Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.


Interpretation and Definitions


Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions:
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application means the software program provided by the Company downloaded by You on any electronic device, named HJAELP.
‍Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
‍Company(referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to HJAELP ApS. For the purpose of the GDPR, the Company is the Data Controller.
‍Consumer, or the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law,includes (1) every individual who is in the USA for other than a temporary ortransitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Country refers to: Denmark
‍DataController, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone, ora digital tablet.
‍DoNot Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the internett industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
‍FacebookFan Page is a public profile named HJAELP specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/hjaelp.io
‍Personal Data is any information that relates to an identified or identifiableindividual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.For the purposes of the CCPA, Personal Datameans any information that identifies, relates to, describes or is capable ofbeing associated with, or could reasonably be linked, directly or indirectly,with You.
‍Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,renting, releasing, disclosing, disseminating, making available, transferring,or otherwise communicating orally, in writing, or by electronic or other means,a Consumer's personal information to another business or a third party formonetary or other valuable consideration.
‍Service refers to the Application.
‍ServiceProvider means any natural or legal person who processes the data on behalfof the Company. It refers to third-party companies or individuals employed bythe Company to facilitate the Service, to provide the Service on behalf of theCompany, to perform services related to the Service or to assist the Company inanalyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
‍Third-partySocial Media Service refers to any website or any social network websitethrough which a User can log in or create an account to use the Service.
‍UsageData refers to data collected automatically, either generated by the use ofthe Service or from the Service infrastructure itself (for example, theduration of a page visit).
‍Youmeans the individual accessing or using the Service, or the company, or otherlegal entity on behalf of which such individual is accessing or using theService, as applicable.Under GDPR (General Data ProtectionRegulation), You can be referred to as the Data Subject or as the User as youare the individual using the Service.


Collecting and Using Your Personal Data


Types of Data Collected

Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
· Email address
· First name and last name
· Phone number
· Address, State, Province, ZIP/Postal code, City
· Bank account information in order to pay for products and/or services within the Service
· Usage Data

When You pay for a product and/or a service via banktransfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
· Date of birth
· Passport or National ID card
· Bank card statement
· Other information linking You to an address

Usage Data
Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device'sInternet Protocol address (e.g. IP address), browser type, browser version, thepages of our Service that You visit, the time and date of Your visit, the timespent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
·      Google
·      Facebook
·      Twitter

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data thatis already associated with Your Third-Party Social Media Service's account,such as Your name, Your email address, Your activities or Your contact listassociated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share,and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
· Information regarding your location
· Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service,to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at anytime, through Your Device settings.

Use of Your Personal Data
The Company may use Personal Data for the following purposes:
· To provide and maintain our Service, including to monitor the usage of our Service.
· To manage Your Account: to manage Your registration as a user of the Service.The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
· For the performance of a contract: the development, compliance and undertakingof the purchase contract for the products, items or services You have purchasedor of any other contract with Us through the Service.
· To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related tothe functionalities, products or contracted services, including the securityupdates, when necessary or reasonable for their implementation.
· To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
· To manage Your requests: To attend and manage Your requests to Us.
· For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other saleor transfer of some or all of Our assets, whether as a going concern or as partof bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
· Forother purposes: We may use Your information for other purposes, such asdata analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products,services, marketing and your experience.

We may share Your personal information in the following situations:
· With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
· For business transfers: We may share or transfer Your personal information in connectionwith, or during negotiations of, any merger, sale of Company assets, financing,or acquisition of all or a portion of Our business to another company.
· With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
· With business partners: We may share Your information with Our businesspartners too offer You certain products, service,s or promotions.
· With other users: when You share personal information or otherwise interactin thee public areas with other users, such information may be viewed by allusers andd may be publicly distributed outside. If You interact with other users orregister through a Third-Party Social Media Service, Your contacts on theThird-Party Social Media Service may see Your name, profile, picture,s anddescription of Your activity. Similarly, other users will be able toview descriptionss of Your activity, communicate with Yo,u and view Your profile.
· With YourConsentt: We may disclose Your personal information for any other purposewith Your consent.

Retention of Your Personal Data
The Company will retain Your Personal Data only for as longas is necessary for the purposes set out in this Privacy Policy. We will retainand use Your Personal Data to the extent necessary to comply with our legalobligations (for example, if we are required to retain your data to comply withapplicable laws), resolve disputes, and enforce our legal agreements andpolicies.
The Company will also retain Usage Data for internalanalysis purposes. Usage Data is generally retained for a shorter period oftime, except when this data is used to strengthen the security or to improvethe functionality of Our Service, or We are legally obligated to retain thisdata for longer time periods.

Transfer of Your Personal Data
Your information, including Personal Data, is processed atthe Company's operating offices and in any other places where the partiesinvolved in the processing are located. It means that this information may betransferred to — and maintained on — computers located outside of Your state,province, country or other governmental jurisdiction where the data protectionlaws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Yoursubmission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary toensure that Your data is treated securely and in accordance with this PrivacyPolicy and no transfer of Your Personal Data will take place to an organizationor a country unless there are adequate controls in place including the securityof Your data and other personal information.


Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before YourPersonal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements
The Company may disclose Your Personal Data in the goodfaith belief that such action is necessary to:
·      Comply with a legal obligation
·      Protect and defend the rights or property of theCompany
·      Prevent or investigate possible wrongdoing in connection with the Service
·      Protect the personal safety of Users of theService or the public
·      Protect against legal liability

Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.


Detailed Information on the Processing of Your Personal Data


The Service Providers We use may have access to YourPersonal Data. These third-party vendors collect, store, use, process andtransfer information about Your activity on Our Service in accordance withtheir Privacy Policies.

Analytics
We may use third-party Service providers to monitor andanalyze the use of our Service.

GoogleAnalytics
‍Google Analytics is a web analytics serviceoffered by Google that tracks and reports website traffic. Google uses the datacollected to track and monitor the use of our Service. This data is shared withother Google services. Google may use the collected data to contextualize andpersonalize the ads of its own advertising network.You may opt-out of certain Google Analyticsfeatures through your mobile device settings, such as your device advertisingsettings or by following the instructions provided by Google in their PrivacyPolicy: https://policies.google.com/privacyFor more information on the privacy practicesof Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing
We may use Your Personal Data to contact You withnewsletters, marketing or promotional materials and other information that maybe of interest to You. You may opt-out of receiving any, or all, of thesecommunications from Us by following the unsubscribe link or instructionsprovided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.

‍Mailchimp
‍Mailchimp is an email marketing sendingservice provided by The Rocket Science Group LLC.For more information on the privacy practicesof Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Payments
We may provide paid products and/or services within the Service.In that case, we may use third-party services for payment processing (e.g.payment processors).

We will not store or collect Your payment card details. Thatinformation is provided directly to Our third-party payment processors whoseuse of Your personal information is governed by their Privacy Policy. Thesepayment processors adhere to the standards set by PCI-DSS as managed by the PCISecurity Standards Council, which is a joint effort of brands like Visa,Mastercard, American Express and Discover. PCI-DSS requirements help ensure thesecure handling of payment information.

‍Stripe
‍Their Privacy Policy can be viewed at https://stripe.com/us/privacy

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate thistransaction and to verify Your identity.


GDPR Privacy


Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:
·      Consent:You have given Your consent for processing Personal Data for one or morespecific purposes.
·      Performanceof a contract: Provision of Personal Data is necessary for the performanceof an agreement with You and/or for any pre-contractual obligations thereof.
·      Legalobligations: Processing Personal Data is necessary for compliance with alegal obligation to which the Company is subject.
·      Vitalinterests: Processing Personal Data is necessary in order to protect Yourvital interests or of another natural person.
·      Publicinterests: Processing Personal Data is related to a task that is carriedout in the public interest or in the exercise of official authority vested inthe Company.
·      Legitimate interests: Processing Personal Data is necessary for the purposes of thelegitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify thespecific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.

Your Rights under the GDPR
The Company undertakes to respect the confidentiality ofYour Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law ifYou are within the EU, to:
·      Requestaccess to Your Personal Data. The right to access, update or delete theinformation We have on You. Whenever made possible, you can access, update orrequest deletion of Your Personal Data directly within Your account settingssection. If you are unable to perform these actions yourself, please contact Usto assist You. This also enables You to receive a copy of the Personal Data Wehold about You.
·      Requestcorrection of the Personal Data that We hold about You. You have the rightto have any incomplete or inaccurate information We hold about You corrected.
·      Object toprocessing of Your Personal Data. This right exists where We are relying ona legitimate interest as the legal basis for Our processing and there is somethingabout Your particular situation, which makes You want to object to ourprocessing of Your Personal Data on this ground. You also have the right toobject where We are processing Your Personal Data for direct marketing purposes.
·      Request erasure of Your Personal Data. You have the right to ask Us to delete orremove Personal Data when there is no good reason for Us to continue processingit.
·      Request the transfer of Your Personal Data. We will provide to You, or to athird-party You have chosen, Your Personal Data in a structured, commonly used,machine-readable format. Please note that this right only applies to automatedinformation which You initially provided consent for Us to use or where We usedthe information to perform a contract with You.
·      WithdrawYour consent. You have the right to withdraw Your consent on using yourPersonal Data. If You withdraw Your consent, We may not be able to provide Youwith access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask Youto verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data ProtectionAuthority about Our collection and use of Your Personal Data. For moreinformation, if You are in the European Economic Area (EEA), please contactYour local data protection authority in the EEA.


Facebook Fan Page


Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/hjaelp.io,the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.phpfor more information about how Facebook manages Personal data or contactFacebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the informationstored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation


CCPA Privacy


This privacy notice section for California residentssupplements the information contained in Our Privacy Policy and it appliessolely to all visitors, users, and others who reside in the State ofCalifornia.

Categories of Personal Information Collected
We collect information that identifies, relates to,describes, references, is capable of being associated with, or could reasonablybe linked, directly or indirectly, with a particular Consumer or Device. Thefollowing is a list of categories of personal information which we may collect ormay have been collected from California residents within the last twelve (12)months.

Please note that the categories and examples provided in thelist below are those defined in the CCPA. This does not mean that all examplesof that category of personal information were in fact collected by Us, butreflects our good faith belief to the best of our knowledge that some of thatinformation from the applicable category may be and may have been collected.For example, certain categories of personal information would only be collectedif You provided such personal information directly to Us.

Category A: Identifiers.
‍Examples: A real name, alias, postaladdress, unique personal identifier, online identifier, Internet Protocoladdress, email address, account name, driver's license number, passport number,or other similar identifiers.
Collected: Yes.

‍Category B: Personal information categories listed in the California Customer Recordsstatute (Cal. Civ. Code § 1798.80(e)).
‍Examples: A name, signature, Social Securitynumber, physical characteristics or description, address, telephone number,passport number, driver's license or state identification card number,insurance policy number, education, employment, employment history, bankaccount number, credit card number, debit card number, or any other financialinformation, medical information, or health insurance information. Somepersonal information included in this category may overlap with othercategories.
Collected: Yes.

‍Category C: Protected classification characteristics under California or federal law.Examples: Age (40 years or older), race,color, ancestry, national origin, citizenship, religion or creed, maritalstatus, medical condition, physical or mental disability, sex (includinggender, gender identity, gender expression, pregnancy or childbirth and relatedmedical conditions), sexual orientation, veteran or military status, geneticinformation (including familial genetic information).
Collected: No.

‍Category D: Commercial information.
‍Examples: Records and history of productsor services purchased or considered.
Collected: Yes.

‍Category E: Biometric information.
‍Examples: Genetic, physiological,behavioral, and biological characteristics, or activity patterns used toextract a template or other identifier or identifying information, such as,fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.

‍Category F: Internet or other similar network activity.
‍Examples: Interaction with our Service oradvertisement.
Collected: Yes.

‍Category G: Geolocation data.
‍Examples: Approximate physical location.
Collected: Yes.

‍Category H: Sensory data.
‍Examples: Audio, electronic, visual,thermal, olfactory, or similar information.
Collected: No.

‍Category I: Professional or employment-related information.
‍Examples: Current or past job history orperformance evaluations.
Collected: No.

‍Category J: Non-public education information (per the Family Educational Rights andPrivacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
‍Examples: Education records directly related to a student maintained by an educational institution or party actingon its behalf, such as grades, transcripts, class lists, student schedules,student identification codes, student financial information, or student disciplinary records.
Collected: No.

‍Category K: Inferences drawn from other personal information.
‍Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.

Under CCPA, personal information does not include:
· Publicly available information from government records
· Deidentified or aggregated consumer information
· Information excluded from the CCPA's scope, such as:
· Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
· Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information PrivacyAct (FIPA), and the Driver's Privacy Protection Act of 1994Sources of Personal InformationWe obtain the categories of personal information listed above from the following categories of sources:

· Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Yourpurchases onn our Service.

· Indirectlyfrom You. For example, from observing Your activity on our Service.

· Automaticallyfrom You. For example, through cookies We or our Service Providers seton yourr Device as You navigate through our Service.

· FromService Providers. For example, third-party vendors to monitor andanalyze thee use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.Use of Personal Information for Business Purposes or Commercial PurposesWe may use or disclose personal information We collect for"business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

·      To operate our Service and provide You withour servicee.

·      To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.

·      To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond toYour inquiry. If You provide Your personal information to purchase a product orservice, We will use that information to process Your payment and facilitate delivery.

·      To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·      As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

·      For internal administrative and auditing purposes.

·      To detect security incidents and protectagainst maliciouss, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.Please note that the examples provided aboveare illustrativee and not intended to be exhaustive. For more details on how weuse thiss information, please refer to the "Use of Your Personal Data"section.If We decide to collect additional categories of personal informationor use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.Disclosure of Personal Information for Business Purposes or Commercial PurposesWe may use or disclose and may have used or disclosed in thelast twelve (12) months the following categories of personal information for business or commercial purposes:

·      Category A: Identifiers

·      Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·      Category D: Commercial information

·      Category F: Internet or other similar networkactivity

·      Category G: Geolocation data

Please note that the categories listed above are thosedefined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.Sale of Personal InformationAs defined in the CCPA, "sell" and"sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information bythe businesss to a third party for valuable consideration. This means that Wemay havee received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.Please note that the categories listed below arethose definedd in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.We may sell and may have sold in the last twelve (12) months the following categories of personal information:

·      Category A: Identifiers

·      Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·      Category D: Commercial information

·      Category F: Internet or other similar networkactivity

·      Category G: Geolocation data

Share of Personal Information
We may share Your personal information identified in theabove categories with the following categories of third parties:

·      Service Providers

·      Payment processors

·      Our affiliates

·      Our business partners

·      Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to YouSale of Personal Information of Minors Under 16 Years of AgeWe do not sell the personal information of Consumers Weactually know are less than 16 years of age, unless We receive affirmative authorization(the "right to opt-in") from either the Consumer who is between 13and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.If You have reason to believe that a child under the age of13 (or 16) has provided Us with personal information, please contact Us withsufficient detail to enable Us to delete that information.Your Rights under the CCPAThe CCPA provides California residents with specific rightsregarding their personal information. If You are a resident of California, Youhave the following rights:

·      The rightto notice. You have the right to be notified which categories of PersonalData are being collected and the purposes for which the Personal Data is beingused.

·      The rightto request. Under CCPA, You have the right to request that We discloseinformation to You about Our collection, use, sale, disclosure for businesspurposes and share of personal information. Once We receive and confirm Yourrequest, We will disclose to You:

·      The categories of personal information Wecollected about You

·      The categories of sources for the personalinformation We collected about You

·      Our business or commercial purpose for collecting or selling that personal information

·      The categories of third parties with whom We share that personal information·      The specific pieces of personal information We collected about You

·      If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose toYou:

·      The categories of personal information categories sold·      The categories of personal information categories disclosed

·      The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.

·      The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may denyYour deletion request if retaining the information is necessary for Us or OurService Providers to: ·      Complete the transaction for which We collectedthe personal information, provide a good or service that You requested, takeactions reasonably anticipated within the context of our ongoing businessrelationship with You, or otherwise perform our contract with You.

·      Detect security incidents, protect againstmalicious, deceptive, fraudulent, or illegal activity, or prosecute thoseresponsible for such activities.

·      Debug products to identify and repair errorsthat impair existing intended functionality.

·      Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

·      Comply with the California Electronic CommunicationsPrivacy Act (Cal. Penal Code § 1546 et. seq.).

·      Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to allother applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

·      Enable solely internal uses that are reasonablyaligned with consumer expectations based on Your relationship with Us.

·      Comply with a legal obligation.

·      Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

·      The rightnot to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

·      Denying goods or services to You

·      Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposingpenalties

·      Providing a different level or quality of goodsor services to You

·      Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods orservices Exercising Your CCPA Data Protection Rights In order to exercise any of Your rights under the CCPA, andif You are a California resident, You can contact Us:

·      By email: support@hjaelp.io

 

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.Your request to Us must:

·      Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

·      Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it We cannot respond to Your request or provide You with therequired information if We cannot:

·      Verify Your identity or authority to make therequest

·      And confirm that the personal information relates to YouWe will disclose and deliver the required information freeof charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45days when reasonably necessary and with prior notice.Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.For data portability requests, We will select a format toprovide Your personal information that is readily usable and should allow Youto transmit the information from one entity to another entity withouthindrance.Do Not Sell My Personal InformationYou have the right to opt-out of the sale of Your personalinformation. Once We receive and confirm a verifiable consumer request fromYou, we will stop selling Your personal information. To exercise Your right toopt-out, please contact Us.The Service Providers we partner with (for example, ouranalytics or advertising partners) may use technology on the Service that sellspersonal information as defined by the CCPA law. If you wish to opt out of theuse of Your personal information for interest-based advertising purposes andthese potential sales as defined under CCPA law, you may do so by following theinstructions below.Please note that any opt out is specific to the browser Youuse. You may need to opt out on every browser that You use.WebsiteYou can opt out of receiving ads that are personalized asserved by our Service Providers by following our instructions presented on theService:·      The NAI's opt-out platform: http://www.networkadvertising.org/choices/·      The EDAA's opt-out platform http://www.youronlinechoices.com/·      The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=ENThe opt out will place a cookie on Your computer that isunique to the browser You use to opt out. If you change browsers or delete thecookies saved by your browser, You will need to opt out again.Mobile DevicesYour mobile device may give You the ability to opt out ofthe use of information about the apps You use in order to serve You ads that aretargeted to Your interests:·      "Opt out of Interest-Based Ads" or"Opt out of Ads Personalization" on Android devices·      "Limit Ad Tracking" on iOS devicesYou can also stop the collection of location informationfrom Your mobile device by changing the preferences on Your mobile device.


"Do Not Track" Policy as Required by CaliforniaOnline Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.However, some third party websites do keep track of Yourbrowsing activities. If You are visiting such websites, You can set Yourpreferences in Your web browser to inform websites that You do not want to betracked. You can enable or disable DNT by visiting the preferences or settingspage of Your web browser.


Children's Privacy


The Service may contain content appropriate for childrenunder the age of 13. As a parent, you should know that through the Servicechildren under the age of 13 may participate in activities that involve thecollection or use of personal information. We use reasonable efforts to ensurethat before we collect any personal information from a child, the child'sparent receives notice of and consents to our personal information practices.

We also may limit how We collect, use, and store some of theinformation of Users between 13 and 18 years old. In some cases, this means Wewill be unable to provide certain functionality of the Service to these Users.If We need to rely on consent as a legal basis for processing Your informationand Your country requires consent from a parent, We may require Your parent'sconsent before We collect and use that information.

We may ask a User to verify its date of birth beforecollecting any personal information from them. If the User is under the age of13, the Service will be either blocked or redirected to a parental consentprocess.

Information Collected from Children Under the Age of 13
The Company may collect and store persistent identifierssuch as cookies or IP addresses from Children without parental consent for thepurpose of supporting the internal operation of the Service.
We may collect and store other personal information aboutchildren if this information is submitted by a child with prior parent consentor by the parent or guardian of the child.The Company may collect and store the following types ofpersonal information about a child when submitted by a child with priorparental consent or by the parent or guardian of the child:
·      First and/or last name
·      Date of birth
·      Gender
·      Grade level
·      Email address
·      Telephone number
·      Parent's or guardian's name
·      Parent's or guardian's email address

For further details on the information We might collect, Youcan refer to the "Types of Data Collected" section of this PrivacyPolicy. We follow our standard Privacy Policy for the disclosure of personalinformation collected from and about children.

Parental Access
A parent who has already given the Company permission tocollect and use his child personal information can, at any time:
·      Review, correct or delete the child's personalinformation
·      Discontinue further collection or use of thechild's personal information

To make such a request, You can write to Us using thecontact information provided in this Privacy Policy.


Your California Privacy Rights (California's Shine the Lightlaw)


Under California Civil Code Section 1798 (California's Shinethe Light law), California residents with an established business relationshipwith us can request information once a year about sharing their Personal Datawith third parties for the third parties' direct marketing purposes.

If you'd like to request more information under theCalifornia Shine the Light law, and if You are a California resident, You cancontact Us using the contact information provided below.


California Privacy Rights for Minor Users (CaliforniaBusiness and Professions Code Section 22581)


California Business and Professions Code Section 22581allows California residents under the age of 18 who are registered users ofonline sites, services or applications to request and obtain removal of contentor information they have publicly posted.

To request removal of such data, and if You are a Californiaresident, You can contact Us using the contact information provided below, andinclude the email address associated with Your account.

Be aware that Your request does not guarantee complete orcomprehensive removal of content or information posted online and that the lawmay not permit or require removal in certain circumstances.


Links to Other Websites


Our Service may contain links to other websites that are notoperated by Us. If You click on a third party link, You will be directed tothat third party's site. We strongly advise You to review the Privacy Policy ofevery site You visit.

We have no control over and assume no responsibility for thecontent, privacy policies or practices of any third party sites or services.


Changes to this Privacy Policy


We may update Our Privacy Policy from time to time. We willnotify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice onOur Service, prior to the change becoming effective and update the "Lastupdated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodicallyfor any changes. Changes to this Privacy Policy are effective when they areposted on this page.


Contact Us


If you have any questions about this Privacy Policy, You can contact us:
· By email: support@hjaelp.io