MINTAL
PRIVACY NOTICE
Effective Date: [May 25, 2021]
This Privacy Notice explains how HiClub,
Inc. (“HiClub”, “we”, “us” or “our”)
collects, uses, discloses, and otherwise processes personal information (as
defined below) in connection with our website (the “Site”) and the
related content, platform, services, and other functionality offered on or
through the online services (collectively, the “Services”). It does not address our privacy practices relating to job
applicants, employees and other personnel.
Please see the Mintal Sleep Privacy Notice and Mintal Tracker Privacy Notice for more
information about our privacy practices in relation to the Mintal mobile
applications.
What is Personal information?
When we use the term “personal information” in this Privacy
Notice, we mean information that identifies, relates to, describes, is reasonably
capable of being associated with, or could reasonably be linked, directly or
indirectly, to an individual. It does not include aggregated or deidentified information
that is maintained in a form that is not reasonably capable of being associated
with or linked to an individual.
Our Collection of Personal Information
Sometimes we collect personal information automatically when an
individual interacts with our Services and sometimes we collect personal information
directly from an individual. At times, we may collect personal information
about an individual from other sources and third parties, even before our first
direct interaction.
Personal Information Collected from Site
Visitors and Account Holders
We collect the following personal information submitted to us by
visitors to our Site and by individuals through our product demonstrations:
- Contact Information,
including name, email address, country/region, phone number and communication
preferences.
-
Inquiry
Information, including information
provided in custom messages sent through the forms or contact information
provided on our Site.
-
Survey Information, including
information provided in any questions submitted through surveys, or content of
any testimonials.
Personal Information Automatically
Collected
As is true of most digital platforms, we and our third-party providers
may also collect personal information from an individual’s device, browsing
actions and site usage patterns automatically when visiting or interacting with
our Site, which may include log data (such as internet protocol (IP)
address, operating system, browser type, browser id, the URL entered and the
referring page/campaign, date/time of visit, the time spent on our Site and any
errors that may occur during the visit to our Site), analytics data
(such as the electronic path taken to our Site, through our Site and when
exiting our Site, as well as usage and activity on our Site) and location
data (such as general geographic location based on the log data we or our
third-party providers collect).
We and our third-party providers may use (i) cookies or small data
files that are stored on an individual’s computer and (ii) other, related
technologies, such as web beacons, pixels, embedded scripts,
location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this
personal information. For more information about our cookie practices, please
see our Cookie
Notice.
Personal Information from Third
Parties
We also obtain personal information from third parties; which we
often combine with personal information we collect either automatically or
directly from an individual.
We may receive the same categories of personal information as
described above from the following third parties:
- Social Media: When an
individual interacts with our Services through various social media networks,
such as when someone “Likes” us on Facebook or follows us or shares our content
on Google, Facebook, Twitter, or other social networks, we may receive some
information about individuals that they permit the social network to share with
third parties. The data we receive is dependent upon an individual’s privacy
settings with the social network. Individuals should always review and, if
necessary, adjust their privacy settings on third-party websites and social
media networks and services before sharing information and/or linking or
connecting them to other services.
- Service Providers: Our service
providers that perform services solely on our behalf, such as survey and
marketing providers, collect personal information and often share some or all
of this information with us.
- Information
Providers: We may from time to time obtain information from third-party
information providers to correct or supplement personal information we collect.
For example, we may obtain updated contact information from third-party
information providers to reconnect with an individual.
- Publicly Available Sources: We collect personal
information about individuals that we do not otherwise have, such as contact
information, employment-related information, and interest-in-services
information, from publicly available sources. We may combine this information
with the information we collect from an individual directly. We use this
information to contact individuals, to send advertising or promotional
materials or to personalize our Services and to better understand the
demographics of the individuals with whom we interact.
Our Use of Personal Information
We use personal information
we collect to:
- Fulfill or meet the reason the information was provided, such as
to fulfill our contractual obligations, to deliver the Services you have
requested and to process transactions;
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email, text message,
social media and/or telephone calls;
- Request individuals to complete surveys about our organization,
organizations we partner with, and Services;
- Market our Services to individuals, including through email,
direct mail, phone or text message;
- Administer, improve and personalize our Services, including by
recognizing an individual and remembering their information when they return to
our Site;
- Facilitate user benefits and services, including customer support
through our command center services;
- Identify and analyze how individuals use our Site and Services;
- Conduct research and analytics on our user base and our Services;
- Improve and customize our Services to address the needs and
interests of our user base and other individuals we interact with;
- Test, enhance, update and monitor the Services, or diagnose or
fix technology problems;
- Help maintain the safety, security and integrity of our property
and Services, technology assets and business;
- Defend, protect or enforce our rights or applicable contracts
and agreements;
- Prevent, investigate or provide notice of fraud or unlawful or criminal
activity; and
- Comply with legal obligations.
Where an individual chooses to contact us, we may need
additional information to fulfill the request or respond to inquiries. We may
provide additional privacy disclosures where the scope of the inquiry/request
and/or personal information we require fall outside the scope of this Privacy
Notice. In that case, the additional privacy disclosures will govern how we may
process the information provided at that time.
Our Disclosure of Personal
Information
We disclose personal information in the following ways:
-
Affiliates. We may share personal information
with other companies owned or controlled by HiClub,
and other companies owned by or under common ownership as HiClub,
which also includes our subsidiaries (i.e., any organization we own or control)
or our ultimate holding company (i.e., any organization that owns or controls
us) and any subsidiaries it owns, particularly when we collaborate in providing
the Services.
-
Survey Providers: We share personal information with third parties who assist us
in delivering our survey offerings and processing the responses.
-
Marketing Providers: We coordinate and share personal information with our marketing
providers in order to communicate with individuals
about the Services we make available.
-
Customer Service and Communication
Providers: We share personal information with
third parties who assist us in providing our customer services and facilitating
our communications with individuals that submit inquiries.
-
Other Service Providers: In addition to the third parties identified above, we engage
other third-party service providers that perform business or operational
services for us or on our behalf, such as website hosting, infrastructure
provisioning, IT services, analytics services, and administrative services.
-
Other Business As Needed To Provide
Services: We may share personal information
with third parties that an individual engages with through our Services or as
needed to fulfill a request or transaction.
- Business Transaction or Reorganization: We may take part in or be involved
with a corporate business transaction, such as a merger, acquisition, joint
venture, or financing or sale of company assets. We may disclose personal information
to a third party during negotiation of, in connection with or as an asset in
such a corporate business transaction. Personal information may also be
disclosed in the event of insolvency, bankruptcy or receivership.
-
Legal Obligations and Rights: We may disclose personal information to third parties, such as
legal advisors and law enforcement:
o in connection with the establishment, exercise, or defense of
legal claims;
o to comply with laws or to respond to lawful requests and legal
process;
o to protect our rights and property and the rights and property
of others, including to enforce our agreements and policies;
o to detect, suppress, or prevent fraud;
o to protect the health and safety of us and others; or
o as otherwise required by applicable law.
-
Otherwise With Consent or Direction: We may disclose personal information about an individual to
certain other third parties or publicly with their consent or direction. For
example, with an individual’s consent or direction we may post their
testimonial on our Site or service-related publications.
If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes
permits a Nevada resident to opt out of future sales of certain covered
information that a website operator has collected or will collect about the resident.
Although we do not currently sell covered information, please contact us at [support@mintalworld.com] to submit such a request.
Children’s Personal Information
Our Services are not directed to, and
we do not intend to, or knowingly, collect or solicit personal information from
children under the age of 13. If an individual is under the age of 13, they
should not use our Services or otherwise provide us with any personal information
either directly or by other means. If a child under the age of 13 has provided personal
information to us, we encourage the child’s parent or guardian to contact us to
request that we remove the personal information from our systems. If we learn
that any personal information we collect has been provided by a child under the
age of 13, we will promptly delete that personal information.
Links to Third-Party Websites or Services
Our Site and Services may include links to third-party websites,
plug-ins and applications. Except where we post, link to or expressly adopt or
refer to this Privacy Notice, this Privacy Notice does not apply to, and we are
not responsible for, any personal information practices of third-party websites
and online services or the practices of other third parties. To learn about the
personal information practices of third parties, please visit their respective
privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we
make changes to this Privacy Notice, we will change the date at the beginning
of this Privacy Notice. If we make material changes to this Privacy Notice, we
will notify individuals by email to their registered email address, by
prominent posting on this Site or our Services, or through other appropriate
communication channels. All changes shall be effective from the date of
publication unless otherwise provided.
Contact Us
If you have any questions
or requests in connection with this Privacy Notice or other privacy-related
matters, please send an email to [support@mintalworld.com].