Privacy Policy

WELCOME TO HOTSPOT LOCAL / HOTSPOT MARKETING PRIVACY POLICY

Hi there, we’re HotSpot Local / HotSpot Marketing of Santa Clarita, CA 91321 (“HotSpot”) and welcome to our privacy policy. This policy sets out how we handle your personal information if you’re a HotSpot, user or visitor to our site.

When we say ‘we’, ‘us’ or ‘HotSpot’ it’s because that’s who we are and we own and run the site.

If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re talking about the rules for using each of the site. The rules vary by product and each product makes them separately available and seeks consent to them separately to this policy.

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THE TYPE OF PERSONAL INFORMATION WE COLLECT

We collect certain personal information about visitors and users of our site.

The most common types of information we collect include things like: user-names, member/merchant/nonprofit names, mobile phone numbers, email addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as transnational details, support queries, blog post comments, content you direct us to make available on our site (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).

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HOW WE COLLECT PERSONAL INFORMATION

We collect personal information directly when you provide it to us, automatically as you navigate through the site, or through other people when you use services associated with the site.

We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our site, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.

Although we generally collect personal information directly from you, on occasion, we also collect certain categories of information about people from other sources. In particular:

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PERSONAL INFORMATION WE COLLECT ABOUT YOU FROM OTHERS

financial and/or transaction details from payment providers located in the US, UK, and Australia in order to process a transaction;

third party service providers (like Google, Facebook) who are located in the US or UK, which may provide information about people when people link, connect, or login to people account with the third party provider and they send us information such as people registration and profile from that service, this only occurs if people are using HotSpot,  Studio. The information varies and is controlled by that service provider or as authorized by people via people privacy settings at that service provider; and

other third party sources/ and or partners from Australia, US or UK, whereby we receive additional information about people (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about people. For example, fraud warnings from service providers like identity verification service. We also receive information about people and people activities on and off the HotSpot,  platform through partnerships, or about people experiences and interactions from our partner ad networks. We also receive information about people as a rights holder from our third party authors. For example, information in the form of a model release when people image is used in an item made available on our site.

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HOW WE USE PERSONAL INFORMATION

We will use people personal information:

To fulfill a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the site, like where people purchase a service or an item from our online shop.

Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:

operating the site;

providing people with services described on the site;

verifying people identity when people sign in to any of our site;

responding to support tickets, and helping facilitate the resolution of any disputes;

updating people with operational news and information about our site and services e.g. to notify people about changes to our site, website disruptions or security updates;

carrying out technical analysis to determine how to improve the site and services we provide;

monitoring activity on the site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the site;

managing our relationship with people, e.g. by responding to people comments or queries submitted to us on the site or asking for people feedback or whether people want to participate in a survey;

managing our legal and operational affairs (including, managing risks relating to content and fraud matters);

training HotSpot,  staff about how to best serve our user community;

improving our products and services.

providing general administrative and performance functions and activities; and

processing people job application to HotSpot, .

Where people give us consent:

providing people with marketing information about products and services which we feel may interest people; and

customizing our services and website, like advertising that appear on the Site – where this involves the use of cookies or similar technologies – in order to provide a more personalized experience.

For purposes which are required by law.

For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

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WHEN WE DISCLOSE PEOPLE PERSONAL INFORMATION

We will disclose personal information to the following recipients:

companies that are in the HotSpot, group which are located in the US;

authors of any items or services made available to people, so they can facilitate support and license validation, who maybe located in any of the countries our products are available in;

subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in the US and UK; technical and customer support services which are located in Canada, India and the US;

our professional advisers (lawyers, accountants, financial advisers etc.) which are located in the USA;

regulators and government authorities in connection with our compliance procedures and obligations;

a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;

a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;

a third party, in order to enforce or defend our rights, or to address financial or reputation risks;

a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and

other recipients where we are authorized or required by law to do so.

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WHERE WE TRANSFER AND/OR STORE PEOPLE PERSONAL INFORMATION

We are based in the USA so people data will be processed in the US. Some of the recipients we have described in section 10 above, and to whom we disclose people personal information, are based outside the USA in places like Canada, India, and the US. We do this on the basis of people consent to this policy.In order to protect people information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

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HOW WE KEEP PEOPLE PERSONAL INFORMATION SECURE

We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in the US. Personal information that we store or transmit is protected by security and access controls, including username and password authentication and data encryption where appropriate.

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HOW PEOPLE CAN ACCESS PEOPLE PERSONAL INFORMATION

People can access some of the personal information that we collect about people by logging in to people account. People also have the right to make a request to access other personal information we hold about people and to request corrections of any errors in that data. People can also close the account people have with us for any of our site at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.

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MARKETING CHOICES REGARDING PEOPLE PERSONAL INFORMATION

Where we have people consent to do so (e.g. if people have subscribed to one of our e-mail lists or have indicated that people are interested in receiving offers or information from us), we send people marketing communications by email about products and services that we feel may be of interest to people. People can ‘opt-out’ of such communications if people would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

People also have choices about cookies, as described below. By modifying people browser preferences, people have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If people choose to reject cookies some parts of our site may not work properly in people case.

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COOKIES (NOT THE TYPE PEOPLE EAT!) AND WEB ANALYTICS

For more general information on cookies, see http://www.allaboutcookies.org.

When people visit our site, there’s certain information that may be recorded which is generally anonymous information and does not reveal people identity. If people’re logged into people account some of this information could be associated with people account. We’re talking about the following kinds of details:

people IP address or proxy server IP address’;

the domain name people requested;

the name of people internet service provider is sometimes captured depending on the configuration of people ISP connection;

the date and time of people visit to the website;

the length of people session;

the pages which people have accessed;

the number of times people access our site within any month;

the file URL people look at and information relating to it;

the website which referred people to our site; and

the operating system which people computer uses.

Occasionally, we will use third party advertising companies to serve ads based on prior visits to our site. For example, if people visit our site, people may later see an add for our products and services when people visit a different Site.

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INFORMATION ABOUT CHILDREN

Our site are not suitable for children under the age of 16 years, so if people are under 16 we ask that people do not use our site or give us people personal information (if people are a peopleng tech wiz, please direct people nearest responsible adult to use the site for people!). If people are from 16 to 18 years, people can browse the site but people’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our site.

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INFORMATION PEOPLE MAKE PUBLIC OR GIVE TO OTHERS

If people make people personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that people can find peopleself providing information to other people, like when people post a public message on a forum thread, share information via social media, or make contact with another user (such as a third party Author) whether via our site or directly via email. Before making people information publicly available or giving people information to anyone else, think carefully. If giving information to another user via our site, ask them how they will handle people information. If people’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

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HOW LONG WE KEEP PEOPLE PERSONAL INFORMATION

We retain people personal information for as long as is necessary to provide the services to people and others, and to comply with our legal obligations. If people no longer want us to use people personal information or to provide people with the HotSpot, services, people can request that we erase people personal information and close people HotSpot,  account. Please note that if people request the erasure of people personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

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WHEN WE NEED TO UPDATE THIS POLICY

We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the policy, we’ll make sure to notify people about such changes, where required. A copy of the latest version of this policy will always be available on this page.

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HOW PEOPLE CAN CONTACT US

If people have any questions about our privacy practices or the way in which we have been managing people personal information, please email us at [email protected].

We’re really glad people made it to the end of the privacy policy, because knowing this stuff is the best way to understand how people personal information is used and how to best manage it!

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IF PEOPLE’RE A USER OR VISITOR IN THE EUROPEAN ECONOMIC AREA THESE RIGHTS ALSO APPLY TO PEOPLE:

For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of people personal information.

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HOW PEOPLE CAN ACCESS PEOPLE PERSONAL INFORMATION

People are also entitled to ask us to port people personal information, to erase it, or restrict its processing. People also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for people consent to process people data, to withdraw this consent as more fully described below.

These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process people personal information. In some instances, this means that we may retain some data even if people withdraw people consent.

Where we require people personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with people, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.

If people have unresolved concerns people also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of people habitual residence; (ii) of people place of work; or (iii) in which people consider the alleged infringement has occurred.

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BOTH PERSONAL INFORMATION AND PERSONAL DATA HAVE THE SAME MEANING IN THE CONTEXT OF THIS PRIVACY POLICY.

HotSpot, Privacy Policy, Most Recent Rev. January 2, 2019