Privacy Policy

Last updated: 14 November 2018

This policy describes the information TEIT (“we”) processes to support our product “Hanna” in European Union member states and the three EEA/EFTA states: Iceland, Liechtenstein and Norway (“EU”).

1. What kinds of information do we collect?

The types of information we collect depend on how you use our product and related media and pages. You can learn how to access and delete information we collect by visiting the settings via our product.

1.1 Things you and others do and provide

1.1.1 Information and content you provide

We collect the content, communications and other information you provide when you use our product, including when you create content, message or communicate using or via the Hanna chatbot. This can include information in or about the content you provide (such as metadata). Our systems automatically process content and communications you provide to analyze context and what is in them for the purposes described. below.

1.1.2 Networks and Connections

We collect information about the people, pages, conversations and community you are connected to and how you interact with them across our product, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device, which we use for things such as helping you find your favorite stores, destinations and shops you may know and for the other purposes listed below.

1.1.3 Usage

We collect information about how you use our product, such as the types of content you view or engage with, the features you use, the actions you take, the people or accounts you interact with, the locations you send, and the time, frequency and duration of your activities. For example, we log when you are using and have last used our product, and what posts and other content you viewed on our product. We process the results of analyzing this information (including the results of profiling).

1.2 Device Information

As described below, we collect information from and about the computers, phones and other web-connected devices you use that integrate with our product, and we combine this information from the different devices you use. Information we obtain from these devices includes:

1.2.1 Device Attributes

Information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

1.2.2 Device Operations

Information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

1.2.3 Identifiers

Unique identifiers, device IDs, and other identifiers, such as from apps.

1.2.4 Device Signals

Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.

1.2.5 Data from Device Settings

Information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.

1.2.6 Network and Connections

Information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, and connection speed.

1.2.7 Cookie Data

Data from cookies stored on your device, including cookie IDs, and settings. Learn more about how we use cookies in the Cookie Policy.

1.3 Personal information obtained from third-party sources

We collect and process information about you obtained through third-party sources such as Google analytics. This information includes your profiling data.

2. How do we use this information?

We use the information we collect (subject to choices you make) for the following purposes, in accordance with the relevant laws on data processing.

2.1 Provide, personalize and improve our product

We use the information we collect to deliver our product, including to personalize features and content (including your conversation histories), and to make suggestions for you (such as shops) on and off our product. To create personalized product that are unique and relevant to you, we use your connections, preferences, interests, location and activities based on the data we collect; how you use and interact with our product; and the people, places, or things you’re connected to and interested in on and off our product.

The usage of profiling and automatic decisions to create recommendations is a necessary obligation under our terms of service. Any separate processing is based on your consent.

2.1.1 Location-related Information

We use location-related information such as your current location, where you live, the places you commonly visit, the destinations you travel to, and locations you rate highly, to personalize and improve our product, including advertisements, for you and others. Location related information can be based on data such as precise device location (if you’ve allowed us to collect it), IP addresses, and latitude/longitude information you send.

The usage of profiling and automatic decisions to create recommendations is a necessary obligation under our terms of service. Any separate processing is based on your consent.

2.1.2 Product Research and Development

We use the information we collect to develop, test and improve our product, via tools such as surveys and research, and testing and troubleshooting new product and features.

The processes of troubleshooting and improvement of our product are necessary obligations under our terms of service. Any separate processing, including profiling, is based on your consent.

2.1.3 Advertisements, Construction of Audience Data, and other sponsored content

We use the information we collect about you, including information about your interests, actions and connections to select and personalize advertisements, offers and other sponsored content that we show you (such as that referred to in section 1.1.3). We construct audience data for ads based on this information. This data is used on DSP for ad optimization and on DMP for CRM. This data processing includes profiling and is based on your consent.

2.2 Provide measurement, analytics, and other business services

We use the information we collect (including your activity off our product, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services. This data processing includes profiling and is based on your consent.

2.3 Promote safety, integrity and security

We use the information we collect to verify accounts and activity, combat harmful content, detect and prevent spam and other bad experiences, maintain the integrity of our product, and promote safety and security. We need to process your information for the purpose of pursuing our and the user’s legitimate interests.

2.4 Communicate with You

We use the information we collect to send you marketing communications, communicate with you about our product, and let you know about our policies and terms. We also use your information to respond to you when you contact us. Your information is processed, except in the case where it involves profiling, to pursue your legitimate interests.

2.5 Research and innovate for social good

We use the information we collect to conduct and support research and innovation on topics of technology advancement, public interest, health and well-being. We make aggregated statistics and insights based on the information you release. This processing includes profiling and is based on your consent.

3. How is this information shared?

Your information is shared with others in the following ways.

3.1 Sharing with Third Party Partners

We work with third party partners who help us provide and improve our product. Data processing for the following purposes are based on your consent.

3.1.1 Partners who use our analytics services

We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, pages, videos and other content on and off the product.

3.1.2 Advertisers

We provide information to advertisers via DSP, DMP and enterprises connected with internet advertising with reports about the kinds of people seeing their ads and how their ads are performing, but we don’t share information that personally identifies you (information such as your name or email address that by itself can be used to directly contact you or identifies who you are) unless you give us permission.

3.1.3 Measurement Partners

We share information about you with companies that aggregate data and provide analytics and measurement reports to our partners.

3.1.4 Partners offering goods and services via our product

When you subscribe to receive premium content, or buy something from a seller in our product, the seller can receive your public information and other information that you share with them, as well as the information needed to complete the transaction, including shipping and contact details. You can check who the seller is every time you subscribe or make a transaction.

3.1.5 Vendors and Service Providers

We provide information and content to vendors and service providers, such as Google Analytics, who support our business, such as by providing technical infrastructure services, analyzing how our product are used, providing customer service, facilitating payments or conducting surveys.

3.2 Law enforcement or Legal Requests

If we receive a subpoena, court order, warrant or other legal demand from a third party (including law enforcement or other public or judicial authorities) seeking the disclosure of your information, we may disclose such information only to the minimum extent necessary to satisfy such a demand. We comply with applicable laws of the States while processing your information.

4. Transfer to recipients in third countries

In the following cases, and in these cases only, we may transfer your information to countries outside of the EU which are not recognized by the European Commission as providing an adequate level of data protection. In these cases, we don’t implement appropriate safeguards pursuant to Article 46 in GDPR.

4.1 Service Providers

We use services provided by the third party which is Google Cloud Platform (“GCP”). In order to provide our product, we need to transfer your information to countries outside of the EU. The transfer is necessary to fulfil obligations under the contract of this service.

4.2 For the purpose of sharing detailed in Section 3

4.2.1 Google Analytics

We use services provided by third parties such as Google Analytics. In order to use these services, we need to transfer your information to countries outside of the EU. The transfer is based on your explicit consent.

4.2.2 Other Recipients

In order to meet our obligations in section 3, we need to transfer your information to countries outside of the EU. The transfer is based on your explicit consent.

5. Retention Period

The retention period of your information provided through our product is 90 days from last access.

6. Your Rights

You have the right to request access to your personal data as well as the right to rectify and where applicable, erase any inaccurate, incomplete or immaterial personal data; to request restriction of processing, and to request data portability for the data held by us.

7. Your rights to object to processing

You have the right to object at any time to the processing of your information, including profiling. To exercise this right, please change the appropriate settings in our product.

8. Withdrawing Consent

Wherever we rely on your consent, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing performed pursuant to consent given prior to the withdrawal. To exercise this right, please change the appropriate settings on our product.

9. Your right to complain to a supervisory authority

If you consider that the processing of your personal data is carried out in an unlawful manner, you may lodge a complaint with the Information and Data Protection Commissioner.

10. Mandatory Information

Our service needs to process your location data. Where provision of this information is mandatory, we are not able to provide our product to you if the information is not provided.

11. How will we notify you of changes to this policy?

We’ll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our product.