Privacy Policy

August 1, 2022

Introduction

Hoonab.online (“Hoonab.online” and also referred to as “our”, “us” and “we”) understands the importance of user privacy and takes privacy matters very seriously. By visiting Hoonab.online’s existing and future website(s), application(s), bots and/or domain name(s) at https://Hoonab.online, https://t.me/hoonabkubot including but not limited to its sub-domains and a mobile-optimized version (collectively, the “Site”), or otherwise accessing any linked pages, features, content, products, services, mobile properties and mobile device applications for iPhone, iPad, Android or other smartphone or tablet device (each, a “Service“) owned or operated by Hoonab.online, you acknowledge that you have read and understood the terms in this Privacy Policy (“Policy”). Please note that this Policy applies where we are processing personal information on our own behalf. If you have been given access to our Services by another company or organization (e.g., your employer), or are otherwise using our Services on behalf of another company or organization, then we may be processing your information on behalf of that company or organization. In those circumstances, your access and use of the Services is subject to the agreement we have entered with that company or organization (the “Customer Agreement”), and the organization that entered into the Customer Agreement (“Customer”) controls and is responsible for the processing of your information. This Policy does not apply to information that we process on behalf of our customers and if you have any questions about specific settings and privacy practices, please contact the administrator for your Hoonab.online account. In addition, this Privacy Policy does not apply to any third-party applications or software that integrate with the Services (“Third Party Services”), or any other third-party products, services, or businesses. This Privacy Policy describes the following information collected by Hoonab.online:

Information We Collect

We collect a variety of personally identifiable information (“PII”) about users of our Services in order to ensure a quality user experience. “PII” means information that we can use to identify or contact you, such as your name, address, phone number, Telegram username, Telegram ID, Instagram username email address, birthdate, birth time, birth location or other information.

You are responsible for ensuring the accuracy of all PII that you submit to us. Inaccurate information may affect your experience when using the Services and/or our ability to contact you as described in this Policy. PII collected by us is protected as personal data under applicable data protection law. PII does not include “Aggregated Information” which is information or data we collect where individual user identities have been removed, including metadata on your use of the Services, IP address logs, device, and location information. Aggregated Information helps us understand trends, user needs, and other information to provide improved Services and may be used by us for any purpose. We may also collect other non-personally identifiable information about your use and interaction with our Services. “Non-personally identifiable information” means information where we cannot determine the identity of a natural person. Non-personally identifiable information is not treated as PII unless we combine it with or link it to PII that you give to us. If you do not wish to disclose any required information, then your sole remedies shall be to close this web tab, delete your Hoonab.online account, and/or exit the Site.

How We Collect Information

Information You Give Us

We collect information that you give to us when you register or use our Services. When you register for a Hoonab.online user account (“Account“) on the website, Telegram bot or mobile application, you will be assigned a unique account identifier which will be associated with any information you give to us under your Account. You may also give us information to allow us to contact you or use certain features available through our Services without signing up for an Account, such as when you fill out a request form, provide feedback, email us, or engage in communications with our team. While you may use some functionality of the Services and/or Site without registering for an Account, most functionality and services will require that you register for an Account.

Customer Support Information

Your emails, calls, and other correspondence to and from us may be recorded for various purposes including monitoring customer service quality or compliance, checking the accuracy of the information you provide us, preventing fraud, or providing training for our staff or customer service representatives. Any information obtained from you through Customer support will be treated in accordance with the provisions of this Policy.

Information We Collect Automatically

Even if you do not provide information to us, we automatically collect certain information about your use and interaction with our Site and/or Services. For example, when you visit our website, our systems automatically maintain web logs to record data about all visitors who use our website and store this information in our database. These weblogs may contain information about you including the following: IP address, type(s) of operating system you use, type of device you use, date and time you visited the website, your activity, and/or referring websites. We use your log information to troubleshoot problems, gather demographic information, customize your experience when accessing our Site, Services, and other business purposes.

Information Collected From Other Sources

We may receive information about you from outside sources, such as commercially available demographic or marketing information, and add or combine it with your information to provide better service to you and inform you of services or other information that may be of interest to you. Our Site offers you the functionality of using your social media credentials (e.g. Facebook, Google, Yandex, Hoonab.online, etc.) to use single-sign-on to enter our Site, and in that manner, we may also collect certain information from you as you log on. We will not collect more information from you when using your social media credentials beyond the information such third parties disclose to us.

How We Use Information

We will use your information to provide and maintain our Site and Services, to improve your user experience, and for the other purposes described in this Policy. Hoonab.online uses your information in furtherance of our legitimate interests in operating our Site, Services, and business. In particular, Hoonab.online uses your information to:

• Provide our services to you.

• Develop, research, process, safeguard, modify and improve our communications, the Site, and Services.

• Send correspondence to your e-mail address, Telegram messenger including sending password verification and retrieval links, billing, account management information, newsletters, answers to queries/suggestions, and other notices related to the Site and Services.

• Improve your user experience and provide you with customer support.

• Investigate and help prevent security issues, abuse, and breaches.

• As required by applicable law, legal process, or regulation.

We do not sell your private data.

With Whom We Share Information

Disclosure With Your Consent

Where we are processing your information on behalf of a Customer, the Customer determines their own policies and practices for the sharing and disclosure of your information, and Hoonab.online does not control how a Customer or any other third parties choose to share or disclose information. Where we are processing your information on our own behalf, we may disclose your information with your consent, which we may obtain in a number of ways, including:

• In writing;

• Verbally;

• Online, by clicking on a link or button;

• In other ways.

Our Services permit you to submit the information that may be displayed to other authorized users in the same or different Customer Account. The sharing and other controls applied to such information may be determined by you, other users, and/or an administrator of your Account.

Disclosure Without Your Consent

In general, we may disclose your information without your consent to disclosure when we reasonably believe disclosure is appropriate in order to:

• Comply with the law (e.g., lawful subpoena or court order);

• Cooperate with or report to law enforcement agencies in investigations that involve users who use our Service Offerings for activities that are or seem illegal or illegitimate activities;

• Enforce or apply agreements for our Service Offerings; or

• Protect our rights or property or that of our affiliates, including respective officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors (e.g., to address allegations about fraudulent or unlawful activity related to a Hoonab.online account).

• In connection with a merger, acquisition, public offering, sale of company assets, insolvency, bankruptcy, or receivership, subject to standard confidentiality requirements.

• To defend Hoonab.online and our affiliates, licensors, officers, agents, and representatives from legal claims and processes brought to us by third parties (including takedown notices);

• Use or disclose aggregated or de-identified data at our sole discretion.

We may share your information with third parties as necessary to provide Services to you or to support the technical operation and/or maintenance of our Services, including third-party applications that you may engage within the Services. We may also share information with our affiliates, agents, outside vendors, or service providers to perform functions on our behalf (such as cloud storage providers, analytics services, marketing, and advertising services, and external consultants and professional advisers). When a third party acts solely on our behalf and otherwise as applicable, we use reasonable commercial efforts to require that party to follow the privacy practices stated in this Policy or have complementary privacy protections to protect your information. We do not share your information with unaffiliated third parties except as permitted to do so in this Policy.

How We Protect Information

We use industry-standard protocols and technology to protect your registered user information and personal data in order to guard and encrypt data for transmission in a format that prevents data theft by unauthorized third parties, including internal reviews of our data collection, storage and processing practices, security measures, and physical security measures. However, please take into account that the Internet and email transmissions are not secure or error-free communication means. We also urge you to take additional steps on your own to safeguard and maintain the integrity of your information. For example, you should never share your Account or login information with other people and be sure to sign off when finished using a shared or public computer. We urge you to be aware that if you use or access our Services through a third-party computer network (e.g., internet café, library) or other potentially non-secure internet connection, such use is not recommended and is solely at your own risk. It is your responsibility to check beforehand on the privacy and/or security policy of your network prior to accessing the Services. We are not responsible for your handling, sharing, re-sharing, and/or distribution of your information except as set forth in the Policy.

What Choices and Rights Do You Have

Control Of Your Information

Customers will generally be able to edit, select or delete the amount and type of personal data they disclose to us when using our Site and services. This will be managed through your Account with us, the settings section of your account, the Site, and through the means mentioned in this Policy.

Your Privacy Rights

You may have certain rights in respect of your personal information under applicable data protection laws. Subject to any exemptions provided by law, this may include the right to:

• Rectify or update your information, when inaccurate or incomplete;

• Request deletion of your information or, in certain circumstances, restrict our processing of your information;

• Revoke your consent for the processing of your information.

As mentioned above, you are able to exercise some of these rights through your Account with us. Otherwise, if you wish to exercise your rights under applicable data protection laws please write to us using the details provided below and include, at a minimum, the following information: (i) your complete name, address, and/or email address, Telegram username in order for us to respond to your privacy request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the personal information with regard to which you seek to exercise any of your privacy rights. If you request rectification, please indicate the amendments to be made and attach documentation to back up your request.

We will handle all privacy requests in accordance with applicable data protection laws. Upon receipt of your privacy request, and after due review of its merit, we may then fulfill your request. If you ask us to delete your information, please note that we may not be able to delete all of your information from our databases but, if that is the case, we will mark such information as permanently inaccessible.

Cookies and Beacons

We (or our affiliates and authorized service providers) may place cookies and similar technologies on your computer or mobile device in order to track and collect data regarding your use of our Site and Services. Cookies are small text files that our Site transfers to you and that allow us to permit us to recognize you and obtain data such as how, when, and how long you browse pages on our Site. Either we or our affiliates and authorized service providers may also use ‘beacons’, which are small files, sometimes only a pixel in size, embedded onto the pages of our Site. Beacons are used to identify each of our pages in order to be analyzed by our system tools. You can always configure your browser to refuse cookies and beacons. For more information, please visit our Cookies Policy.

Your browser or device may include “Do Not Track” functionality. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to “Do Not Track” signals. However, you can opt-out from the use of cookies and beacons as explained above.

Third Party Services

Generally

Our Site and services may also implement hyperlinks to the websites of our commercial partners and other third parties. If you click on such links, you are choosing to visit such websites and will be redirected thereto. If you click on a third-party link, our Policy and Service terms are no longer applicable and your browsing is at your own risk. We are not responsible for the privacy and personal data practices used by such third parties (including any tools, cookies, information, or content contained thereinto), and we do not have control over the manner in which such third parties may collect, process, treat or use your personal data. You are strongly advised to check the privacy settings, policies, and/or notices applicable to such third-party sites and services prior to browsing or using such third-party websites and/or services.

In addition, any banner or ad that we may have on our Site does not constitute any endorsement of any third party thereof.

Financial data and information

We use third-party payment processing platforms. These platforms will request you to disclose sensitive personal data (e.g. credit card number, account username, and password) in order to complete purchases and operations related to our services. Such third-party payment processing platforms are governed by their own safety standards, policies, and terms of use. We shall not be liable for their operation, safety, or otherwise their functioning. We strongly advise our users to engage in online safety measures in order to protect their financial information, here on the Site and elsewhere. We will not collect or store any sensitive financial data of yours.

Advertising, opt-out

From time to time, we may use Google Analytics, Google Ads, Meta Pixel, and other tracking codes, along with other third party services (such as remarketing codes) in order to collect marketing analytics about the pages you browse on our Site or when you undertake specific actions through our services. Our advertising and analytics providers may also use cookies, codes, and other technologies to help us analyze our users’ patterns. For example, our advertising providers may show you Hoonab.online ads on third-party websites across the Internet, even after you leave our Site. Our third-party providers may also use cookies and beacons to track your Internet browsing in order to serve you ads based on what they or we believe to be of interest. Such information will be processed for purposes of evaluating your browsing activities and consumer preferences.

Regional and International Provisions

International Data Transfers

Hoonab.online headquarters and servers are located in Georgia, US and Russia. This means that your personal information may be accessed and processed by us in the Georgia, Russia or in the US and other countries where our affiliates, agents, partners, or third-party service providers operate. If you are accessing our Site from other regions, you ought to know that you are thereby transferring your personal data to Georgia, Russia, USA or to any other country in which we operate.

Data Transfers outside the EEA, Switzerland and UK

If you are located in the European Economic Area, Switzerland, or the United Kingdom (Europe), we take appropriate safeguards to ensure that your information remains protected in accordance with this Policy and applicable data protection laws when it is transferred and processed outside of Europe. This includes transferring your information to a country that the European Commission or UK authorities (as applicable) have determined provides an adequate level of protection for personal information, or by implementing standard contractual clauses with our customers, third-party service providers, and partners. We have also implemented certain additional safeguards to ensure your information remains protected, such as encrypting and pseudonymizing information (where possible) and implementing strict security and access controls.

Legal basis to process your information

If you are located in Europe, we need a lawful basis to collect, use and disclose your personal information. Our lawful basis will depend on the information concerned and the context in which it is processed. We may process your personal information in order to perform a contract with you (such as to create and maintain your account). In other circumstances, we may process your information where the processing is in our legitimate interests and those interests are not overridden by your rights and freedoms. For example, we rely on our legitimate to communicate with you about our Services and to personalize and improve our Services. Hoonab.online may also process your information in reliance on our legitimate interests for direct marketing purposes, provided that you have a right to object to Hoonab.online’s use of your information for this purpose at any time. Where required, we may also process your personal information where we have obtained your consent (for example, where we obtain your consent to send you promotional or marketing materials). Finally, we may need to process your information to comply with our legal obligations (such as to enforce our terms of use, exercise, establish or defend our legal rights, or share your information with a law enforcement body or regulatory agency where disclosure is required by law).

Age Restriction

By using our Services and/or browsing the Site, you hereby represent and warrant that (i) you are at least eighteen (18) years of age — or older — as of the date of first access to the Site; and, (ii) if you are a minor (which may differ depending on the jurisdiction where you reside), you are accessing the Site under the direct supervision of your parent or legal guardian.

Amendments

Hoonab.online may change this Policy from time to time as laws, regulations, industry standards, and/or our business evolves. We will post the changes to this page and encourage you to review our Policy periodically to stay informed. If you disagree with the changes to this Policy, you should deactivate your Account.

Contact

Email: [email protected]

Legal Address: Georgia, Tbilisi, Chugureti District, 38 Chitaia Street,
Office No. 1