Privacy Policy of Hyra
Hyra collects some Personal Data from its Users.
Owner and Data Controller
Sam Easton t/a Hyra - 71-75 Shelton Street, Covent Garden, WC2H 9JQ, United Kingdom
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that Hyra collects, by itself or through third parties, there are: Usage Data; Trackers; firstname; last name; email address; User ID; physical address; contact info; billing address; gender; date of birth; phone number;username; password; company name; country; state; prefix ; language; payment info; purchase history; Data communicated whileusing the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or byspecific explanation texts displayed prior to the Data collection.Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Hyra.Unless specified otherwise, all Data requested by Hyra is mandatory and failure to provide this Data may make it impossible forHyra to provide its services. In cases where Hyra specifically states that some Data is not mandatory, Users are free not tocommunicate this Data without consequences to the availability or the functioning of the Service.Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.Any use of Cookies – or of other tracking tools — by Hyra or by the owners of third-party services used by Hyra serves thepurpose of providing the Service required by the User, in addition to any other purposes described in the present document and inthe Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Hyra.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthoriseddestruction of the Data.The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modesstrictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types ofpersons in charge, involved with the operation of Hyra (administration, sales, marketing, legal, system administration) or externalparties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies)appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner atany time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing arelocated.Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Tofind out more about the place of processing of such transferred Data, Users can check the section containing details about theprocessing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond toenforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulentactivity, as well as the following: Traffic optimisation and distribution, Analytics, Handling payments, Registration and
authentication provided directly by Hyra, Interaction with support and feedback platforms, Hosting and backend infrastructureand Managing contacts and sending messages.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed informationon the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of Userbehaviour.
ProfitWell Metrics (200 OK LLC)
ProfitWell Metrics is an analytics service provided by 200 OK LLC, that allows the Owner to analyse revenue and Users’(commercial) activity on Hyra.
Personal Data processed: email address; first name; last name; physical address; User ID.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
a Sale in California
PostHog
PostHog is the all-in-one platform for building better products - with product analytics, feature flags, session recordings, a/btesting, heatmaps, and more
This processing constitutes:
Handling payments
Unless otherwise specified, Hyra processes any payments by credit card, bank transfer or other means via external paymentservice providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personalinformation directly to such payment service providers. Hyra isn't involved in the collection and processing of such information:instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfullycompleted.
Paddle
Paddle is a payment management service provided by Paddle.com Inc, Paddle.com Market Limited or by Paddle PaymentsLimited, depending on how the Owner manages the Data processing, which allows Users to make online payments. Paddle alsoallows Hyra to measure the performance of their checkout and subscriptions model, and to re-engage and message Users whohave shown signs of abandonment.
Personal Data processed: billing address; contact info; email address; User ID.
Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
Retain by ProfitWell (200 OK LLC)
Retain by ProfitWell is a payment service that follows up with Users when payments fail, provided by 200 OK LLC.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
Stripe
Stripe is a payment service provided by Stripe Inc, Stripe Payments Ltd or by Stripe New Zealand Limited, depending on howthe Owner manages the Data processing.
Personal Data processed: billing address; email address; first name; last name; payment info; purchase history.
Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; New Zealand – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Hyra to run and be distributed as well as to provide aready-made infrastructure to run specific features or parts of Hyra.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult todetermine the actual location where the Personal Data are stored.
OpenAI API (OpenAI, L.L.C.)
The OpenAI API provided by OpenAI, L.L.C. is a service that helps the Owner to automate tasks through its AI engine.
Personal Data processed: Data communicated while using the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Hyra.If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users donot actively use the service.
Not Just Tickets Limited
When you contact us for Customer Support via email or via other means, we make use of software by NOT JUST TICKETSLIMITED to help us provide the best possible experience.Your email, account username, query and account usage data includingIP addresses may be shared with NOT JUST TICKETS LIMITED to help our agents provide the best possible service.Personal data processed: email, username, usage dataPlace of processing: United KingdomCategory of information collected according to CCPA: identifiers
Canny
Information is stored in Canny to aid with collecting customer feedback.Personal data processed: email, usage dataPlace of processing: United StatesCategory of personal data collected according to CCPA: identifiers
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information tocommunicate with the User. These services may also collect data concerning the date and time when the message was viewed bythe User, as well as when the User interacted with it, such as by clicking on links included in the message.
Postmark (Wildbit LLC)
Postmark is an email address management and message sending service provided by Wildbit LLC.
Personal Data processed: company name; country; email address; first name; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information.
Registration and authentication provided directly by Hyra
By registering or authenticating, Users allow Hyra to identify them and give them access to dedicated services. The Personal Datais collected and stored for registration or identification purposes only. The Data collected are only those necessary for theprovision of the service requested by the Users.
Direct registration (Hyra)
The User registers by filling out the registration form and providing the Personal Data directly to Hyra.
Personal Data processed: company name; country; date of birth; email address; first name; gender; language; last name;password; phone number; physical address; prefix ; state; User ID; username.
Category of Personal Information collected according to CCPA: identifiers; commercial information; inferred information.
Traffic optimisation and distribution
This type of service allows Hyra to distribute their content using servers located across different countries and to optimise theirperformance.Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function isto filter communications between Hyra and the User's browser.Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that maycontain Personal Information of the User are transferred.
Bunny CDN (BunnyWay d.o.o.)
Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.
Personal Data processed: Usage Data.
Place of processing: Slovenia – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
a Sale in California
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.The way Cloudflare is integrated means that it filters all the traffic through Hyra, i.e., communication between Hyra and theUser's browser, while also allowing analytical data from Hyra to be collected.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
a Sale in California
Further information about the processing of Personal Data
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or anyother means of payment envisaged. The kind of Data collected by Hyra depends on the payment system used.
Cookie Policy
Hyra uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligationsthereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in theOwner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall beretained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfillsuch purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within therelevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing,as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer periodwhenever required to fulfil a legal obligation or upon order of an authority.Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right torectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given theirconsent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing iscarried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regardingcertain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated orcorrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Ownerwill not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from theOwner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in astructured, commonly used and machine readable format and, if technically feasible, to have it transmitted to anothercontroller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to anyinternational organisation governed by public international law or set up by two or more countries, such as the UN, and about thesecurity measures taken by the Owner to safeguard their Data.If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with theOwner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or forthe purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a groundrelated to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object tothat processing at any time, free of charge and without providing any justification. Where the User objects to processingfor direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether theOwner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of thisdocument.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Suchrequests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Userswith the information required by law. Any rectification or erasure of Personal Data or restriction of processing will becommunicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this provesimpossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflictinginformation contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personaldata, if any, the retention period and further information about Personal Data can be found in the section titled “Detailedinformation on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of PersonalData be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties beprohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Suchrequests are free of charge and will be answered by the Owner as early as possible, providing Users with the information requiredby law.
Further information for Users in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and isprovided by the entity running Hyra and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this sectionreferred to collectively as “we”, “us”, “our”).This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "LeiGeral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflictinginformation contained in the privacy policy.This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legalinstruments;
studies conducted by research entities, preferably carried out on anonymised personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information onthe processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing ofPersonal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or ofinformation that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymised information) toanother service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless oneor more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or withconsumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, whichaffect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspectsof your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details providedin this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons thatprevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your
personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are inthe position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specifywhether you’d like your personal information to be delivered in electronic or printed form.You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in asimplified fashion, or if you need a complete disclosure instead.In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the originof your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposesof the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sureto immediately communicate your request to other parties with whom we have shared your personal information in order toenable such third parties to also comply with your request – except in cases where such communication is proven impossible orinvolves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecutionbodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorised by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract orpreliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitrationprocedures.
Further information for Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and isprovided by the business running Hyra and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of thissection referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”),who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada,Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected ordisclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyonewho is not a California resident to get a general idea of what types of Personal Information are collected.
Internet or other electronic network activity information
Identifiers
Commercial information
Inferences drawn from other personal information
ℹ️You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of yoursensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacyrights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing ofPersonal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatiblewith the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Hyra.
For example, you directly provide your Personal Information when you submit requests via any forms on Hyra. You also providePersonal Information indirectly when you navigate Hyra, as Personal Information about you is automatically observed andcollected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with thefunctioning of Hyra and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, youhave:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether ornot we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccuratePersonal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of yourPersonal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable andusable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercisingyour privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which isnecessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note thatcertain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive PersonalInformation is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, NewHampshire, New Jersey, Nebraska and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado,Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtheranceof decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information.Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection andprocessing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested bythe consumer.
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptionsoutlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive PersonalInformation is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided inthis document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify youridentity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an accountwith us to submit your request. We will use any Personal Information collected from you in connection with the verification ofyour request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary forpurposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also usethe privacy choices link provided on Hyra.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacycontrol, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in africtionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should weneed more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you maythen contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in allother cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on therequest. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal actionarising from improper use of Hyra or the related Services.The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Hyra may provide the User with additional and contextualinformation concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Hyra and any third-party services may collect files that record interaction with Hyra(System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please seethe contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possiblywithin Hyra and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available tothe Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consentfrom the User, where required.
Definitions and legal references
Personal Data (or Data) / Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number —allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information consideredsensitive according to the applicable privacy law.
Usage Data
Information collected automatically through Hyra (or third-party services employed in Hyra), which can include: the IP addressesor domain names of the computers utilised by the Users who use Hyra, the URI addresses (Uniform Resource Identifier), the timeof the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical codeindicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser andthe operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within theApplication) and the details about the path followed within the Application with special reference to the sequence of pagesvisited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Hyra who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, asdescribed in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposesand means of the processing of Personal Data, including the security measures concerning the operation and use of Hyra. TheData Controller, unless otherwise specified, is the Owner of Hyra.
Hyra (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Hyra as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuableconsideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with aservice provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale ofyour Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwisecommunicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a thirdparty for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactionsbetween a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money isexchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a serviceprovider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharingof your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on PersonalInformation obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predictsuch consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states tothe European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Hyra, if not stated otherwise within this document.
Latest update: 8 November 2024