HIPOLINK PLATFORM PRIVACY POLICY
Last updated: July 2, 2024
1. Who we are
1.1. We are CEBC B.V. located at Joop Geesinkweg 201, Office 9.12, 1114AB Amsterdam-Duivendrecht, the Netherlands
1.2. This Privacy Policy sets out how we collect and use your personal information when you visit our sites https://hipolink.net and https://hipolink.me (“Sites”) or use our online service “Hipolink” (“HIPOLINK Services”) offered by CEBC B.V. at https://hipolink.net and https://hipolink.me and the choices available to you in connection with our use of your personal information (“Privacy Policy”). The Sites and HIPOLINK Services are hereinafter collectively referred to as the “HIPOLINK Platform”. This Privacy Policy should be read alongside, and in addition to, our terms and conditions at https://hipolink.net/en/user-agreement and https://hipolink.me/agreements/user-agreement (“Terms”) and our Cookie Policy (accessible online at https://hipolink.net/en/cookie-policy and https://hipolink.me/agreements/cookie-policy). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
2. THIS PRIVACY POLICY
2.1. By making available the HIPOLINK Platform we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register and use the HIPOLINK Platform;
(b) provide true information about yourself to the extent necessary for use of the HIPOLINK Platform;
(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other HIPOLINK Platform users and internet users, be copied and disseminated by them;
(d) understand that some types of information transferred by you to other HIPOLINK Platform users cannot be deleted by you or us;
(e) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. INFORMATION WE COLLECT ABOUT YOU
3.1. In order to implement the agreement between you and us, and provide you with access to the use of the HIPOLINK Platform, we will improve, develop and implement new features to the HIPOLINK Platform, and enhance the available HIPOLINK Platform functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we may collect when you use the HIPOLINK Platform, why we collect and process it and the legal bases below.
| 3.3 | Information Collected | Purpose | Legal Basis |
| 1 | Data you provide for registering in HIPOLINK Platform: data obtained via third parties in case you log in through a third-party social network or authentication service (such as Google, Instagram, among others), including your social network nickname and email, your nickname that you create at the process of registering | We use this information in order to manage and administer HIPOLINK Platform provided to you. We use this data to enable us to fulfill our obligations to you as part of HIPOLINK Platform (e.g. in cases where you request restoration of your account). | Performance of our contract with you |
| 2 | Additional data you provide when you edit your profile page or on dedicated service profile page via including your name, surname, email, nickname, country. | We use this information in order to provide HIPOLINK Platform to you, to manage and administer HIPOLINK Platform and as additional information to verify your account to prevent abuse and infringements of your or other persons rights.We also use this information in order to provide you with updates and information on our and selected third parties products and HIPOLINK Platform we think you may be interested in. | Performance of our contract with you |
| 3 | Additional data received when you access HIPOLINK Platform, including information regarding technical interaction with HIPOLINK Platform such as your IP-address, time of registration on HIPOLINK Platform, time of your last visit of HIPOLINK Platform, device ids, country and language settings. | We use your data for internal review in order to constantly improve the content of HIPOLINK Platform and web pages, optimizing your user experience, to understand any errors you may encounter when using HIPOLINK Platform, to notify you of changes to HIPOLINK Platform and to personalise the use of our HIPOLINK Platform. | Legitimate Interests |
| 4 | Information that is automatically received at the time of access to HIPOLINK Platform with the use of cookies. | Please see our cookies policy, which sets out the types of cookies we use and what we use these cookies for. | Consent |
| 5 | Information that is created by you while using HIPOLINK Platform (including User Content). This information can be available to all viewers of the Creator Content where the User Content is placed | We use this information in order to manage and administer HIPOLINK Platform including providing our HIPOLINK Platform to you. | Legitimate interests |
| 6 | Information that is created by you while placing requests to our Services support. | We use this information in order to verify your identity and to fullfil your support request.We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. | Performance of our contract with you |
| 7 | Information that is received as the result of your using payment functionality on the Sites (e.g. first and last four digits of your card number that are needed for the option of matching these details with user’s id number). | We use this information in order to manage and administer the Sites including providing our HIPOLINK Platform to you.We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. | Performance of our contract with you |
| 8 | Data collected via third parties, in case you choose to provide such data from a third-party social network, authentication or verification services (such as Google, Instagram, among others), when you log in using such network and/or service or connect such network and/or service to our HIPOLINK Platform, including your social network ids (such as Google ID), device, browser, application or application store ids, such as, but not limited to, IMEI code, MAC address, Widevine and Firebase version ids, advertising ids, your phone number, nickname, email and friends list, subscribers list, channel name, channel description, channel URL, avatar or profile picture. | We use this information in order to manage and administer the HIPOLINK Platform provided to you and as additional information to verify your account to prevent abuse and infringements of your or other persons rights. | Performance of our contract with you. |
| 9 | Where necessary, a copy of your identity or another document containing your first name, surname, photograph, number of the principal identity document of you or your representative, payment details, and other additional data that you may provide us with, including through our Support Service.We may take additional verification steps, which we consider reasonable in order to verify your account. | We use this data in order to identify you, verify your account, and prevent abuse and infringement of your or other persons rights.For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us. | Legitimate interests |
| 10 | Anonymous, non-personalized (without reference to the personal data of visitors to the HIPOLINK Platform) data on visits to the Creators' Pages, the number of clicks on blocks on the Creators' Pages. | We use this information in order to provide HIPOLINK Platform, to obtain aggregate statistical information available for further use by the Creators using HIPOLINK Platform. | Legitimate interests |
3.4. Our legitimate interests include
(1) maintaining and administrating HIPOLINK Platform;
(2) providing HIPOLINK Platform to you;
(3) improving the content of HIPOLINK Platform and web pages;
(4) processing of the data that was manifestly made public by you
(5) ensuring your account is adequately protected; and
(6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.6. You may withdraw your consent for sending you marketing information by amending your privacy settings of your account. An option to unsubscribe will also be included in every email sent to you by us or our selected third party partners.
3.7. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on HIPOLINK Platform.Once you have provided this data it will be accessible by the users of the web-sites (including mobile versions) where this data is posted and it becomes difficult for us to remove this data.
3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer HIPOLINK Platform, you may not be able to access and use HIPOLINK Platform.
3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. DATA SHARING
4.1. Your nickname can be available to all viewers of your Creator Content in the Internet when you use HIPOLINK Platform. We take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information, you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.
4.2. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide HIPOLINK Platform to you or to administer HIPOLINK Platform, for example if you choose to share your data across other social media platforms.
4.3. CEBC B.V. and our other affiliated entities or our selected third party partners with our permission, using their own ad servers, can show advertisements to you.
4.4. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, you hereby consent that we may also transfer your personal information to a third party if we decide to transfer or sale of all or substantially all of our business to which this Privacy Policy relates to, whether by merger, sale of stock, sale of assets, or otherwise, if permitted by and done in accordance with applicable law, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, you hereby consent that in that case your personal data will be processed by our successor or assignee in accordance with this Privacy Policy.
5. PRIVACY SETTINGS
5.1. HIPOLINK Platform may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party HIPOLINK Platform and you should ensure you review the relevant third partys privacy statement which will govern your data privacy rights.
5.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the HIPOLINK Platform, obtain access to your information in accordance with the confidentiality level selected by you.
5.3. We bear no liability for the consequences of use of the information which, due to HIPOLINK Platform nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted in HIPOLINK Platform.
6. INTERNATIONAL TRANSFERS
6.1. We may transfer and maintain on our servers or databases some of your personal information in different countries outside the European Economic Area (EEA) including in CIS.
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
7. RETENTION PERIODS
7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2. You may delete your personal data by removing the data from your account or by sending us an email to support@hipolink.net.
7.3. We may remove your account, or the information you post as provided by the Terms.
8. YOUR RIGHTS
8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased if:
8.1.1. it is no longer required in relation to the purposes for which it was gathered or processed in another way;
8.1.2. you withdraw your consent concerning processing subject to consent;
8.1.3. you are justifiably opposed to the processing;
8.1.4. it has been subject to illicit processing; or
8.1.5. it is imposed by law.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
(i) For processing based upon your consent, the right withdraw that consent at any time.
(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.
8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on https://www.bloctel.gouv.fr.
8.3. If you would like to exercise these rights, please contact Support Service at support@hipolink.net or send your request to us, in writing to Joop Geesinkweg 201, Office 9.12, 1114AB Amsterdam-Duivendrecht, the Netherlands. We will aim to respond to you within period established by applicable law. We will need to verify your identity before we are able to disclose any personal data to you
9. Security Measures
9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9.2. Access to HIPOLINK Platform is authorized using by the relevant social network your login (e-mail address) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
10. Changes to this Policy
10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
11. Contact Us
11.1. If you have any questions, please send your inquiries to Service support at support@hipolink.net or in writing to Joop Geesinkweg 201, Office 9.12, 1114AB Amsterdam-Duivendrecht, the Netherlands. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within period established by applicable law.
11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
11.3. The e-mail address of our DPO is dpo@hipolink.net.
Only the English version of this document has legal effect. Any translations of this document to other languages are provided for your convenience only.
