collection, use, storage, forwarding, and/or disclosure. “Process” shall be construed accordingly.

1. Personal Information

a) “Personal Information” refers to information that allows HiLo Analytics to identify you, directly or indirectly, by reference to an identifier, in the course of your registering for, accessing, and using the Website and/or Platform. Personal information shall be provided by you for the purposes of registration to the Platform and account creation; it includes name, address, email, telephone number, company/employer, job title, job department, and payment details. Failure to provide such Personal Information will result in your inability to register for, access, and use the Platform and its subsequent versions.

HiLo Analytics may also collect Personal Information automatically through your use of the Website and/or the Platform, such as IP address, date and time of access request, time zone difference to Greenwich Mean Time (GMT), specific site requested, HTTP status code, amount of data transmitted, the website from which you visit the Website, browser type, operating system and user interface, and language and version of browser software. Please refer to the section on Cookies and similar technologies below for more information.

b) HiLo Analytics may use your Personal Information to:

  • Process your registration for the purposes of using the Platform

  • Provide you with the services and products of the Platform, including but not limited to processing payments, if applicable, and providing you with customer support

  • Improve your interaction with the Platform

  • Notify you of any changes to the Website and/or the Platform

  • Communicate with you with respect to the Platform’s and/or HiLo Analytics’ services and products

  • Enforce the Agreement

  • Send you marketing communications, unless you have requested by written notice that your Personal Information not be used for the purposes of direct marketing

  • Request your participation in surveys related to the Platform, its services, and products, and administer such surveys

  • For HiLo Analytics’ respective business purposes, such as data analysis, usage analytics, audits, fraud monitoring and prevention, development of new products and services, improvement of products and services of the Platform, identification of usage trends, business development, and research. For these purposes, HiLo Analytics may de-identify and/or aggregate your Personal Information with other information.

c) HiLo Analytics does not generally share your Personal Information with any third parties. However, your Personal Information may be disclosed in the following circumstances:

  • By HiLo Analytics, for the uses described in the Privacy Policy. HiLo Analytics represents and warrants that it is required to comply with the same limitations regarding the use of Personal Information as set forth herein.

  • By HiLo Analytics to third-party service providers who provide services to HiLo Analytics, such as website hosting, data analysis, usage analytics, business development, payment processing, functionality development and improvement, information technology, customer support, and related infrastructure provision, provided that such service providers have provided HiLo Analytics with satisfactory assurances of their technical and organizational ability to provide appropriate and sufficient data protection in accordance with applicable law.

  • By HiLo Analytics to third-party providers of products or services that you purchase through the Platform.

  • If applicable, by HiLo Analytics to other users for the implementation of any functionality of the Platform.

  • By you, if applicable, to anyone with whom you communicate through the Platform.

  • By HiLo Analytics to a third party in the event of a merger, sale, or transfer of assets, joint venture, assignment, reorganization, bankruptcy, or other similar proceedings.

  • By HiLo Analytics to comply with any applicable law, including laws outside of your country of residence or outside of the European Economic Area; to respond to requests from courts or public and/or judicial authorities, which may include authorities outside of your country of residence or of the European Economic Area; to take precautions against liability; or to investigate and defend HiLo Analytics against any third-party claims or allegations.

  • By HiLo Analytics to protect the rights, privacy, security, safety, integrity, or property of HiLo Analytics, facilities or equipment used to make the services available, Platform users, or others, and to enforce the Agreement.

d) HiLo Analytics may retain your Personal Information for up to seven (7) years from the termination of your right to use the Platform and/or the Website, in accordance with the Terms of Use.

e) HiLo Analytics may transfer to, store, and use your Personal Information (for troubleshooting, customer support, usage tracking, and data storage purposes) in any country where HiLo Analytics related companies, affiliates, or third-party service providers are based, including countries outside of the European Economic Area, which may have lower levels of data protection than those applicable in the European Economic Area. HiLo Analytics also takes steps to protect Personal Information in the country in which it is stored, used, or to which it is transferred, and to ensure that any such data storage, uses, and transfers are subject to adequate safeguards.

f) You acknowledge that HiLo Analytics may use your Personal Information as provided for in this Privacy Policy in order for you to be able to use the Platform and/or the Website. If you do not wish your Personal Information to be used by HiLo Analytics as described herein, you may send an email to HiLo Analytics at sales@hiloanalytics.com. Requests are dealt with within seven (7) business days. However, please note that any objection by you to HiLo Analytics’ processing of your Personal Information will not affect the lawfulness of the use of your Personal Information up to that time and will result in the termination of your right to use the Platform and/or Website, in accordance with the Terms of Use.

g) HiLo Analytics has put in place appropriate technical, organizational, and other measures to protect your Personal Information from unauthorized or unlawful use and accidental loss or damage, and to provide a level of data protection that meets the requirements of applicable law. Such measures also apply to entities directly or indirectly controlling, controlled by, or under common control with HiLo Analytics. However, no data security measures are 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. HiLo Analytics suggests that you create a strong password, in case you are required to create one, and that you periodically change it. Moreover, if you have reason to believe that your interaction with HiLo Analytics and/or the Platform and/or the Website is no longer secure, please immediately notify HiLo Analytics at sales@hiloanalytics.com.

h) You may review, rectify, modify, update, or delete any of your Personal Information by sending an email to sales@hiloanalytics.com. You may also object to the use of any Personal Information for certain purposes in accordance with applicable law (for example, you have a right to object to your Personal Information being used for direct marketing purposes as well as certain rights to object to being profiled). You may also request HiLo Analytics to provide you with your Personal Information in a structured, commonly used, and machine-readable format, and to transmit such Information to a third party pursuant to your instructions. In case you believe that your Personal Information as used by HiLo Analytics is inaccurate, that the use of your Personal Information is unlawful, or that HiLo Analytics no longer needs the Personal Information you submitted to it for the designated purposes, you may also request the restriction of use by HiLo Analytics and/or its third-party service providers until the incident is investigated and resolved.

i) You shall not provide any Personal Information about others unless you are authorized to do so. By submitting Personal Information about others, you represent and warrant that you are authorized to do so, that you have received authorization from the person about whom you provide Personal Information, and, where required, that person has consented to having all such Personal Information submitted in accordance with this Privacy Policy.

j) You acknowledge and agree that employees of HiLo Analytics may gain access to your Personal Information. HiLo Analytics shall limit such access on a need-to-know basis. HiLo Analytics shall take all reasonable steps to ensure that such employees are informed of the nature of the Personal Information and comply with the provisions of this Privacy Policy.

k) You may contact sales@hiloanalytics.com regarding any questions about the Privacy Policy or any complaints or objections about the way your Personal Information has been processed by HiLo Analytics. You may lodge a complaint with any supervisory authority if you believe that the use of your Personal Information by HiLo Analytics infringes upon any applicable law.

l) The Website and/or Platform may include links to third-party websites or applications whose privacy policies may differ from ours. Any information that these third parties collect about you is governed by their respective privacy policies. We suggest that you contact those third parties directly to obtain information about their privacy policies.

2. Cookies and similar technologies

a) The Platform and the Website collect information about the use of the Platform and/or the Website. Such information may be collected: (i) through your browser or device; (ii) through cookies and similar technologies (such as beacons, pixels, and tags). Cookies contain a small amount of information downloaded to your computer or other device by the server of a website, page, or advertisement, which allows the originating website, page, or advertisement to recognize your computer or other device on subsequent visits. The Platform and the Website use both session-based cookies (which last only while your browser is open) and persistent cookies (enabling authentication, as well as other Platform features, each time you log on to the Website and/or the Platform), as well as third-party cookies, such as Google Analytics, subject to the respective service provider’s policies. You may opt out of third-party cookies on that provider’s respective website. Although most browsers accept cookies by default, you are able to set yours to alert you when cookies are being used, as well as to accept or reject cookies. You may also opt out of all or certain cookies used by the Website and/or the Platform, but please note that such opting out may significantly disrupt your use of the Website and/or Platform and that you may even lose the ability to access the Website and/or Platform. Cookies can be either associated with your account and Personal Information or used to perform analytics and personalization, among other things. The following types of cookies are used by the Platform and the Website:

  • strictly necessary/essential cookies (i.e., cookies that are necessary to enable you to browse the Website and use the Platform and its features, such as accessing secure areas of the Platform),

  • authentication and functionality cookies (i.e., cookies that are used to store login information, as well as to provide personalized services),

  • performance and analytics cookies (i.e., cookies that are used to collect information about the use of the Website and/or the Platform, as well as for the improvement and research of features and services of the Platform),

  • security cookies (i.e., cookies that are used for the detection of malware and the support of Website and/or Platform security),

  • preference cookies (i.e., cookies that are used for the provision of customized services and features),

  • marketing cookies (i.e., cookies that are used for launching and monitoring marketing campaigns and delivering customized advertising); (iii) through your use of the Platform and/or the Website (including but not limited to the date and length of visit, location data, traffic data, etc.); (iv) from you on a voluntary basis, such as information about your geographic and/or commercial preferences; and/or (v) by aggregating Personal Information, where such information does not personally identify you (collectively, “Electronic Tools”).

b) HiLo Analytics and its third-party service providers may use information collected through Electronic Tools for any purpose, such as the enhancement of navigation, functionality of the Platform, monitoring and analyzing the effectiveness of the Website and/or the Platform, as well as aggregating usage metrics, except where HiLo Analytics is required to do otherwise under applicable law.

c) If HiLo Analytics combines information collected through Electronic Tools with Personal Information, it will treat the combined information as Personal Information.