PRIVACY POLICY
We respect and honor your privacy! Any and all information collected
at this site will be kept strictly confidential and will not be sold,
reused, rented, loaned, or otherwise disclosed. Any information you
give to Halley Elise.com will be held with
the utmost care, and will not be used in ways that you have not consented
to. A more detailed explanation about how we safeguard your personal
information is described below. If you have any questions, please
contact us.
Thank You,
Halley Elise
1. Overview of Halley Elise.com Privacy Policy Definitions
- We’re Halley Elise and Halley Elise.com
and Mysteries by Halley Elise at
5301 N. Federal Hwy., Ste. 200 Boca Raton, FL 33487
USA. This policy sets out how we handle your personal information
if you’re a Halley Elise website user or visitor to our
Sites. It applies across all Halley Elise products and websites (the “Sites” or
"websites")
- When we say ‘we’, ‘us’ or Halley Elise it’s because that’s who
we are and we own and run the Sites.
- Where the wording reads as ‘policy’ we’re talking about this
privacy policy. If we say ‘user terms’ we’re talking about the rules
for using each of the Sites. The rules vary by product and each
product makes them separately available and seeks consent to them
separately to this policy.
- Both personal information and personal data have the same meaning
in the context of this Privacy Policy.
2. The type of personal information we collect
- We collect certain personal information about visitors and users
of our Sites.
- The most common types of information we collect include things
like: user-names, member names, email addresses, IP addresses, other
contact details, survey responses, blogs, photos, payment information
such as payment agent details, transactional details, tax information,
support queries, forum comments, content you direct us to make available
on our Sites (such as item descriptions) and web analytics data.
We will also collect personal information from job applications
(such as, your CV, the application form itself, cover letter and
interview notes).
3. How We Collect Information
- We collect personal information directly when you provide it
to us, automatically as you navigate through the Sites, or through
other people when you use services associated with the Sites.
- We collect your personal information when you provide it to
us when you complete software registration and buy or provide
items or services on our Sites, subscribe to a newsletter, email
list, submit feedback, request support by e-mail or other
computer methods, enter a contest, fill out a survey, or send
us a communication.
4. Personal information we collect about you from
others
Although we generally collect personal information directly
from you, on occasion, we also collect certain categories of personal
information about you from other sources. In particular:
- financial and/or transaction details from payment providers
located in the US or your country of origin processor in order to process a transaction.
We do not collect credit card number information in any
manner because third party providers process the payments
and do not provide credit card number information for
Halley Elise;
- third party service providers (like Google, Facebook,
Linked-In) who
are located in the US or your country of origin, which may provide information about
you when you link, connect, or login to your account with the
third party provider and they send us information such as your
registration and profile from that service, this only occurs
if you are using Halley Elise e-mail
newsletters. The information varies and
is controlled by that service provider or as authorized by you
via your privacy settings at that service provider; and
- other third party sources/ and or
partners from Australia, Germany, Greece, Netherlands, US or UK,
whereby we receive additional information about you (to the
extent permitted by applicable law), such as demographic data or
fraud detection information, and combine it with information we
have about you. For example, fraud warnings from service
providers like identity verification service. We also receive
information about you and your activities on and off the Halley
Elise
platform through partnerships, or about your experiences and
interactions from our partner ad networks. We also receive information
about you from other vendors that integrate our products and
support or training is needed.
- Endorsements such as testimonials or other information release when your
image, testimonial, endorsement or other information is used in an item made available on our Sites
may be directly provided by you.
5. How we use personal information
- To fulfill a contract, or take steps linked to a contract:
in particular, in facilitating and processing transactions that
take place on the Sites such as where you purchase an item using
on-line shopping carts, PayPal, VISA or similar payment
processing methods.
- Where this is necessary for purposes which are in our, or third
parties, legitimate interests. These interests include:
- operating
the Sites;
- providing you with services described on the Sites;
- verifying your identity when you sign in to any of our Sites;
- responding to support tickets, and helping facilitate the resolution
of any disputes;
- updating you with operational news and information
about our Sites and services e.g. to notify you about changes to
our software products, Sites, website disruptions or security updates;
- carrying
out technical analysis to determine how to improve the Sites and
services we provide;
- monitoring activity on the Sites, e.g. to
identify potential fraudulent activity and to ensure compliance
with the user terms that apply to the Sites;
- managing our relationship
with you, e.g. by responding to your comments or queries submitted
to us on the Sites or asking for your feedback or whether you want
to participate in a survey;
- managing our legal and operational
affairs (including, managing risks relating to content and fraud
matters);
- training Halley Elise staff about how to best serve our
user community;
- improving our products and services.
- providing
general administrative and performance functions and activities;
- processing your job application to
Halley Elise
- Where you
give us consent:
- providing you with marketing information about
products and services which we feel may interest you;
- and customizing
our services and websites, like advertising that appear on the Site
– where this involves the use of cookies or similar technologies
– in order to provide a more personalized experience.
- For purposes
which are required by law.
- For the purpose of responding to requests
by government, a court of law, or law enforcement authorities conducting
an investigation.
6. When we disclose your personal information
We will disclose personal information to the following recipients:
- companies that are in the Halley Elise group which are located in the US;
- authors of any items or services made available
to you, so they can facilitate support and license validation, who maybe
located in any of the countries our products are available in;
- subcontractors
and service providers who assist us in connection with the ways we use
personal information (as set out above), in particular: website hosting
and technical support service providers which are located in Australia,
Germany, Greece, Mexico, Netherlands, UK and the US; marketing and analytics services
which are located in the US; security and fraud prevention services
which are located in the US; subscription management services which
are located in the US; payment processing services which are located
in the US and your country of origin; identification verification services located
in the US; and operational support services which are located in
US. Noting that our subcontractors and services providers may also transfer
and access such information from other countries in which they have
operations.
- our professional advisers (lawyers, accountants, financial
advisers etc.) which are located in USA;
- regulators
and government authorities in connection with our compliance procedures
and obligations;
- a purchaser or prospective purchaser of all or part
of our assets or our business, and their professional advisers, in connection
with the purchase;
- a third party to respond to requests relating
to a criminal investigation or alleged or suspected illegal activity;
- a third party, in order to enforce or defend our rights, or to address
financial or reputational risks;
- a rights holder in relation to an
allegation of intellectual property infringement or any other infringement;
and
- other recipients where we are authorized or required by law to
do so.
7. Where we transfer and/or store your personal information
We are based in the USA so your data will be processed in the USA.
Some of the recipients we have described in section 6 above,
and to whom we disclose your personal information, are based in
Countries and Territories outside of the USA. We do this on the basis of your consent to this policy. In
order to protect your information, we take care where possible to work
with subcontractors and service providers who we believe maintain an
acceptable standard of data security compliance.
8. How we keep your personal information secure
Our storage of both our information and
your personal information on secure servers are managed
by us and our service providers, and occasionally hard copy files that
are kept in a secure location in the USA. Personal
information that we store or transmit is protected by security and access
controls, including username and password authentication, multi-factor
authentication, and data encryption where appropriate.
9. How you can access your personal information
You can access some of the personal information that we collect about
you by logging in to your account where that feature is available to
you. You also have the right to make a
request to access other personal information we hold about you (if
it exists) and to
request corrections of any errors in that data. You can also close the
account you have with us for any of our Sites at any time where
there is such an account. To make an
access or correction request, contact our privacy champion using the
contact details at the end of this policy.
10. Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed
to one of our e-mail lists or have indicated that you are interested
in receiving offers or information from us), we send you marketing communications
by email about products and services that we feel may be of interest
to you. You can ‘opt-out’ of such communications if you would prefer
not to receive them in the future by using the “unsubscribe” facility
provided in the communication itself.
- You also have choices about
cookies, as described below. By modifying your browser preferences,
you have the choice to accept all cookies, to be notified when a cookie
is set, or to reject all cookies. If you choose to reject cookies some
parts of our Sites may not work properly in your case.
- We do not and will not sell, rent, lease
your personal information to any third parties.
11. Cookies (not the kind with chocolate chips!) and web analytics
- For more information about how we may use cookies, web beacons and similar
technologies see our cookie policy
here and for more general information
on cookies, see http://www.allaboutcookies.org.
- When you visit our
Sites, there’s certain information that’s recorded which is generally
anonymous information and does not reveal your identity. If you’re logged
into your account some of this information could be associated with
your account. We’re talking about the following kinds of details:
- your IP address or proxy server IP address’;
- the domain name you
requested;
- the name of your internet service provider is sometimes
captured depending on the configuration of your ISP connection;
- the
date and time of your visit to the website;
- the length of your session;
- the pages which you have accessed;
- the number of times you access
our site within any month;
- the file URL you look at and information
relating to it;
- the website which referred you to our Sites; and
- the operating system which your computer uses.
- Occasionally, we maywill
use third party advertising companies to serve ads based on prior visits
to our Sites. For example, if you visit our Sites, you may later see
an add for our products and services when you visit a different Site.
Read more about your options in our cookie policy.
12. Information about appropriate materials by
age group
Our websites are suitable for all ages.
13. Information you make public or give to others
If you make your personal information available to other people,
we can’t control or accept responsibility for the way they will use
or manage that data. There are lots of ways that you can find yourself
providing information to other people or companies, like when you post a public message
on a forum thread, share information via social media, or make contact
with another user (such as a third party) whether via our websites
or directly via email. Before making your information publicly available
or giving your information to anyone else, think carefully. If giving
information to another user via our Sites, ask them how they will handle
your information. If you’re sharing information via another website,
check the privacy policy for that site to understand its information
management practices as this privacy policy will not apply.
14. How long we keep your personal information
We retain your personal information for as
long as is necessary to provide the services to you and others, and
to comply with our legal obligations. If you no longer want us to
use your personal information or to provide you with the Halley
Elise services, you can request that we
erase your personal information and close your Halley Elise account
if such information exists. Please
note that if you request the erasure of your personal information we
will retain information from deleted accounts as necessary for our legitimate
business interests, to comply with the law, prevent fraud, collect fees,
resolve disputes, troubleshoot problems, assist with investigations,
enforce the terms of service and take other actions permitted by law.
The information we retain will be handled in accordance with this Privacy
Policy.
15. When we need to update this policy
- We will need to change this policy from time to time in order to
make sure it stays up to date with the latest legal requirements and
any changes to our privacy management practices.
- When we do change
the policy, we’ll make notify you about such changes, where
required. A copy of the latest version of this policy will always be
available on this page.
16. How you can contact us
If you have any questions about our privacy practices or the way
in which we have been managing your personal information, please contact
our privacy advocate in writing by using our
Contact Page.
17. If you’re a user or visitor in the European Economic
Area these rights also apply to you:
For the purposes of applicable EU data protection law (including
the General Data Protection Regulation 2016/679 (the “GDPR”), we are
a ‘data controller’ of your personal information.
18. How you can access your personal information
- You are also entitled to ask us to port your personal information,
if it exists
(i.e. to transfer in a structured, commonly used and machine-readable
format, to you), to erase it, or restrict its processing. You also have
rights to object to some processing that is based on our legitimate
interests, such as profiling that we may perform for the purposes of direct
marketing, and, where we have asked for your consent to process your
data, to withdraw this consent as more fully described below.
- These
rights are limited in some situations – for example, we can demonstrate
that we have a legal requirement to process your personal information.
In some instances, this means that we may retain some data even if you
withdraw your consent.
Where we require your personal information
to comply with legal or contractual obligations, then provision of such
data is mandatory: if such data is not provided, then we will not be
able to manage our contractual relationship with you, or to meet obligations
placed on us. In all other cases, provision of requested personal information
is optional.
- If you have unresolved concerns you also have the right
to complain to data protection authorities. The relevant data protection
authority will be the data protection authority of the country:
- of your habitual residence;
- of your place of work; or
- in
which you consider the alleged infringement has occurred.
Halley Elise Privacy Policy v2, effective date May 25, 2018
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