Privacy Policy

Last updated and effective as of July 13, 2023.

1. OVERVIEW

Habu builds software applications for privacy-preserving data collaboration, real-time analytics, automated segmentation, and optimization across all of the major cloud providers.

This Privacy Policy explains how Habu, Inc. (“Habu, “we,” or “us”) processes personal information collected:

  • through our website, https://habu.com/, and any other websites, applications, tools, services, and platforms where this Privacy Policy is posted or linked (collectively, the “Digital Properties”) and any services available through the Digital Properties;
  • in connection with our business development and marketing activities; and 
  • through our other offline and business interactions with you.
  • Collectively, we refer to our interactions with you as the “Services.” 

By accessing or using the Services, you are agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services.

In this Privacy Policy, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.

Please note that this Privacy Policy does not apply to personal information that we receive from or collect on behalf of our customers for processing on their behalf in connection with the delivery of our products and services to them (“Customer Data”). The processing of Customer Data is governed by our customers’ privacy policies and the agreements that we have in place with them.  

You should read this Privacy Policy in full to understand what information we collect, how we use it, and the circumstances in which we may disclose it.

This Privacy Policy may change over time. If we make changes to it, we will post a modified version of this Privacy Policy on our website, www.habu.com/privacy-policy. The date at the top of this page indicates when this Privacy Policy was last revised. We encourage you to visit this page periodically to learn of any updates.

CALIFORNIA NOTICE AT COLLECTION

We collect the categories of personal information (as defined in the California Consumer Privacy Act (CCPA)) listed in the table below.

Category of Personal Information Collected

Sold or Shared

Identifiers, including names, email addresses, online identifiers, IP addresses, account names, and other similar identifiers.

Yes

Personal information categories listed in the California Customer Records statute, including names, telephone numbers, and employment information (e.g., company name and job title).

NOTE: Some personal information included in this category may overlap with other categories.

Yes

Commercial information, including products or services purchased, obtained, or considered and business-related information.  

Yes

Internet or other electronic network activity information, including information regarding interactions with the Digital Properties and advertisements. 

Yes

Geolocation data, such as IP location.

Yes

Audio, electronic, visual, or similar information, including phone call recordings.  

Yes

Inferences, which are drawn from any of the information in the above-listed categories of information.

No

Sensitive personal information, including account log-in information in combination with passwords.

No

As further described in this Privacy Policy, we generally collect and use the above-listed categories of personal information to provide and manage the Services and achieve legitimate business or commercial purposes.

As noted in the table above, we “sell” or “share” (as these terms are defined in the CCPA) certain categories of personal information, and you may exercise your right to opt out of such disclosures by clicking the “Privacy Settings” link in the footer of our website (https://habu.com/privacy-settings/) and following the instructions.

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in this Privacy Policy, including to satisfy legal or reporting requirements.

More information, including a description of your legal rights, can be found below in the “California Privacy Rights” section.

2. WHAT INFORMATION WE COLLECT

We collect personal information from and about you when you use the Services or otherwise interact with us. As further described in this section, we may receive your personal information: (1) directly from you; (2)  automatically as you use the Services; and (3) from third parties.

Information You Choose to Submit.

We receive personal information that you choose to provide to us, including when you send us an email or submit information through the Digital Properties.

Depending on the context of your interactions with us and the Services, the categories of personal information that we may collect directly from you include:

  • Contact information, including your name and business contact information (e.g., telephone number and email address).
  • Professional and employment-related information, including your company name and job title.
  • Correspondence and communications, including recordings of our email and phone conversations with you and any correspondence related to providing you with the Services.
  • Preferences, including how frequently you wish to receive marketing and promotional communications from us.
  • Other information you choose to provide, including information you include in any webforms that you complete and submit on the Digital Properties and other information that you provide during your interactions with us. 

Information We Automatically Collect.

We and our third-party service providers and partners (including any third-party content, advertising, and analytics providers) automatically collect certain information from your device and/or web browser when you interact with the Digital Properties. The specific types of information we (and our service providers and partners) may collect include:

  • Device and browser information, including the Internet Protocol (IP) address and/or other unique identifiers assigned to your device; the location of your device (generally derived from your device’s IP address); and other information about your browser, device, and operating system. 
  • Usage information, including information about your interaction(s) with the Digital Properties (e.g., the date and time of your visit(s); the area(s) or page(s) that you visit; the amount of time you spend on a page or using the Digital Properties; the domain name from which you accessed the Digital Properties; and other click-stream or usage information). 

In addition, we (and our service providers and partners) use tracking technologies, such as cookies, local storage, and pixel tags to collect certain information when you interact with the Digital Properties, as described further below.

Cookies and Local Storage

Cookies and local storage may be set and accessed on your device. Specifically, upon your first visit to the Digital Properties, a cookie or local storage will be sent to your device that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your device’s browser and stored on your device when you visit a website. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you may not be able to sign in to the Digital Properties or take full advantage of the Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.

The Digital Properties use the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Analytics and Performance Cookies

These cookies are used to collect information about traffic to and use of the Digital Properties. The information gathered is aggregated and does not identify any individual visitor. It includes the number of visitors to the Digital Properties, the websites that referred them to the Digital Properties, the pages that they visited on the Digital Properties, what time of day they visited the Digital Properties, whether they have visited the Digital Properties before, and other similar information. We use this information to monitor the level of activity on the Digital Properties, to gather broad demographic information, and to help operate the Digital Properties more efficiently.  

We use Google Analytics for this purpose. Google Analytics uses its own cookies. The service is only used to improve how the Digital Properties work. You can find out more information about Google Analytics cookies here: https://developers.google.com/…. You can find out more about Google Analytics’ information handling practices and how you can control the use of information sent to Google here: https://policies.google.com/technologies/partner-sites.  If you wish to  prevent your information from being  used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on,  available via this link: http://tools.google.com/dlpage…

Essential Cookies

These cookies are essential to provide you with services available through the Digital Properties and to enable you to use their features. For example, they allow you to log in to secure areas of the Digital Properties and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Digital Properties. Specifically, these cookies allow the Digital Properties to remember choices you make, such as your language preferences, and other relevant information, such as your login details,  which polls you have voted in, and the changes you make to other parts of the Digital Properties  that you can customize. These cookies also enable us to identify you across various screens and devices as you log in and use the Digital Properties, as well as enable us to work with partners to resolve your digital identities and personalize your experience across the Digital Properties,  across the services of our partners and customers, and across channels.

Social Media Cookies

These cookies are used when you share information using a social media platform’s sharing button or “like” button on the Digital Properties or when you link your account or engage with our content on or through a social media platform,  such as Facebook, Twitter, LinkedIn, or Pinterest. The social media platform  will record your activity and other information in accordance with its privacy policy. These cookies may also be used to show you interest-based advertisements on other online services. 

 

Flash Cookies

A Flash cookie is a data file placed on a device via the Adobe Flash plug-in that is built into or downloaded by you onto your device. Flash cookies are used for various purposes, including, without limitation, to enable a Flash feature and remember your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/supp…. If you choose to adjust your Flash privacy settings on your device, please note that some of the Digital Properties’ features may not function properly.

Pixel Tags

We also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Digital Properties  and collect usage data. A pixel tag can collect information, such as the IP address of the device that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on the device. 

We use pixel tags to collect information about your visit, including the pages you view, the links you click, and other actions taken on the Digital Properties. We also use them in combination with our cookies to provide offers and information of interest to you. Similar functionality may be enabled in a mobile app through the use of an SDK (Software Development Kit).

Pixel tags also enable ad networks to serve targeted advertisements to you when you visit the Digital Properties  or other websites.

Other Similar Technologies 

Other parties may integrate our widgets on their websites. When you visit a website with our widgets embedded, we may receive certain information, including information you actively submit as well as usage data.

In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes.

For more information about the use of cookies and similar technologies on the Digital Properties, please review our Cookie Policy. You can also find more information about cookies, including how they work and how to manage and delete them at http://www.allaboutcookies.org

Interest-Based Advertising 

We use third-party tools and services to serve interest-based advertisements to you across the internet. These tools may include cookies, pixel tags, and/or other similar technologies that automatically collect, store, and/or transmit certain information about your interaction(s) with the Digital Properties and other websites and mobile apps that you interact with and use across devices. Our third-party service providers and partners use the collected information to serve advertisements to you and measure the performance of our advertising campaigns. To learn more about your interest-based advertising choices, please see the “Your Choices” section below.

Information We Obtain from Other Sources.

We may obtain your personal information from other sources, such as our customers; data providers; affiliates within our corporate group of companies; our business partners, such as joint marketing partners and event co-sponsors; and publicly accessible sources.

The information that we receive from other sources may include contact information, Internet or other electronic network activity information, and inferences.

We use the personal information that we receive from other sources to help us maintain the accuracy of or supplement the information we collect; personalize your experience with the Services; conduct internal business analysis; and fulfill other business or commercial purposes described in this Privacy Policy. 

Combination of Information.

We may combine the personal information that we receive from and about you, including information you provide to us, information we automatically collect through the Digital Properties, and information we receive from third-party sources. Where applicable, we will use, disclose, and protect the combined information for the purposes described in this Privacy Policy. 

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes:

  • To provide, develop, improve, and personalize the Services.
  • To provide you with information, products, or services that you have requested.
  • To process information with machine learning algorithms, which helps us build, personalize, and improve the Services.
  • To maintain security and prevent fraud, such as to detect, investigate, and prevent harmful, fraudulent, and illegal activity and security issues and protect the rights, property, privacy, and safety of Habu and others.
  • To enable communications through the Services.
  • To contact you for administrative purposes (e.g., to respond to your comments and questions) and to send you important updates and communications about this Privacy Policy and/or other applicable terms and conditions. 
  • To send you marketing and promotional communications, including emails about additional Habu services you might be interested in (with your consent, where required by law). Details on how to exercise your choices with respect to marketing and promotional communications can be found in the “Your Choices” section below.
  • To engage in interest-based advertising, including to serve you interest-based advertising across the devices you may use. Details on how to exercise your choices with respect to interest-based advertising can be found in the “Your Choices” section below. 
  • To conduct research and analytics, including to analyze usage trends and preferences in order to develop new products, services, and features. 
  • To satisfy our legal obligations, including to comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement authorities and other government officials.
  • To support our business operations and business transactions, including to administer our general business and other related functions and to carry out sales or other business transactions. 

We will also use your personal information for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

4. TO WHOM WE MAY DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information to the following categories of third parties:

  • Our Affiliates and Subsidiaries. We disclose your personal information to our affiliated companies, including our parent company, subsidiaries, joint ventures, and other companies under common control with us. We require these entities to honor this Privacy Policy.
  • Our Service Providers. We disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf. These companies are obligated by contract to safeguard any personal information they receive from us.
  • Our Analytics Providers. We disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Services and our marketing and advertising efforts. 
  • Our Marketing and Advertising Partners. We disclose your personal information to our marketing and advertising partners, including social media platforms, third-party advertising networks, and other parties that assist us in serving, measuring the performance of, and optimizing our advertising campaigns. 
  • Our Business Partners. We disclose your personal information to other companies with whom we partner to provide the Services and carry out other activities described in this Privacy Policy. For example, we will disclose personal information to third parties who co-sponsor a promotion with us.
  • Governmental and Public Authorities. We will disclose your personal information to governmental and public authorities if  we believe that disclosure is reasonably necessary to comply with a law, regulation, or valid legal process (e.g., subpoenas or warrants served on us). If we are required to release your personal information, we will do our best to provide you with notice in advance by email, unless we are prohibited by law from doing so.
  • Relevant Third Parties in Connection with a Business Transaction. In the event we go through a business transition (such as a merger, acquisition by another company, or sale of all or a portion of our assets, including, without limitation, during the course of any due diligence process), or in the event of any insolvency, bankruptcy, or receivership, your personal information will likely be among the assets transferred to one or more parties as one of our business assets. Should such a transfer occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this Privacy Policy, we will request that you receive prior notice.
  • Other Parties. We disclose your personal information to other parties as we believe necessary or appropriate either to: (1) comply with applicable law; (2) protect our operations and those of our affiliates and subsidiaries; (3) investigate and prevent against fraud and other illegal activity; (4) protect our rights, privacy, safety, property, and/or those of others (e.g., our employees, customers, users, etc.); or (5) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your information. Additionally, we will disclose your personal information with your consent or when you direct us to do so.

Please note that we de-identify, anonymize, or aggregate personal information in a variety of ways and use and disclose such information for various purposes, including to improve the Services and as otherwise permitted by law. 

5. YOUR CHOICES

We respect your privacy and provide you with the ability to make certain choices about how we use your personal information, as described below. 

Marketing and Promotional Communications 

You can opt out of receiving marketing and promotional communications from us at any time by clicking the unsubscribe link found at the bottom of any such communication that you receive from us or by updating your account preferences. Please note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries/requests. 

Cookies 

As noted above, we (and our third-party service providers and partners) use cookies on the Digital Properties for various purposes, including for analytics and advertising purposes. You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Please refer to your device’s settings or your browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences. Additional information about cookies, including how to manage and delete them, can be found here: https://allaboutcookies.org/.

Interest-Based Advertising

Certain websites/platforms and mobile devices allow you to exercise choices with respect to interest-based advertising, as described below.

  • Web browsers: You may be able to opt out of receiving interest-based advertising using the browser opt-out tools and consumer choice mechanisms provided by interest-based advertising self-regulatory groups by following the links below:
  • Digital Advertising Alliance (DAA): https://optout.aboutads.info/?c=2&lang=EN
  • Network Advertising Alliance (NAI): https://optout.networkadvertising.org/?c=1
  • European Interactive Digital Advertising Alliance (EDAA): https://youronlinechoices.eu/
  • Mobile devices: You have the ability to control whether you see interest-based advertisements on your mobile device in the following ways:
  • Device settings: Your device operating system may provide mechanisms that allow you to opt in or opt out of the use of information about your usage of mobile apps to deliver interest-based advertising to your mobile device. For more information, consult your device settings.
  • AppChoices tool: The DAA offers a tool for opting out of the collection of cross-app information on a mobile device for interest-based advertising. To exercise your choices with respect to participating companies, please download the AppChoices tool available here: https://youradchoices.com/appchoices.

Some of our advertising partners may provide you with additional choices with respect to interest-based advertising. For example, certain social media platforms may allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information. 

6. INFORMATION SECURITY AND RETENTION 

We use industry standard technical, administrative, and physical controls designed to protect your personal information while under our control. While we take reasonable precautions against possible security breaches, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or another breach will never occur.

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy our legal or reporting requirements, unless a longer retention period is required or allowed under law.   

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk from unauthorized use or disclosure of the personal information; the purpose(s) for which we use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law. 

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION 

Depending on your country of residence, your personal information may be transferred to countries or regions with data protection and privacy laws that differ from those in your country of residence.

By using the Services, you acknowledge that your personal information may be transferred outside of your country of residence. You also understand that your personal information may be stored in the United States and may be subject to lawful requests by the courts or law enforcement authorities in the United States.

If you are situated in the European Economic Area, Switzerland, or the United Kingdom, please note that whenever we transfer your personal information to countries or regions that have not been recognized by the European Commission, the Swiss government, and/or the UK government as providing an adequate level of protection for personal information, we ensure that appropriate and suitable safeguards are in place to protect your information. In particular, we may use government-approved contracts that provide appropriate safeguards for personal information that is transferred to countries that have not been recognized as providing an adequate level of protection. For more information about how we lawfully transfer your personal information internationally, please contact us as specified below.    

7. THIRD-PARTY SERVICES

The Digital Properties  may contain links to and from third-party services. If you follow a link to any of these services, please note that the service is owned and operated by a third party. Any personal information collected by third-party services is subject to the services’ respective  privacy policies, and we do not accept any responsibility or liability for such policies. We encourage you to review all third parties’ privacy policies before providing them with your personal information.  

MINORS’ PRIVACY

The Services are not intended for or directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18.  

8. CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act, as amended by the California Privacy Rights Act and implementing regulations (collectively, the “CCPA”) provides California residents with certain rights in relation to their personal information (as defined in the CCPA). Pursuant to the CCPA, this section, which supplements the rest of this Privacy Policy, applies to residents of California and contains additional details regarding our collection, use, and disclosure of personal information relating to California residents. This section also describes the rights available to California residents in relation to their personal information and how they can exercise their rights. 

Personal Information Collection and Disclosure

The following chart details which categories of personal information we have collected from and about California residents in the past twelve (12) months, the source(s) of each category of information, the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties to whom we have “sold” or with whom we have “shared” each category of information (as such terms are defined in the CCPA) (where applicable). Please note that the first column in the chart lists by category the types of information described in the “What Information We Collect” section above, as required by the CCPA. 

Categories of Personal Information

Categories of Sources

Disclosures of Personal Information for a Business Purpose

Sale or Sharing of Personal Information

Identifiers, including names, email addresses, account names, online identifiers, IP addresses, and other similar identifiers.

Directly from individual

Through automated means

Third-party sources 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries 
  • Our Service Providers
  • Our Analytics Providers
  • Our Business Partners

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

  • Our Analytics Providers
  • Our Marketing and Advertising Partners (including social media platforms and advertising networks)

Personal information categories listed in the California Customer Records statute, including names, telephone numbers, and employment information (e.g., company name and job title).

NOTE: Some personal information included in this category may overlap with other categories.

Directly from individuals

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries 
  • Our Service Providers
  • Our Business Partners

 

Commercial information, including products or services purchased, obtained, or considered.

 

Directly from individuals

Through automated means

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  •  Our Service Providers

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

  • Our Analytics Providers
  • Our Marketing and Advertising Partners (including social media platforms and advertising networks)

Internet or other electronic network activity information, including information regarding interactions with the Digital Properties and advertisements.

 

Through automated means

 

Third-party sources

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  • Our Service Providers
  • Our Analytics Providers

We have sold or shared this category of information in the past 12 months to or with the following categories of third parties:

  • Our Analytics Providers
  • Our Marketing and Advertising Partners (including social media platforms and advertising networks)

Geolocation data, such as IP location.

Through automated means

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  • Our Service Providers
  • Our Analytics Providers
 

Audio, electronic, visual, or similar information, including phone call recordings.

 

Directly from individuals

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  •  Our Affiliates and Subsidiaries
  • Our Service Providers

 

Professional or employment-related information, including employer names and job roles/titles.

 

Directly from individuals

 

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  • Our Service Providers

 

Inferences, which are drawn from any of the information in the above-listed categories of personal information.

 

Through automated means

Third-party sources

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  • Our Service Providers

 

Sensitive personal information, including account log-in information in combination with passwords.

Directly from individuals

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our Affiliates and Subsidiaries
  •  Our Service Providers

 

 

Purposes for Collecting Personal Information  

We collect the categories of personal information listed in the chart above for our commercial and business purposes, as further described in this Privacy Policy and in the section titled “How We Use Your Personal Information.” 

Our business purposes (as defined in the CCPA) for collecting personal information include:

  • Auditing related to counting ad impressions to unique visitors; 
  • Helping to ensure security and integrity; 
  • Debugging to identify and repair errors;
  • Short-term, transient use; 
  • Performing services (on our behalf), such as account servicing, processing orders and payments, and providing analytics services;
  • Undertaking internal research for technological development; and 
  • Undertaking internal activities to verify, maintain, and improve the Services. 

Disclosures of Personal Information 

As detailed in the “To Whom We May Disclose Your Personal Information” section of this Privacy Policy, we disclose personal information to fulfill specific processing purposes. We will also disclose certain categories of personal information to competent governmental and public authorities and other third parties as necessary or appropriate, including when we have a legal or contractual obligation to disclose the information.

Sale and Sharing of Personal Information

We “sell” and “share” (as such terms are defined in the CCPA) certain categories of personal information to and with third parties. Additionally, as detailed in the chart above, we have “sold” and “shared” certain categories of personal information in the past twelve (12) months for analytics and advertising purposes. Please refer to the chart above for additional details.

We do not “sell” or “share” the personal information of minors we know to be under the age of 16.

Use and Disclosure of Sensitive Personal Information

As detailed in the chart above, we collect certain “sensitive personal information” (as defined in the CCPA). However, we do not use or disclose sensitive personal information for any purpose outside of the limited permissible purposes set forth in the regulations implementing the CCPA. These purposes include providing the Services and preventing, detecting, and investigating security incidents. 

Your Legal Rights 

If you are a California resident, you may exercise the following rights with respect to your personal information, subject to certain exceptions and limitations:

  • The right to know the following information: 
    • the categories of personal information we have collected about you and the categories of sources from which we collected such information;
    • the specific pieces of personal information we have collected about you;
    • the business or commercial purposes for collecting, selling, or sharing your personal information; 
    • the categories of third parties to whom we disclosed your personal information; and
    • if we sold, shared, or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales and shares, identifying the personal information categories that each category of recipient received; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
  • The right to delete the personal information we have collected from you.
  • The right to correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

To exercise any of the above-listed rights, please click the Privacy Settings link in the footer of this page.

 

Verification Process and Required Information 

We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require the matching of up to three pieces of personal information provided with your request with information we maintain to verify that it is you making the request. If you have a password-protected account with us, we may verify your identity through the existing authentication practices for your account, in which case we will require you to re-authenticate yourself before we further process your request. Please note that we may decline a request where we are unable to verify your identity and confirm the personal information we maintain relates to you.

Authorized Agent 

You may authorize someone to submit a privacy rights request on your behalf (an “authorized agent”). An authorized agent will need to demonstrate that you have authorized them to act on your behalf, unless you have provided the agent with power of attorney pursuant to applicable probate law. Depending on the evidence provided, we may also contact you to verify your identity with us, as described above, or request confirmation from you that the agent is authorized to submit the request on your behalf.

Exercise Your Sale and Sharing Opt-Out Rights

As detailed in the chart above, we “sell” and “share” certain categories of personal information to and with third parties. If you are 16 years of age or older, in addition to the rights described above, you have the right to direct us to not “sell” or “share” your personal information at any time. To exercise your opt-out right, you may submit a request to us by clicking the “Do Not Sell My Personal Information” link in the footer of our website (https://habu.com/) and following the instructions.

Alternatively, where available, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including Habu. If you enable a browser-based opt-out preference signal that complies with the CCPA, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

An authorized agent may also use the methods described above to submit an opt-out request on your behalf if you provide the agent with signed permission to do so. Please note that we may request from the agent documentation demonstrating that they have your authority to act on your behalf.

Non-Discrimination

Habu will not discriminate against you if you decide to exercise  any of the rights described above.

9. NEVADA PRIVACY RIGHTS

This section, which supplements the rest of this Privacy Policy, applies to residents of Nevada. Under applicable law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.

To exercise this right, please click the “Privacy Settings” link in the footer of this page.

10. PRIVACY SHIELD NOTICE

Habu complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information  transferred from the European Union and Switzerland to the United States pursuant to the Privacy Shield. Habu has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.

This Privacy Shield Notice applies to the categories of personal information described in the “What Information We Collect” section above. We collect and use personal information about individuals in the European Union and Switzerland for the purposes described in the “How We Use Your Personal Information” section of this Privacy Policy. Personal information covered by this Privacy Shield Notice is collected and used only as permitted by the Privacy Shield Principles. Where necessary and appropriate, Habu obtains consent prior to using or disclosing personal information.

Consistent with the Privacy Shield Principles, Habu may disclose personal information to the categories of third parties identified in the “To Whom We May Disclose Your Personal Information” section of this Privacy Policy. Generally, we will only disclose personal information to third parties if it is:

  • to a third party providing services to us;
  • made with an individual’s permission or consent;
  • necessary to meet our legal obligations, including responding to lawful requests by public authorities and meeting national security or law enforcement requirements; or
  • reasonably necessary for legal or regulatory compliance purposes or for the establishment of legal claims.

The Privacy Shield Principles describe Habu’s accountability for personal information that it subsequently transfers to a third-party agent. Under the Privacy Shield Principles, Habu shall remain liable if third-party agents process the personal information in a manner inconsistent with the Privacy Shield Principles, unless Habu proves it is not responsible for the event giving rise to the damage.

As specified in the Privacy Shield Principles, individuals whose personal information is covered by this Privacy Shield Notice have the right to access the personal information that Habu maintains about them. If you are interested in accessing your personal information; requesting that we update, correct, or delete your personal information; or exercising any of the other legal rights listed in the “Additional Information for Individuals in the EEA, Switzerland, and the UK” section of this Privacy Policy, including limiting the use and disclosure of your personal information, you can write to us at:

Habu, Inc.
Attn: Privacy
23 Geary Street, Suite 600
San Francisco, CA 9410

In compliance with the Privacy Shield Principles, Habu commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding this Privacy Shield Notice should first contact Habu at the postal address below:

Habu, Inc.
Attn: Privacy
23 Geary Street, Suite 600
San Francisco, CA 94108

Habu has further committed to refer unresolved Privacy Shield complaints to VeraSafe, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please review the following page and contact VeraSafe for more information: VeraSafe Privacy Shield Dispute Resolution Procedure. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here. The services of VeraSafe are provided at no cost to you.

In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means. For more information, please visit https://www.privacyshield.gov/article?id=G-Arbitration-Procedures

Habu is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

NOTE: Habu recognizes that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information originating from the EU or Switzerland. Nonetheless, the U.S. Department of Commerce, which oversees compliance with the Privacy Shield, has stated that it will continue to administer the Privacy Shield program and that participants are not relieved of their obligations under the Privacy Shield. Accordingly, Habu continues to comply with its commitments under the Privacy Shield until such time as the Data Privacy Framework becomes available.

11. ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA, SWITZERLAND, AND THE UK 

This section only applies to individuals in the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”). 

Legal Basis for Processing

Applicable law requires us to set out the “legal basis” that we rely on to collect and use your personal information. Where applicable the legal bases upon which we rely to collect and use your personal information are as follows:

  • Consent. We may collect, use, and disclose your personal information on the basis of the consent that you provide at the point of information collection or disclosure. Where required by law, we will rely on your consent for direct marketing and to collect information from your device via cookies and other similar technologies.
  • Contractual Necessity. We may collect and use certain personal information where it is either necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This may include personal information used to provide you with the Services.
  • Compliance with a Legal Obligation. We are subject to various legal requirements in the jurisdictions in which we operate, including tax and accounting obligations. Accordingly, we may use, disclose, and retain your personal information if necessary for us to comply with a legal obligation arising under applicable law.
  • Legitimate Interests. We may collect and use your personal information to the extent necessary to carry out our legitimate interests (or those of a third party), provided that such interests do not outweigh your interests or fundamental rights and freedoms. For example, we may collect and use your personal information in reliance on a legitimate interest in managing our relationship with you; conducting and managing our business; providing you with customer support; offering, developing, and enhancing the Services; detecting and preventing fraud and other harmful activities; and monitoring and maintaining the security of our information systems and networks.

Your Legal Rights

You may have certain rights in relation to your personal information, including the right to:

  • request confirmation as to whether we are processing your personal information, and if so, to request access to your personal information and details regarding our processing;
  • request correction or rectification of any inaccurate or incomplete personal information that we hold about you;
  • request deletion of your personal information (subject to applicable exceptions);
  • object to our processing of your personal information under certain circumstances;
  • request that we restrict our processing of your personal information in certain circumstances;
  • request that we transmit your personal information to a third party (where technically feasible);
  • withdraw the consent you have provided us to process your personal information (without affecting the lawfulness of any processing carried out before you withdrew your consent); and
  • lodge a complaint about the way we handle or process your personal information with the appropriate data protection regulator. 

If you are interested in exercising any of the above-listed rights, you can do so by accessing the “Privacy Settings” link in the footer of this webpage.

In order to protect your privacy and confirm that you are entitled to exercise the above-listed rights, we may need to request specific information from you to help us confirm your identity. Where applicable, we will use the requested information for verification purposes only. 

Habu will offer individuals located in the EEA, Switzerland, and the UK whose personal information  has been transferred to us the opportunity to choose whether the personal information we have received may be used or disclosed for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt out of such uses or disclosures of their personal information by visiting our Privacy Settings center. 

VeraSafe has been appointed as Habu’s representative in the European Union for data protection matters, pursuant to Article 27 of the EU General Data Protection Regulation. If you are located in the European Union, have questions or concerns regarding the processing of your personal information, and are unable to reach Habu via submitting a request through our Privacy Settings portal, you can contact VeraSafe using the contact details below:

Web: Complete and submit this form

Telephone: Dial +420 228 881 031

Postal mail: Write to: 

VeraSafe Netherlands BV
Keizersgracht 391 A
1016 EJ Amsterdam
The Netherlands

VeraSafe has been appointed as Habu’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the UK General Data Protection Regulation. If you are located in the United Kingdom, have questions or concerns regarding the processing of your personal information, and are unable to reach Habu via submitting a request through our Privacy Settings portal, you can contact Verasafe using the contact details below:  

Web: Complete and submit this form: [https://verasafe.com/public-resources/contact-data-protection-representative

Telephone: Dial +44 (20) 4532 2003

Postal mail:  Write to: 

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom

CONTACT US 

If you have any questions about this Privacy Policy our privacy practices, or if you wish to make a request, you can write to us at :

Habu, Inc.
Attn: Privacy
23 Geary Street, Suite 600
San Francisco, CA 94108

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