Privacy Policy of Hotspot Effect

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Hotspot Effect and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Internet or other electronic network activity information

Personal Data processed: Trackers; Usage data; Number of users; Session statistics + 28

Personal Information collected or disclosed:

• Trackers
• Usage Data
• number of Users
• session statistics
• Data communicated while using the service
• IP address
• first name
• last name
• date of birth
• phone number
• company name
• profession
• physical address
• country
• state
• county
• email address
• ZIP/Postal code
• various types of Data
• city
• User ID
• number of employees
• website
• various types of Data as specified in the privacy policy of the service
• billing address
• answers to questions
• clicks
• keypress events
• motion sensor events
• mouse movements
• scroll position
• touch events

Sensitive Personal Information collected or disclosed

password

Purposes:

• Analytics
• Building and running Hotspot Effect
• Collection of privacy-related preferences
• Contacting the User
• Displaying content from external platforms
• Handling payments
• Hosting and backend infrastructure
• Managing contacts and sending messages
• Registration and authentication
• Spam and bots protection
• Registration and authentication provided directly by Hotspot Effect

Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

No

Targeted Advertising:

No

Third-parties:

Google LLC, Hotspot Effect, iubenda srl, Square, Inc., Amazon Web Services, Inc., Intuit Inc., Automattic Inc.

Identifiers

Personal Data processed: Various types of data as specified in the privacy policy of the service; First name; Last name; Date of birth + 17

Personal Information collected or disclosed:

• various types of Data as specified in the privacy policy of the service
• first name
• last name
• date of birth
• phone number
• company name
• profession
• physical address
• country
• state
• county
• email address
• ZIP/Postal code
• various types of Data
• city
• User ID
• number of employees
• website
• Usage Data
• Trackers
• billing address

Sensitive Personal Information collected or disclosed

password

Purposes:

• Backup saving and management
• Contacting the User
• Further information about Personal Data
• Handling payments
• Hosting and backend infrastructure
• Infrastructure monitoring
• Managing contacts and sending messages
• Registration and authentication
• Traffic optimization and distribution
• Registration and authentication provided directly by Hotspot Effect

Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

No

Targeted Advertising:

No

Third-parties:

Amazon, Hotspot Effect, Square, Inc., Amazon Web Services, Inc., Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti., Intuit Inc., Automattic Inc., Sucuri, Inc.

Service providers or contractors:

Hotspot Effect

Commercial information

Personal Data processed: First name; Last name; Date of birth; Phone number + 15

Personal Information collected or disclosed:

• first name
• last name
• date of birth
• phone number
• company name
• profession
• physical address
• country
• state
• county
• email address
• ZIP/Postal code
• various types of Data
• city
• User ID
• number of employees
• website
• Usage Data
• Trackers

Purposes:

• Contacting the User
• Managing contacts and sending messages

Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

No

Targeted Advertising:

No

Third-parties:

Intuit Inc.

Employment related information

Personal Data processed: First name; Last name; Date of birth; Phone number + 14

Personal Information collected or disclosed:

• first name
• last name
• date of birth
• phone number
• company name
• profession
• physical address
• country
• state
• county
• email address
• ZIP/Postal code
• various types of Data
• city
• User ID
• number of employees
• website
• Usage Data

Purposes:

• Contacting the User

Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

No

Targeted Advertising:

No

Inferences drawn from other personal information

Personal Data processed: Usage data; Trackers; Answers to questions; Clicks + 5

Personal Information collected or disclosed:

• Usage Data
• Trackers
• answers to questions
• clicks
• keypress events
• motion sensor events
• mouse movements
• scroll position
• touch events

Purposes:

• Spam and bots protection

Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

No

Targeted Advertising:

No

Third-parties:

Google LLC

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Hotspot Effect.

For example, you directly provide your Personal Information when you submit requests via any forms on Hotspot Effect. You also provide Personal Information indirectly when you navigate Hotspot Effect, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Hotspot Effect and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Hotspot Effect.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information for Users in the United States

Profiling of Users in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana

We perform automated processing of your Personal Information to evaluate, analyze, or predict personal aspects related to, for example, your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Such profiling activity is done in furtherance of decisions that may result in the provision or denial of, for example, financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, healthcare services, or access to essential goods or services.

You always have the right to opt out from this kind of profiling activity. To fully exercise this right to opt out you can contact us at any time, using the contact details provided in this document. To find out more about your rights and how to exercise them, you can consult the“Your privacy rights under US state laws” section of this document.

We do not collect Personal Information about Users below the age of 13 in the United States

We do not knowingly collect Personal Information of Users who are below the age of 13 nor do we Sell or process their Information for Targeted Advertising purposes.