2. Data collection

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where your identity has been permanently removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you.

The types of information we collect are:

• User Account Data includes hardware ID (HWID) and passkey
• Technical Data includes information about how you use our app and services, internet protocol (IP) address, your login data, operating system and platform, and other technology on the devices you use to access this app.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our app to help improve the website and our service offering.

If you fail to provide personal data

Where we ask you to provide personal data and you choose not to do so, we may not be able to provide you with the full functionality of our app and some features may not be accessible.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions You may give us your personal data by using our app and interacting with our services. This includes personal data you provide when you:
• Create an account
• Use the features of of our application
• Subscribe to our service
• Technical Data or interactions. As you interact with our app, we will automatically collect Technical Data depending on what features of our app you decide to use. We collect this User Account data by using, server logs and other similar technologies

4. Data usage

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Peformance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

5. Disclosure of your personal data

We may share your User Account Data & Technical Data with third parties.

• External Third Parties as set out in clause 10.1.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your User Account Data and Technical Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your User Account Data and Technical Data for their own purposes and only permit them to process your User Account Data and Technical Data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third-party service providers are based outside the UK so their processing of your User Account Data and Technical Data will involve a transfer of data outside the UK.

Whenever we transfer your User Account Data and Technical Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for User Account Data and Technical Data.
• Where we use certain service providers which are located in a country not deemed to provide an adequate level of protection for User Account Data and Technical Data, we may use specific contracts approved for use in the UK which give User Account Data and Technical Data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my User Account Data and Technical Data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for User Account Data and Technical Data, we consider the amount, nature and sensitivity of the User Account Data and Technical Data, the potential risk of harm from unauthorised use or disclosure of your User Account Data and Technical Data, the purposes for which we process your User Account Data and Technical Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data. However, you will lose access to our services: see your legal rights below for further information.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us via email at info@hdoptimisations.com .

No fee usually required

You will not have to pay a fee to access your User Account data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your User Account data and Technical Data (or to exercise any of your other rights). This is a security measure to ensure that User Account data and Technical Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

EXTERNAL THIRD PARTIES

• Service providers acting as processors based in the UK and the EU who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK and the EU who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Table of Specific Third Parties