Privacy Notice on Processing of Personal Data pursuant to Articles 13 and 14 of the GDPR

HUDI considers the protection of its users’ data to be of fundamental importance and guarantees that the processing of their personal data is carried out in full compliance with the principles, safeguards and rights recognised by Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “Regulation” or “GDPR”) and the further applicable rules on the protection of personal data.

This Privacy Notice provides you with information regarding the collection, use, and disclosure of your personal information in connection with HUDI Website (including its mobile application if used by you) as defined in HUDI User Terms of Services in accordance with Articles 13 and 14 of the GDPR.

  1. Data Controller

The Data Controller is Human Data Income Ltd, based in London (UK), 207 Regent St, Mayfair W1B 4NE (from now on also “HUDI” or “we” “us”).

If you have general questions about your account or how to contact customer service for assistance, please contact us at info@humandataincome.com. For questions specifically about this Privacy Policy, or our use of your personal information, please contact us at privacy@humandataincome.com.

Please note that when you contact us to assist you, for your safety and ours we may need to verify your identity before fulfilling your request.

  1. Data Source

- Information you provide to us: information such as name, surname, e-mail address or any other information given freely by you while using the functionalities of HUDI Website .

- Information collected automatically as a result of your use of HUDIWebsite: we collect information about your use of HUDI Website. This information may include device and software characteristics, connection information, URL addresses, IP address, browser information, standard web server log information.

- Information collected from third parties: third-party companies that provide (or have provided) services to you or other online platforms with which you have interacted may share the personal data they hold about you (e.g., data about your online purchases) with HUDI Website in order to enrich your profile (“Data Provider”). Data Providers are responsible for personal data they obtained, published, or shared through HUDI Website and for identifying a lawful basis for the transfer of such data with HUDI. We also collect information from companies that provide services to you or with which you interact while using HUDI Website (e.g., payment service providers, social media platforms, e-commerce solutions, etc.).

  1. Purposes of processing and legal basis

We process personal data for the purposes and on the legal bases indicated below.

 

Purposes

Categories of Personal data

Legal Basis

1.      

To manage the technical functioning of HUDI Website

Data for this purpose are collected automatically and may include device and software characteristics, connection information, URL addresses, IP address, browser information, standard web server log information

To perform a contract with you (article 6 (1)(b) of the GDPR)

2.      

To enable you to create an account and authenticate your access to your account, to allow you to create, update and enrich your profile

·     Name, surname, contact details (e-mail, phone number), date of birth, country, password (as required to complete your registration)

·     your profile picture

·     any further information included by you in your profile section, concerning your career, education level, employment status, marital and parental status, gender, lifestyle and demographic data. This information may be kept in its identifiable form, or in an aggregated form (so that individuals cannot be identified)

 

To perform a contract with you (article 6 (1)(b) of the GDPR)

3.      

To enable you to create an account and authenticate your access to your account, to allow you to create, update and enrich your profile that third party partners may use to create and export an audience for their own direct marketing and research purposes (“DataBuyers”)

·     Name, surname, contact details (e-mail, phone number), date of birth, country, password (as required to complete your registration)

·     your profile picture

·     any further information included by you in your profile section, concerning your career, education level, employment status, marital and parental status, gender, lifestyle and demographic data. This information may be kept in its identifiable form, or in an aggregated form (so that individuals cannot be identified)

·     any further information shared by Data Providers concerning your purchases and actions taken by you within the Data Providers’ platform

Your consent (article 6 (1)(a) of the GDPR)

4.      

To connect your account on other third-party services (e.g., your social media account) to HUDI Website (if you choose to do so by using the specific functionalities made available within your reserved area)

Information that such other services may transfer to HUDI depending on their own policy.

Such information may include your name, profile picture, language, and friend list.

To learn more about the personal data that the third parties share with us, please refer to their privacy policies and terms of service.

Your consent (article 6 (1)(a) of the GDPR)

5.      

To transfer the personal data you or Data Providers have shared with HUDI Website to Data Buyers for their own direct marketing and research purposes. As legitimate owner of the data, you will receive royalties from every data-related transaction as described in the HUDI User Terms of Services

The personal data in your profile section (except for your profile picture that will only be visible to you). Data Buyers may create and populate audiences by performing a query with parameters provided by you. Please note that these data will be transferred in a pseudonymized form as described in the HUDI Website

Your consent (article 6 (1)(a) of the GDPR)

6.      

To enable you to complete quests within the bounty area (e.g., inviting friends to join HUDI Website, following HUDI Instagram and Twitter profile, joining HUDI Telegram channel, carrying out online purchases, etc.) and to reward you on the basis of the quests that you have completed

The actions that you have performed in order to complete a given quest (including actions you have carried out on third party platforms) and the necessary information that we need in order verify whether you have completed the quest (e.g., your Instagram and Twitter username, Telegram code). To learn more about how the third parties with which you interact in completing the quest process your personal data, please refer to the privacy policies of their services

To perform a contract with you (article 6 (1)(b) of the GDPR)

7.      

To carry out direct marketing activities by HUDI, such as sending advertising material and communications with informative and/or promotional content in relation to services or products provided and/or promoted by HUDI

Identification and contact information

Your consent (article 6 (1)(a) of the GDPR). Please note that consent is not required when we use your email address in order to send you information about similar products and services. In this case, we process your personal data for the purposes of pursuing our legitimate interests (so-called soft spam)

8.      

To process and respond to customer support communications and requests for information you may raise with us

Identification and contact information, any other personal data that you provide to us when making your request and any other personal data that we may need to acquire in order to fulfil your requests

To perform a contract with you (Article 6 (1)(b) of the GDPR)

9.      

To improve our products and services (for example, by conducting user surveys and research activities to provide you with new features, and to assess user satisfaction; processing of statistical data in order to understand how HUDI Website is used)

Statistical data on how HUDI Website is used, your answers to our surveys and research activities, technical performance data, crash data/performance data/other diagnostic data

For the purposes of pursuing our legitimate interests, where it is not overridden by your data protection interests or fundamental rights and freedoms (Article 6 (1)(f) of the GDPR)

10.   

To secure our systems, prevent payment fraud, help us protect the security of your account and enforce our terms

Data collected automatically, including device and software characteristics, connection information, URL addresses, IP address, browser information, standard web server log information, user identification and contact information

For the purposes of pursuing our legitimate interests, where it is not overridden by your interests or fundamental rights and freedoms (Article 6 (1)(f) of the GDPR)

11.   

To comply with our legal obligations, including requests from public authorities

Any information which may be required by the law or by public authorities

For compliance with a legal obligation to which we are subject (Article 6 (1)(c) of the GDPR)

12.   

To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions)

Any information which may be necessary in order to fulfil this purpose

For the purposes of pursuing our legitimate interests, where it is not overridden by your interests or fundamental rights and freedoms (Article 6 (1)(f) of the GDPR)


  1. Your choices with regard to the processing of your personal data

Your personal data is necessary and mandatory for the aforementioned purposes. Any refusal to provide them would prevent us from pursuing our contractual relationship with you and from providing the requested services.

Where we rely on your consent for the purposes indicated above, your provision of personal data is optional, and you have the right to withdraw your consent at any time without affecting your contractual relationship with us. If you choose to grant us access to the data in your account on another service (see section 3 above), you can remove our access to that other service by using the specific functionalities made available in your reserved area.

Where we rely on our legitimate interest, you may, at any time, object to the processing of your personal data as described in section 7.

  1. Data Storage and Data Retention

Personal data will be processed by both automated and non-automated means and are stored at our service provider’s servers. Unless otherwise specified, personal data shall not be transferred or processed outside the U.K. or the European Economic Area or other country not providing an adequate level of protection in this field. In this case, the data transfer may take place on the basis of Standard Contractual Clauses adopted by the European Commission or other appropriate safeguards (according to article 46 GDPR) or derogations according to article 49 GDPR, if not otherwise specified case-by-case.

Your personal data will be kept as long as necessary to fulfill the purposes indicated above, without prejudice to the cases in which the retention for a longer period is necessary to comply with the applicable legislation or with requests received by competent authorities. The personal data that we process on the basis of your consent are retained until your consent is withdrawn where there is no other legal ground for processing.

  1. Sharing Your Personal Data

We will share or disclose your personal data to the following categories of recipients:

  • Suppliers carrying out activities that are related or instrumental to our business and operational activities as data processors appointed in writing or acting as autonomous data controllers (such as suppliers of infrastructure and IT services, consultancy services, accounting, administrative, legal services)
  • With your consent, Data Buyers for their own direct marketing and research purposes.
  • If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers and may be included in the asset that is transferred to another company.
  • Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

In order to obtain an updated list of the subjects who may become aware of your personal data, please contact us by email at privacy@humandataincome.com.

  1. Information and privacy rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and processed your personal information with your consent, you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise your data protection rights you may:

  • enter your “Profile” section where you will have the ability to access and update the data you have included in order to enrich your profile and, if we have collected and processed your personal information with your consent, withdraw your consent at any time by unchecking the specific box;
  • contact us at any time by email at: privacy@humandataincome.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You also have the right to lodge a complaint with a Data Protection Authority about our collection and use of your personal information, in particular in the Member State in which you habitually live or work or in the place where the alleged violation took place.

  1. Changes to this Privacy Notice

This policy may be subject to modifications also as a consequence of any regulatory changes. In this case, we will inform you of such modifications with the means of communication available. Should these changes relate to activities carried out on the basis of consent, we will require a new consent before proceeding to any further processing. We also kindly invite you to periodically review this Privacy Notice for the latest information on our privacy practices.