Houdah Software s.à r.l. ("we", "us", "our") is committed to protecting and respecting your privacy. This document serves to inform you about the nature, scope, and purpose of the personal data we collect, receive, use, and process. Furthermore, you are informed about the choices and rights you have with regard to this data. By using our Service, or otherwise sharing information with us, you agree to the collection, use, and storage of personal data in accordance with this policy.
- the houdah.com and related websites (including our discussion forums and blog)
- the software applications published by Houdah Software s.à r.l. (including HoudahSpot, HoudahGeo, Tembo, and Type2Phone)
- other products and services offered by Houdah Software s.à r.l. (including our newsletters)
Name and Address of the Controller
For the purpose of the European Union General Data Protection Regulation ("GDPR") and other applicable privacy laws, the data controller is:
Houdah Software s.à r.l.
255 route d'Arlon
- 'personal data' means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- 'data subject' means an identified or identifiable natural person who uses our Service or otherwise provides us personal data
- 'processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- 'restriction of processing' means the marking of stored personal data with the aim of limiting their processing in the future
- 'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements
- 'controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
- 'processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
- 'recipient' means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing
- 'third party' means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data
- 'consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
Data Collection and Storage
Data You Provide
- Contact information including, but not limited to your name, email address, phone number, and postal address
- Content for publishing. For example: a public post to our discussion forums
- Communications with us. For example: email messages, crash reports, tweets, or web forms you submit
- Other personal data. For example: sample data you provide to customer support to illustrate a problem
Data We Collect Automatically
- Server log and usage data. Our online services - like most websites - collect a series of general data and information when called up by a data subject or automated system. This typically includes the accessing computer's Internet protocol address ("IP address"), application / browser type and version used, operating system used, source by which our websites were reached (known as referrer), date, time, pages of our websites visited as well as similar data and diagnostic information.
- Usage and debugging information. Our support and crash reporting services may collect additional information to help us provide customer support, detect and address problems. This typically includes operating system and software versions used, error logs, license information and, if provided, contact information.
- Information included in your communications with us. For example, when you contact us by email your message typically includes your computer's Internet protocol address, email software used and operating system used. When you contact us through social networks, we may collect personal data such as your user name and public profile on that network.
Examples of cookies we use:
- Strictly necessary cookies. This include, for example, cookies that enable you to log in to certain areas of our websites
- Analytical cookies. These allow us, for example, to analyze how our websites are used
- Preference cookies. These allow us, for example, to remember your preferences and personalize website content
You may, at any time, use the features of your browser to prevent the setting of cookies or delete existing cookies. If you chose to deactivate cookies, some portions of our Service may not function fully.
We use the collected data for the following purposes:
- To provide and maintain our Service to you. For example, to provide you with a license key to one of our software applications
- To provide customer support for our Service
- To provide you with information you have requested
- To notify you of changes to our Service or our policies
- To analyze usage, further develop and improve our Service
- To measure, evaluate, and improve effectiveness of our communication and advertisements
- To provide you with news, information relating to our Service, product announcements, special offers, and related content where you have consented to be contacted for such purposes
- To allow you to participate in our discussion forums
- To monitor, detect, and prevent any problems with our Service
- To remember your preferences and personalize your experience. For example, provide website content in your preferred language
We will send you our newsletter only if you opted in to receiving it. You may unsubscribe at any time by following the unsubscribe link in our newsletter or by contacting us directly.
As a general rule, we don't share personal data with any third party. There are a few exceptions where we may have to disclose personal data:
- To meet applicable laws, regulations, legal processes, or enforceable governmental requests
- To protect rights, property, or safety of Houdah Software s.à r.l., our data processors, our customers, or others
- To prevent, investigate, or address misuse, fraud, or other wrongdoing in connection with our Service
- To prevent, investigate, or address security or technical issues with our Service
- To enforce applicable terms of service or license agreements
- With your consent
Although we will do our best to protect your personal data, you should know that Internet-based data transmissions and electronic data storage may have security gaps. Thus, we cannot guarantee absolute protection of your data.
Data Protection Rights
Where the European Union General Data Protection Regulation applies, the European legislator has granted the following rights to data subjects:
- Right of confirmation: A data subject can contact us to the confirmation as to whether or not personal data concerning him or her are being processed
- Right to rectification: A data subject can contact us to have inaccurate or incomplete personal data rectified
- Right to erasure: A data subject can contact us to request erasure of personal data that is no longer needed as set forth above. We will use reasonable endeavors to remove personal data from our systems where legal and technically feasible
- Right to object. Right to restriction of processing. Right to withdraw consent: A data subject can contact us to object to our processing of personal information. For example, to unsubscribe from our newsletter
- Right to data portability: A data subject can contact us to receive personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format
- Right to lodge a complaint: A data subject can contact a supervisory authority to lodge a complaint
In order to protect the privacy of data subjects, we may ask you to verify your identity before responding to such requests.
Legal Basis For Data Collection and Use
Where the European Union General Data Protection Regulation applies, our collection and use of data is based on the following grounds:
- The data is necessary to provide our Service, to fulfill our commitments or other agreements with you. For example, in order to provide access to paid features of our Service
- The data is necessary to comply with a legal obligation. For example, to fulfill statutory storage obligations
- The data is necessary to process payments, avoid misuse, or fraud in connection with our Service
- We have legitimate interests in processing the data and these are not overridden by your personal rights. For example, to analyze usage, further develop and improve our Service, our communication, or advertising
- You have given us consent. For example, when you request information, customer support, or subscribe to our newsletter
There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that informs websites that you do not want to be tracked. This is referred to as a Do-Not-Track ("DNT") signal.
We do not support Do-Not-Track.
Our Services are not directed to individuals under 13. We do not knowingly collect personal data from children under 13. If we become aware that a child under 13 has provided us with personal data without parental consent, we will take steps to delete such information. If you become aware that a child has provided us with personal data, please contact us.
Data Processors and Service Providers
We rely on Service Providers to help us provide our Service, provide the Service or part of it on our behalf, or to assist us in the collection and use of data.
Web analytics is the collection, gathering, and analysis of data about the number and behavior of visitors to websites.
Google Analytics is a web analytics service operated by Google Inc.
For further information on what data is collected, how it is used, your options and rights, refer to https://www.google.com/intl/en/policies/privacy/
Clicky is a web analytics service operated by Roxr Software Ltd.
For further information refer to https://clicky.com/terms/privacy
Jetpack is a WordPress toolkit operated by Automattic Inc.
For further information refer to https://automattic.com/privacy/
We rely on payment processors to securely process payment for our Service.
iOS and Mac App Stores operated by Apple, Inc.
For further information refer to https://automattic.com/privacy/
FastSpring operated by Bright Market, LLC d/b/a FastSpring
For further information refer to https://fastspring.com/privacy/
Web Hosting and Email
Stablehost.com operated by Stable Host, LLC
For further information refer to https://www.stablehost.com/privacy.php
Website Toolbox operated by Website Toolbox, Inc.
For further information refer to https://www.websitetoolbox.com/privacy
Gmail operated by Google Inc.
For further information refer to https://policies.google.com/privacy
Campaign Monitor operated by Campaign Monitor Pty Ltd.
For further information refer to https://www.campaignmonitor.com/policies/#privacy-policy
Advertising and Remarketing
LinkedIn Ads operated by LinkedIn Corporation
For further information refer to https://www.linkedin.com/legal/privacy-policy/
Impact Radius operated by Impact Tech, Inc.
For further information refer to https://impact.com/privacy-policy/
You can also opt-out from Google, Twitter, Facebook, and other participating companies via the consumer choice tools created under self-regulation programs in many countries, such as the US-based aboutads.info (http://www.aboutads.info/choices/) choices page or the EU-based Your Online Choices (http://www.youronlinechoices.eu/).
Customer Support, Crash Reporting and App Analytics
Replies operated by Replies AG
For further information refer to https://replies.io/privacy_policy.html
HockeyApp operated by Microsoft Inc.
For further information refer to https://privacy.microsoft.com/en-us/PrivacyStatement
Crashlytics operated by Google Inc.
For further information refer to https://try.crashlytics.com/terms/privacy-policy.pdf
You may encounter embedded videos and files on our websites. Such content may be hosted by third party services such as YouTube, Vimeo, or DropBox.
Third-Party Websites and Services
Please note that we cannot assume any responsibility for the content or the privacy policies of third-party websites or services.
Effective date: May 25, 2018.