Last Update: June 19, 2024

1. INTRO AND PRIVACY PRINCIPLES

PrivacyHawk, Inc. (“PrivacyHawk,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information.

Protecting people's privacy is the reason our company exists, and we start with the way we handle your data ourselves.

This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you through your use of the Services (as defined in our Terms of Use).

For more information on how our product works, including how we securely determine which companies are likely to have your data, how our data broker privacy scan works, and other commonly asked questions, visit our FAQs or email us at support@privacyhawk.com.

We operate and build our own products under the following privacy principles:

• Data minimization: We aim to collect and store the minimum amount of user data that is reasonably necessary and proportionate to offer our Services.

• Transparency: We aim to be clear about what user data we have and how we use it. Privacy by Default and by Design: We aim to build products with privacy as a priority from the start.

• User Control: We aim to allow our users to control what data we have about them, and to make ourselves available and responsive to user requests or concerns.

• We do not sell your information to third parties or share your information for the purposes of cross-context behavioral advertising.

2. COLLECTION OF INFORMATION

We collect the following categories of information when you use our Services (including when you download or launch our mobile application (“app”), use our web services, or when the app is running on your device in the background):

Information you provide directly to us:

• Identification data: We collect your name, email address, and unique identifiers assigned by third party platforms (such as analytics or communication tools).

• Demographic data: We collect your age and city during signup.

• Communication data: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing this information is optional to you.

• Payment information: Billing details and credit card information if provided through our website. Billing handled through app stores such as Apple and Google is not handled or stored by PrivacyHawk.

• Social media data: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Information we collect about you, automatically through your use of our Services, or through scans of data public data that has been exposed by data brokers:

• Through privacy scans of data broker data to identify potentially publicly exposed data:

  • Possible contact information

  • Possible relatives’ names

  • Possible cities associated with you

  • Possible employers

  • Note: This is all publicly available information that we search so that we can help you contact these companies and exercise your data rights.

• Through email scans to identify companies who may have your data:

  • The domains of companies that have emailed you in the past (eg. “company.com”)

  • Note: We do not store your emails, email login credentials, or email contacts (except messages and responses related to sending opt outs using the Service, and this is only to ensure proper processing and compliance by the companies you choose to send opt outs to); Additionally, we only store the domains described above so that we can help you contact these companies and exercise your data rights.

• Automatically, through your use of the app:

  • Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. Such Log Data is also collected when you interact with the App.

  • Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.

  • Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.

  • Usage Data: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

  • Location Data: We may derive a rough estimate of your location from your IP address.

  • Email Open/Click Data: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

• We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

3. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above for the following business purposes to provide and maintain the Services, and other products or services you request:

• To help you identify which companies have your data, and to help you send requests to those companies asking them to delete or stop selling it.

• To verify your identity and contact details;

• To authenticate your access to the Services;

• To personalize the Services for you;

• To process your payments and maintain appropriate billing and accounting information;

• To respond to your inquiries, comments, feedback, or questions;

• To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies;

• To administer a promotion, survey or other PrivacyHawk features;

• To otherwise provide and maintain the Services, including to improve the Services and to analyze and better understand how you interact with our Services;

We also use and otherwise process each of the categories of information identified above for the following business purposes:

• To develop new products and services;

• To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture, and networks; and

• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

4. DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

• Authorized third-party vendors and service providers. We share the information you provide directly to us and the information we collect automatically with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing, analytics, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.

• Business transfers. We may share the information you provide directly to us and the information we collect automatically in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.

• Legal purposes. We may disclose any of the information that we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of PrivacyHawk, our affiliates, users, or the public.

• With your consent. We may share all of the information that we collect for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

To reiterate what we stated above:

We do not sell your information to third parties or share your information for the purposes of cross-context behavioral advertising.

5. COOKIES AND SIMILAR TECHNOLOGIES

When you use our Services, we use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”). Cookies are small files placed on the hard drive of your computer that collect information from your browser or device.

The following types of cookies are used on our Services:

• Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, certain services cannot be provided. These cookies also help keep our Services safe and secure.

• Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you've previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.

• Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly, which device and/or website you come from, and any error messages that appeared during your use of the Services. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.

We use the personal information collected through cookies for the purposes specified above (including in the Section “Use of Information and Purpose of Data Processing”). The next Section (“Your Rights and Choices”) provides information on how to manage cookies.

6. YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.

Requests should be submitted in writing to the email address at the bottom of this policy, or, in some cases, can also be made within the app. Once we receive your request, we will verify it by matching the data you provide with the data in our system. You also may be entitled, in accordance with applicable law, to submit a request through an authorized agent.

Please note that we may ask you to verify your identity before responding to such requests.

With regard to cookies, you may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section).

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you. Any differences in the Services are related to the value provided.

7. INTERNATIONAL TRANSFERS

We may transfer and store your information on servers located outside your resident jurisdiction. To the extent you are a resident of a country other than the United States, UK or EEA, you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA or UK, including in countries that may not provide the same level of data protection or redress means as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality.

8. CHILDREN

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law. The Services are not directed at children.

9. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

We maintain reasonable security measures to safeguard information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

10. CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

11. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please don’t hesitate to contact us at support@privacyhawk.com.