“Site(s)” means any software application on a compatible device or URL that is owned and operated by Havn, which provides goods and services offered by Havn including together with our partner websites and mobile applications, and any other media form and media channel acting in conjunction or collaboration with Havn .
Havn considers your privacy to be important. We are committed to protecting the privacy of the information you provide to us, including your personal data. This policy describes the types of personal data we collect, how we use that data, with whom we share it, the choices you can make about our use of such data, your privacy rights and how the law protects you. We also describe the measures we take to protect the security of your personal data and how you can contact us about our privacy practices.
Information We Collect
We may have a direct relationship with you, and you may choose to provide personal data to us in connection with that relationship, or we may collect it via other means. The data we collect about you may include:
- Contact Information
- Login Details (Username and Password)
- E-Mail Address
- Telephone Number
- IP Address
- Financial Information
- Content You Provide To Us
- Technical Information About Your Device and Site Usage (Including IP Address)
- Mobile Application information
- Location Data
- Transaction History
- Information About Your Browsing Characteristics and Preferences
- Facebook Permissions
- Data From Social Networks
If you are a customer or a partner of ours, or otherwise interact with us (e.g. through our info site) then we will collect certain basic contact information about you. This may include your name, postal address, email address, telephone number and demographic information such as your age, gender, hometown and interests that you provide to us when you register with our Sites or when you choose to participate in various activities related to our Sites, such as online chats and message boards.
In the event that you are a representative or employee of one of our Partners, then we may also collect the name of your employer / the company that you represent, your role within the company and your job title.
If you have an account with us, then we will store your username and password in order to manage your access to our platforms. Other than information held by us. you are responsible for the security of these login details.
Content That You Provide To Us
Personal and other information you may provide when you may get in touch with us via our Sites or by telephone, we may email you in response, or vice versa. You may also send us feedback via a survey form or entering contests and/or giveaways.
Technical Information About Your Device and Site Usage
Through cookies, web beacons and similar technologies, we may collect details about your device, such as your IP address, your internet browser type, your mobile device ID, model, manufacturer, operating system, version information, IP address and information regarding the location of your device (if you access our Sites through a mobile device).
We may also collect information about your browsing activity, such as how you use our Sites, your access times, the pages you have visited directly before and after accessing our Sites, your device name and type, your phone number, your country, your likes and replies to a post and other interactions with our Sites and other uses via server log files, as well as any other information you choose to provide.
Mobile Application Information
When you connect using our mobile application we may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services.
Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile phone devices bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage and other features.
We may request to send you push notifications regarding your account or the application.
If you wish to change our access or permissions at any time, you may do so in your device’s settings.
If you provide us with your card details, then we will collect records of your transactions on that card, including the location, date and time of the transaction.
With your consent, we will access location-based information or collect location markers from your mobile device or based on your IP address. We will use this information to provide you with notifications related to locations of users and partners (as applicable). We do not use this information to specifically locate you for any reason other than to provide you with the service. If you have allowed us to utilise your location information in the past and wish to revoke the permissions, please change the settings on your device. We shall also remind you of this ability to amend your settings during any software update of the Application.
Information About Your Characteristics and Preferences
We may collect certain details about you and your preferences as a prospective customer and/or partner. This may include your purchasing behaviour and preferences.
The Sites may, by default, access your Facebook basic account information, including your name, email address, gender, birthday, current city and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account such as friends, check-ins and likes. You may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference Page.
Data From Social Networks
User information may be collected from social networking sites, such as Apple’s Game Center, Facebook, Instagram, Pinterest and Twitter; including your name, your social network usernames, location, gender, birth date, email address, profile picture and public data for contacts (if you connect your account to such social networks). When you are using our Sites, this information may also include the contact information of anyone you incite to use and/or join our Sites.
How We Collect Your Information
We use different methods to collect data from and about you, depending upon the nature of our relationship. This may include through direct interactions we have with you, through the use of automated technologies (e.g. cookies) and from third parties or publicly available sources.
You may provide us with your data by completing forms (e.g. through our Sites) or by corresponding with us by post, phone email or otherwise. This includes data you provide when you:
- Purchase a product or service on our Sites
- Create an account on our Sites
- Sign up to receive information (e.g. subscribe to our email marketing list)
- Participate in promotions or surveys
- Provide us with feedback
- Otherwise communicate with us
Third Party or Publicly Available Sources
How We Use Your Data
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose / Activity
|Type Of Data
|Lawful Basis For Processing – Including Basis Of Legitimate Interest
|To register you as a new customer, including:
|Performance of a contract with you.
|Fulfil and manage purchases, including processing card transactions, orders, payments and other transactions related to our Sites.
|Performance of a contract with you and necessary for our legitimate interests to recover debts due to us.
|Administer your account, including:
|Performance of a contract with you and necessary for our legitimate interests to keep our records updated and develop our services.
|Generate a personal profile about you to make future visits to the Sites more personalised.
|Necessary for our legitimate interests to develop our services and grow our business.
|Assist law enforcement agencies and protect ourselves against fraud and money laundering, verify your identity and to detect, investigate and prevent crime.
|Necessary to comply with a legal obligation and necessary for our legitimate interests to protect our business from unlawful activity.
|Provide you with information about our products and/or services, and deliver targeted advertising, coupons, newsletters and other information regarding promotions and new products, services, experiences and/or recommendations on our Sites to you.
|We will provide you this information where you have consented to receive such information.
|Administer sweepstakes, promotions and contests.
|Performance of a contract with you and necessary for our legitimate interests to study how customers use our services, to develop them and grow our business.
|Allow you to participate in interactive features e.g. via the Sites through our live chat function.
|Performance of a contract with you and necessary for our legitimate interests to keep our website updated and relevant, to develop our business and to improve our service provisions and customer service.
|Enable user-to-user communications.
|Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
|Monitoring and analysing usage and trends to improve your experience with our Sites.
|Necessary for our legitimate interests to operate, evaluate and improve our business, including to increase efficiency and the operation of our Sites.
|Compile anonymous statistical data and analysis for use internally or with third parties.
|Necessary for our legitimate interests to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
|Performance of a contract with you and necessary to comply with a legal obligation.
|Share information with third parties.
|Necessary for our legitimate interests (See sections entitled ‘Data We Share and Receive for more information).
We may process data in other ways (not listed above) regarding which we will notify you (and obtain consent where necessary) at the time of its collection or use. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you have opted in to receiving marketing communications, you can ask us or third parties to stop sending you marketing communication at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time at firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Data We Share and Receive
To find out more please see below.
By Law or To Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities (including regulators and other government agencies including, but not limited to, public authorities, regulators, the police and other law enforcement agencies) for fraud protection and credit risk reduction.
We may share your information with our business partners (including partners who provide features on our Sites) to offer you certain products, services or promotions, and any company to whom we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, along with its professional advisers.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, our insurers and professional advisers, IT suppliers, and marketing assistance. With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing and data analytics purposes, as permitted by law.
Interactions With Other Users
If you interact with other users of our Sites, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.
When you post comments, contributions or other content to our Sites, your posts may be viewed by all users and may be publicly distributed outside the Sites in perpetuity.
We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Sites and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
Social Media Contacts
If you connect to our Sites through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, only as permitted by law.
Sale or Bankruptcy
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
We do not authorise any third parties that we share data with to use or disclose your data except as necessary to perform certain services on our behalf, to comply with legal requirements or as detailed under the “Credit Reference Agencies” section of this policy. We require these third parties, through our contractual arrangements with them, to appropriately safeguard the privacy and security of the data they process on our behalf.
We may also receive data about you from the following third parties:
- Social Media Platforms
- Credit Reference Agencies
- Data Brokers
- Our Commercial Partners
- Public Databases
- Regulators and Other Government Agencies
If you would like to receive a full list of our suppliers and other third parties who we share your data with or receive your data from then you can get in touch with us at email@example.com.
Where Your Data May Be Sent
We may be required to transfer data internationally. Accordingly, your personal data may be transferred globally (if your data is collected within the European Union, this means that your data may be transferred outside of it). This includes transfers that have been identified in the previous section Data we share and receive.
How We Keep Your Information Secure
We use administrative, technical, and physical security measures to help protect your personal data and to protect it from loss, misuse or alteration. Personal data that we hold about you is stored on our secure servers or those of our appointed suppliers. Our web pages that collect your data are secured with Secured Socket Layers (SSLs).
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.
Havn maintains an information security program that is designed to:
- Secure and maintain confidentiality of your data.
- Protect against anticipated threats or hazards to security or integrity of your data.
- Protect against unauthorised access to our use of your data that coil result in substantial harm or inconvenience to you or your entity if compromised.
- Comply with applicable laws.
While we have taken reasonable steps to secure the personal data you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorised parties. Therefore, we cannot guarantee complete security if you provide us with personal data.
How Long We May Keep Your Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data can be requested by emailing firstname.lastname@example.org.
In some circumstances you can ask us to delete your data, please see Your rights and choices.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with or be used to identify you) for research or statistical purposes in which case we may use such data indefinitely without further notice to you.
Havn’s Sites are not intended for use by children, especially those under the age of 18. No one under the age of 18 should provide any personal data or participate in any forums, chats, or online discussions. Minors under the age of 18 are prohibited from applying for emails, newsletters and/or products or services, on our Sites. If we identify that we have received any such personal data we will delete it.
Third Party Websites
Your Rights and Choices
You may have some or all of the following rights in respect of personal data about you that we hold:
- Request us to give you access to it
- Request us to rectify it, update it or erase it
- Request us to restrict use of it, in certain circumstances
- Object to our use, in certain circumstances
- Where legally possible, withdraw your consent to our use
- Data portability, in certain circumstances
- Opt out from or object to our use for direct marketing
- Lodge a complaint with the supervisory authority in your country (if applicable)
You are able to exercise these rights by contacting us using the details set out in the ‘How To Reach Us Section’ below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
|Right In Respect Of The Data About You That We Hold
|Further Details (Note: Certain Legal Limits To All These Rights Apply)
|To request us to give you access to it
|This is confirmation of:
On your request we will provide you with a copy of the data we hold.
|To request us to rectify or update it
|This applies if the data we hold is inaccurate or incomplete.
|To request us to erase it
|This applies if:
|To request us to restrict our processing of it
|This right applies temporarily while we look into your case, if you:
(If you make use of your right in these cases, we will tell you before we use the data again).
This right applies also, if:
|To object to our processing of it
You have two rights here:
|To withdraw your consent to our use of it
|This right applies to any data which we have collected and process based on your consent.You have the right at any time to withdraw the consent you have provided to us.
|To data portability
|This right applies: (i) to personal data that you have provided to us; and (ii) if we use that data on the basis either of your consent, or on the basis of discharging our contractual obligations to you.If both (i) and (ii) apply, you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible.
|To lodge a complaint with the supervisory authority in your country
|Each European Union country must provide for one or more public authorities for this purpose.You can find their contact details here: ARTICLE29 Newsroom – National Data Protection Authorities.
How To Reach Us
If your country of residence has a data protection authority, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.