Privacy Policy

Effective Date: January 2, 2021

This Privacy Policy  (“Policy”) describes how M&Y Apps LLC and its subsidiaries (collectively, “Hooot,” “we,” “our” or “us”) collect, use, process and share personal information. This Policy applies to visitors and users (individually, “you”) of Hooot’s websites, mobile or tablet applications, social media accounts, and other services (collectively, our “Services”). Please note that your use of our Services is additionally subject to the Hooot Terms & Conditions.

As a leading provider of personal security solutions, Hooot uses your personal information to provide these Services. This use involves sharing personal information with your designated contacts and other third parties, including, security system providers, and others (collectively, “security partners”).

For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by third parties or their services, and we do not take responsibility for their privacy practices.

You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to the Your Choices and Rights section of this Policy.

OVERVIEW

INFORMATION WE COLLECT AND USE

“Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For purposes of this Policy, there is no meaningful distinction between the terms “personal information” and “personal data.”

Personal Information We Collect Directly From You

As you visit, access or use our Services, we collect the following categories of personal information directly from you:

• Personal details (such as your name, age, birthday, gender)
• Contact information of you (such as email address, address, phone number)
• Account information (such as login credentials, password, and account settings)
• Social media data (if you choose to link your Hooot account with a social media account, Hooot may collect personal information such as name, age, gender, photograph, and other personal information relating to your social media account)
• Your contacts (such as contact information of people you add to, or notify of, your use of our Services)
• Your preferences (such as your best phone number to reach you, your primary contact person, and other preference information you provide us)
• Reviews you submit (including any screen name you publish under or any personal information you include about yourself or others in such review)
• Content you publish (including your security recommendations and any personal information you include about yourself or others, or in content you publish in mediums provided by us)
• Photos of you (such as when you add a photo of yourself to your profile, upload photos to a review, or link your social media account to your Hooot account)
• Communications you send us (such as questions, conversations, complaints, or other information that you may submit to our support team)
• Promotion information (if you choose to participate in a contest, sweepstakes, or similar campaign, we will collect any information you provide in relation to such activity, such as photos, images, captions, or other content, in accordance with the terms provided at that time)
• Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms)

You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.

We do not proactively collect sensitive personal information, such as health-related information. However, our Services include text boxes that are designed for you to describe certain details about your status or special requests that you want us or our security partners to know. Please be aware that information you freely submit in these boxes may reveal to us or to the security partners or third parties with whom we share information (as detailed in the How We Share Your Information section below) certain information that may be considered sensitive personal information under applicable law (for example, information about your physical or mental health). Sensitive personal information you voluntarily submit is processed on the basis of your consent, which you may revoke at any time by contacting us at the details set out in the How to Contact Us section below.

Personal Information Generated By Us. 

As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies (see our Cookies and Interest-Based Advertising Policy for more details). We generate the following categories of personal information about you:

• Device information. When you visit or use our Services, we automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; such as IP address or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
• Usage and performance information. We also automatically collect personal information about your usage of the Services, including information about your number of uses, statistics about the uses you initiate with us, how you interact with the features of our Services and the links you click, your preferences, access times, referring URL, and performance of our Services.
• Location information. If you use our Services, we automatically collect approximate location information about you (such as your city) or, with your consent, precise geographic location data from your mobile device when the app is running and when it is not running, depending on the choices you make when you are asked to consent to our collection of location information. The technologies we use to determine your location may include IP address mapping, cell tower position, Wi-Fi position and GPS signals. We may use and store this information to provide and improve features of our Services, for example, to tailor our Services on a needs-based manner to better facilitate your requests (such as helping you find the safest place closest to you) and to provide you with more relevant content in the places you visit (such as sending you marketing communications relating to goods or services in your current city, including local safe locations or police departments). Hooot does not have control over your device settings, but in order for many of our Services to work as intended, enabling location services on your device is necessary so you can take advantage of the location-based features and functionality offered. Please see the Your Rights and Choices section below for more information about how to adjust your preferences, including those related to location information.
• Inferences about you. We combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the advertising we and our partners display or offer to you.

Personal Information We Obtain from Third Parties. 

We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (each, a “third-party platform”), security partners, and other third parties, including individuals who have agreed to act as your designated emergency contact(s). If you are an existing Hooot user, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties includes:

• Your name
• Email address or other contact information
• Social media data, if you connect to our Services using a social media third-party platform or interact with Hooot by liking or commenting on our social media pages or content, we may receive information from that social media third-party platform about those interactions and from your social media profile (e.g., name, age, gender, photograph, and other personal information related to that account)
• How you use third-party websites, applications, and services; information relating to your interactions with our advertising and marketing materials; and demographic information about users of our Services.

HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes (“Purposes”), to:

• Provide the Services, which includes providing you with the services, products, and functionality offered through our Services and fulfilling your requests, including, but not limited to: tracking your location when you activate a use, alerting your contacts and our security partners, and notifying people you add to, or otherwise request to notify of, your location or status through the Services
• Authenticate your account credentials and identify you, as necessary to log you in to the Services and ensure the security of your account
• Communicate with you about your account or use of our Services, products, and/or functionality (e.g., soliciting reviews and feedback, sending alerts and notifications you have subscribed to, sending you information servicing and administrative emails or other notices required by law); respond to, or follow up on, your comments and questions; and otherwise provide customer service (see below for more detail on Electronic Communications)
• Send you marketing communications, including communicating with you about services or products offered by Hooot, or our security partners or business partners and other marketing communications that we believe you would be interested in, as permitted by law
• Operate and improve our Services and develop new products and services, including using analytics to better understand how you use our Services for purposes of product, website, application and service development and to enhance the user experience
• Process and deliver contest entries and rewards
• Process your payment information
• Provide services and information to security partners, such as providing user feedback and usage details
• Tailor your experience with our Services, such as by making inferences or combining different pieces of information we have collected about you to offer better user experience or otherwise tailor our Services to you according to your preferences or restrictions.
• Provide you more relevant advertising on and off our Services, including to show you personalized offers and advertising on and off our Services.
• Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity
• Comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law
• As otherwise consented to by you and as required or permitted by applicable law. If you give your consent to any further use of personal information, you can withdraw that consent at any time by contacting us using the details set out below.

You have choices about your personal information, and in some circumstances, you may have the right to opt out or object to our uses of your personal information for these purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.

Electronic Communications. 

Consistent with the above purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:

• Send you information relating to our products and Services. This may include user alerts, receipts, technical notices, updates, security alerts, and support and administrative messages.
• Send you marketing communications. In other situations, subject to the Your Choices and Rights section below and applicable law, we may communicate with you about contests, offers, promotions, rewards, upcoming events, and other news about products and Services offered by us, security partners, and other business partners.

With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages in connection with the above purposes.

Our Role as Data Controller. For purposes of European Union law and similar data protection regimes, we generally act as a data controller, meaning we determine the purposes and means of processing your personal information. Our security partners to whom we may connect you to make reservations are also data controllers. To learn more about how a security partner may use your personal information, you should review its privacy notice.

Processing Bases and Consequences. When we process your personal information, we rely on the following legal bases:

• Performance of the contract we have with you (for example, if you use our Services to send an alert, we will process your information in order to allow your designated contact to find your location).
• Compliance with legal obligations to which we are subject (such as when we are obliged to comply with lawful requests from competent authorities such as law enforcement).
• To serve our legitimate interests (such as tailoring your experience with our Services, carrying out online advertising, and for fraud detection), provided that such processing does not outweigh your rights and freedoms. The processing must also be pursuant to other applicable legal bases for data processing, especially provisions set out under local law.

When we use personal information to meet our legitimate interests, we take steps to ensure that your rights to your personal information are not infringed. You can contact us using the details set out in the How to Contact Us section below for more information about the steps we take to ensure these rights are not infringed. You also have the right to object to such processing as described in the Your Choices and Rights section below.

• Consent. To the extent that a legal ground described above would not apply to processing of your personal information by us, we will seek your consent for such specific purpose in accordance with applicable law (such as sending direct marketing messages by electronic means, like email, without an exception from the requirement to obtain consent).

Aggregate Information. We aggregate personal information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with personal information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “personal information” and may be subsequently used for any purpose.

Anonymized Information. We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “personal information” and may be subsequently used for any purpose.

HOW WE SHARE YOUR INFORMATION

We disclose the personal information we collect (or otherwise generate or obtain) as follows:

• With our security partners. We share your information with our security partners to provide the Services (such as alerting a security system service) and for our security partners' own purposes, which may include marketing or advertising purposes (see below for more detail on Sharing with Security Partners).
• With other business partners. We share information with other third-party business partners to provide the Services (such as for processing payment) and for their own marketing purposes, including sharing with online advertisers or advertising technology (“ad tech”) companies to provide you with targeted advertising and marketing communications, where permitted under law (see below for more detail on Sharing with Our Business Partners).
• With social networking services. We share (or facilitate your sharing of) your information with social networking services when you use our Services to connect and share your information publicly or with friends or when you use our Services to connect with us on, share on, or use third-party social networking platforms and services (see below for more detail on Sharing with Social Networking Services).
• Third-party services or applications you use to log into your account. If you use a third-party service or application (e.g., Facebook) to log into your Hooot account, we share certain personal information with that third party.
• Reviews you submit. If you provide us with a review of our Services, you authorize us to publish it on all our Services under the screen name you provided and to share it with security partners. You also authorize us to aggregate your review with other reviews.
• Content you publish. If you publish content on mediums provided by us, you authorize us to publish it on all our Services.
• With other service providers. We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (see below for more detail on Sharing with Other Service Providers).
• In the event of a corporate transaction. We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
• To protect rights and property. We may disclose your information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, the integrity of the Services, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.
• To comply with and as required by law. We may disclose your personal information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities.
• Aggregate information. We share aggregate statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.
• At your request. We also share your information as directed or requested by you, or subject to your consent.

In some circumstances, you may have the right to opt out or object to our sharing of your information with certain third parties. For more information, or to exercise these or other rights, see the Your Choices and Rights section below.

Sharing with Security Partners. When you initiate an alert through our Services, we may share your information with that Security Partner to facilitate locating you and providing the services you requested. Depending on the request, this may include your name, contact information, location, any special requests, information or comments that you choose to submit (if any), and other information you provide. Your information is provided to the Security Partner, just as it would be if you contacted the Security Partner directly. If you provide a mobile phone number in connection with your request, Security Partners may send you text messages regarding your request.

When you initiate an alert, we also share your location, name and other information to your designated contacts.  This is necessary for the proper function of the Services.

Sharing with Our Business Partners. We share your information with other third-party business partners to provide services on our behalf as a part of the Services or for their own marketing purposes. These third parties include payment processors, online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our Services and information we collect about you through the use of cookies and similar technologies .

For example, we may need a way to bill you for the Services. If you create an account via our website, we share your information with Stripe.  If you create an account via our application, we share your information with Apple’s AppStore.

We may share additional information with Stripe, Apple or other online advertisers or ad tech companies so they can better understand which of our customers are interested in seeing certain content. Stripe or the other Business Partner may then, for example, use this information to offer you a promotion.

To learn more about your choices related to how we share your information with our business partners, please see the Your Choices and Rights section below.

Sharing with Social Networking Services. Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. Our Services may also allow you to connect with us on, share on, and use third-party platforms, including those on which Hooot has a presence. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. Hooot also does not control the privacy practices of third-party platforms. Please contact those sites and services directly to learn about their privacy practices.

Sharing to Process Payment Information. To use certain Services (such as the paid subscriptions) we utilize third party Business Partners. When you submit your payment information through our Services, we will share that information with the Business Partner, third-party payment processors, and other third-party service providers (including, but not limited to, vendors who provide fraud detection services to us and other third parties), to the extent necessary to meet our contractual obligations to you (e.g., to secure your transaction where required), to meet our legitimate interests in preventing fraud and other misuses of our platforms or Services, or with your consent where this is required by law. Please be aware that Hooot does not process your credit card directly or handle your credit card information. For information about the security of your payment information, see the privacy terms of AppStore, Google Play Store or Stripe, as applicable.

Sharing with Other Service Providers. We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (e.g., hosting or operating our Services, data collection, reporting, ad response measurement, site analytics, data analysis, delivering marketing messages and advertisements, and providing fraud detection services). We do not authorize these third parties to use or disclose your information for purposes other than those for which it has been provided. We require these third parties to maintain and implement security measures to protect your information from unauthorized access or processing.

HOW WE STORE AND PROTECT YOUR INFORMATION

Hooot maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

When your payment is being transmitted to our Services, your information will be protected by cryptographic protocols. To be clear, Hooot does not store your payment information. Our contracts with Business Partners that receive your payment information require them to keep it secure and confidential.

However, we cannot guarantee that transmissions of your payment information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Hooot or our Security Partners, Business Partners or other third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your information secure. You should not share your user name, password, or other security information for your Hooot account with anyone. If we receive instructions using your user name and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the How to Contact Us section below.

Retention. We may retain your personal information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your personal information as necessary to:

• Maintain logs and business records for analysis, security, and/or audit purposes
• Comply with record retention requirements under the law
• Deal with any complaints regarding the Services; and
• Comply with our legal obligations, protect or defend our rights, resolve disputes and enforce our contracts

COOKIES

When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. See our Cookies Policy for more details.

YOUR CHOICES AND RIGHTS

Email. If you no longer want to receive marketing and promotional emails from Hooot, you may click on the “unsubscribe” link in such emails to opt out of future marketing email communications. If you have a Hooot account, you may also opt out of marketing emails in your account settings. Please note that even if you opt out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as the number of uses you initiated or when you add or remove a designated emergency contact.

Push Notifications (on Mobile Devices). You can use the settings on your mobile device to enable or turn off mobile push notifications from Hooot.

Text Messages. If you no longer want to receive text messages from Hooot, reply STOP (or as otherwise instructed) to the text message. If you have a Hooot account, you may also adjust your account settings to opt out of text messages.

Cookies and Interest-Based Advertising. To exercise choices regarding cookies set through our websites or Services, as well as other types of online tracking and online advertising, see our Cookies and Interest-Based Advertising Policy for more details. We currently do not employ technology that recognizes “do-not-track” signals from your browser.

Application Location. As explained in more detail in the Information We Collect and Use section above, we collect information about your location if you enable location services through the settings in your mobile device, or with your consent, as may be required by law. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our Services. However, if you choose to turn off location services, this will affect certain features of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

Sharing with third parties. As described above in the How We Share Your Information section, we share your information with third parties for their own purposes or work with those partners to support their own marketing purposes. You can opt out of sharing your information with Security and Business Partners, for their own marketing purposes (including sending marketing communications and providing targeted advertising, promotions, and other offers). You can opt out of such sharing by changing your Hooot account preferences. You may also send such opt-out requests to us as described in the How to Contact Us section below.

Access and Correction of Your Information. If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and update your information. You may also contact us as described in the How to Contact Us section below.

Legal Rights. Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest. Where we are using your personal information on the basis of your consent, and where applicable under local law, you have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time.

If you wish to exercise the legal rights you may have under applicable law, please submit your request by emailing security@gethooot.com. So that we can better process your request, please provide the email you use to log into your Hooot account. If you do not have a Hooot account, please provide the email you used to make requests or to use our Services.

Where applicable, you may also have the right to register a complaint to your local data protection authority. For residents of the EU and UK, contact the EU data protection authorities. For residents of Australia, if you are not satisfied with the outcome of your complaint after first contacting us, you may wish to contact the Office of the Australian Information Commissioner.

INTERNATIONAL TRANSFERS OF INFORMATION

Information about you will be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities may be located in countries that do not provide an equivalent level of protection for personal information as your home country.

We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.

LINKS TO OTHER WEBSITES

Our Services contain links to other websites or services that are not owned or controlled by Hooot, including links to websites of Security Partners and our advertisers, our group companies, and other business partners. This Policy only applies to information collected by our Services. We have no control over these third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third party websites linked to our Services, including those of our group companies. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Services.

CHILDREN

Our Services are not directed at or intended for use by children. We do not knowingly collect information from children under 18 years of age unless the child is between the ages of 13-17 and the account is created by the legal guardian of the child. If you become aware that your child or any child under your care who is under the age of 13 has provided us with information without your consent, please contact us using the contact details listed in the How to Contact Us section below.

ADDITIONAL DISCLOSURES FOR CALIFORNIA CONSUMERS

These disclosures describe how Hooot (as defined above) collects, uses, processes, and discloses personal information of California consumers and the rights you may have under California law. These disclosures are intended to supplement Hooot’s Privacy Policy with information required by the California Consumer Privacy Act.

California law requires that we describe the personal information we collect about California consumers, including by identifying specific categories of information. As we describe in more detail in the Information We Collect and Use section of the Policy, we have collected the following categories of personal information in the past 12 months:

• Identifiers such as contact information, name, email, or IP address
• Characteristics of protected classifications under California or federal law
• Commercial information such as transaction history
• Device, usage and internet or other electronic network activity information such as information about your device type, browser settings or interactions with our sites
• Geolocation data
• Visual information
• Inferences about your preferences and interests from data we collect in order to provide and personalize our services and tailor the offers we and our partners provide to you

For information about the categories of sources from which we obtain personal information, or for additional details about the specific types of personal information we collect, please refer to the Information We Collect and Use section of the Policy. For information about our purpose(s) for collecting, or possibly sharing your personal information, please refer to the How We Use Your Information section of the Policy.

We may share your personal information with third parties as described in the How We Share Your Information section of the Privacy Policy. California law also requires that we provide you with information about certain disclosures of personal information to third parties, where the disclosure involves monetary or other consideration. California treats these disclosures as “sales” of information, even if no money changes hands. Some of the disclosures we make constitute “sales” under California law and involve the disclosure of the following types of personal information:

• Identifiers
• Commercial information
• Internet activity
• Geolocation data
• Inferences

We also disclose certain personal information for “business purposes”, such as disclosures to service providers who assist us with securing our Services or delivering marketing messages and advertisements. We disclose the following types of personal information for our business purposes:

• Identifiers
• Characteristics of protected classifications under California or federal law
• Commercial information
• Internet activity
• Geolocation data
• Visual information
• Inferences

California law grants certain rights to California consumers. These include the rights to:

• access specific pieces of personal information
• learn about how we process and share personal information
• request deletion of personal information
• opt out of “sales,” as that term is defined under California law

You may exercise your right to opt out of “sales” by selecting this preference in your account or by emailing privacy@gethooot.com.

We will not discriminate against you for exercising any of your rights under California law. Unless permitted under California law, we will not deny you any goods or services; charge you different prices or rates for goods or services; provide you a different quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that Hooot’s denial of your rights for reasons mandated or permitted by the CCPA or applicable law is not considered discriminatory.

If you are an authorized agent wishing to exercise rights on behalf of a California consumer, please contact us by emailing privacy@gethooot.com along with a copy of the consumer’s written authorization designating you as their agent.

Please note that we may need to verify your identity before completing your rights request. This may include signing into your user account or answering some security questions. Upon receiving a verifiable request, we will provide you with this information in writing, free of charge, within a time frame consistent under California law.

The following metrics below include the aggregate number of requests to know, requests to delete, and requests to opt-out received, complied with in whole or in part, and denied by Hooot: As of January 2021, 0 Requests to know, 0 Request to Delete, 0 Requests to Opt out of “sales.”

Hooot has responded to the requests to know, requests to delete, and requests to opt out within the timeframe required under applicable law.

CHANGES TO THIS POLICY

Except to the extent limited by applicable law, we will update this Policy from time to time to reflect changes in our privacy practices, legal requirements, and other factors by prominently posting notice of the update on our Services. Changes to our Policy will be effective when posted and the new effective date will be identified.

If we make any changes to the Policy that materially impact previously collected personal information about you, we will make reasonable efforts to provide notice and obtain consent to any such changes as may be required by law.

To request a copy of this Policy, or to request a copy of the Policy in place at the time you signed up for an account, please contact us at the details below.

HOW TO CONTACT US

If you have any questions about this Policy or the way in which your personal information has been used, please contact us via your account, at privacy@gethooot.com or by postal mail at:

M&Y Apps LLC

Attn: Data Protection Officer

M&Y Apps LLC

PO Box 4334

Boulder, CO 80306

USA

COOKIES AND INTEREST-BASED ADVERTISING POLICY

What are Cookies?

Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website. On mobile websites and mobile applications, we use device IDs and / or Advertising IDs in a similar manner to which we use cookies.

We and certain third-party partners (as described below) use cookies on our websites, our mobile applications and within emails or other communications we send to you (we refer to these together as our “Sites”).

To the extent the cookies we use for these purposes lead to the processing of your personal information, details about how we use that personal information and your rights over that personal information are discussed in our Policy.

What types of Cookies are used on our Sites and what do we use them for?

We use “first-party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own Sites, or to provide functionality such as remembering your language preference.

Other cookies on our Sites are used both by us for the purposes described in this policy and by third parties for purposes where those third parties may wish to combine information from our Sites with information from other sites to improve their services. For example, these types of cookies may be used for interest-based advertising purposes.

The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.

We divide the cookies we use into three categories:

Our Advertising Cookies

We work with third parties that place cookies on our Sites to provide their services, including:

1. Ad Targeting. We work with third-party advertising companies to serve ads while you are visiting our Sites and to permit these companies to place and access their own cookies on your computer in the course of serving advertisements on our Sites.
   
   These companies may use information obtained through their cookies (which does not include your name, address, e-mail address or telephone number) about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.
   
   We also allow certain third parties (as described in our Policy to collect web log data from you (which may include IP address, where permitted, and information about your browser or operating system), when you visit our Sites, or to place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified usage data or other data linked to data you voluntarily have submitted to us, for example, your email address, that we may share with third parties solely in hashed, non-human readable form.
2. Advertising Analytics/Measurement. We make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our Sites after they have been shown an online advertisement, which may include advertisements on third-party websites. In particular, our Sites use Google Analytics 360 Suite, including Google Analytics Advertising, which are web analytics and analytics advertising services provided by Google, Inc., which use third party cookies. Where required, our Sites have activated the IP address anonymization functionality so that the IP address of the user is shortened by Google. Our Sites also use the following Google Analytics Advertising features: Google Remarketing, Google Segments, Google Ads Manager and Google Ads. These features use third party cookies to collect information about our website traffic by tracking users across websites and across time and generating reports for us to better understand our website users and to create audiences for our advertisements based on such understanding.
3. Remarketing Pixel Tags. In addition, we may share website usage information about visitors to our Sites with third-party advertising companies for the purpose of managing and targeting advertisements and for market research analysis on our Sites and other sites. For these purposes, we and our third-party advertising companies may place pixel tags (also called clear gifs) on some of the pages you visit on our Sites. We will then use the information that is collected using these pixel tags to serve you relevant advertisements when you are visiting other sites on the Internet. These advertisements may be based on your interests, for example, on the basis of specific action you conducted on our Sites during earlier browsing sessions.
4. Other Cookies: Our partners, who provide certain features on our Sites or display advertising based on your browsing activity, also use Local Storage such as HTML5, to collect and store content information and preferences. Please note that different web browsers offer their own management tools for removing HTML5 local storage.

Mobile Devices, Anonymous Device Identifiers and Hashed IDs. We and/or third parties that we have engaged may collect and store a unique identifier matched to your mobile device, in order to deliver customized ads or content while you use applications or surf the internet, or to identify you in a unique manner across other devices or browsers. In order to customize these ads or content, we or a third party may collect de-identified usage data or other data about you which you have either voluntarily submitted to us, for example, your email address, or has been passively collected from you, such as your device identifier or IP address, where permitted. However, if we share your email address, we share it solely in hashed, non-human-readable form.

Your Cookie Choices

We provide you with choices over the use of cookies as described in this policy.

When you first visit our Sites, where required by law, you will have the option to give your consent to the advertising and functional cookies we use, or to refuse your consent to our use of those cookies by clicking on the [X] within that disclosure.

Browsers. Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools" or "Edit" facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have tried to indicate where this is possible in the table above.

You can also find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, at www.allaboutcookies.org and www.youronlinechoices.eu.

Mobile Devices. If you no longer wish to receive interest-based advertising on your mobile applications, please refer to your device’s operating system settings and follow instructions below.

1. iOS users: To use the "Limit Ad-Tracking" option, follow the instructions provided by Apple here: Apple Support Center
2. Android Users: To use the "opt-out of interest-based advertising" option, follow the instructions provided by Google here: Google Play Help
3. You may also consider downloading the DAA AppChoices Mobile App to manage online behavioral advertising technology.

If you no longer wish to receive interest-based advertising on your mobile device browser, you can follow the steps in relation to Browsers outlined above.

Do-Not-Track Signals. We currently do not employ technology that recognizes “do-not-track” signals from your browser.

Please keep in mind that, without cookies, you may not have access to certain features on our Sites, including access to your profile/account and certain personalized content. Removing all cookies from your computer could also affect your subsequent visits to certain websites, including our Sites, by requiring that, for example, you enter your login name when you return to that website. Please note that even if you exercise any of the choices described above, you will still see ads, but they will not be based upon the information collected through these tracking technologies, and therefore not necessarily relevant to your interests.

Contact. If you have any questions about our use of cookies, please email us at security@gethooot.com.