DeepHow Privacy Policy

Last modified: April 25, 2022

Introduction

DeepHow, Inc. ("DeepHow" or "we" or “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes: 

  • The types of information we may collect or that you may provide when you download and register with, access or use, or transact with the DeepHow application or associated website any associated content, material, or functionality contained on the DeepHow application, all interactive features, applications, widgets, blogs, social networks and social network pages, and other online or wireless offerings that post a link to or otherwise is covered by this Privacy Policy, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the DeepHow application (collectively, the “App”). The App is owned, developed and managed by DeepHow. 
  • Our practices for collecting, using, maintaining, processing, accessing, storing, protecting and disclosing that information.
  • Your rights under applicable law.

Information We Collect and How We Collect It

The below chart summarizes our collection, use, and disclosure of personal information:

Types of Personal Information Collected

Source of the Personal Information

Purpose for Collection and Use

Information Disclosed for a Business or Commercial Purpose? (Yes/No)

Categories of Third Parties (Which Do Not Include Service Providers) with whom the Personal Information may be Shared under certain circumstances.

Identifiers (e.g., name, e-mail, employee ID, image, voice, video, and persistent identifiers that we may assign)

Information that you provide directly to us through the App; from business partners; and from our service providers that support the App’s operations.

Operate the App and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights; Evaluate performance through data analytics.

Yes

Business partners who deliver product and service offerings, and financial institutions.

Demographic information

Information that you provide directly to us through the App; from business partners; and from our service providers that support the App’s operations.

Operate the App and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights; Evaluate performance through data analytics.

 

Yes

Business partners who deliver product and service offerings and financial institutions.

Geolocation information

Information that you provide directly to us through the App; from business partners; and from our service providers that support the App’s operations.

Operate the App and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights; Evaluate performance through data analytics.

 

Yes

Business partners who deliver product and service offerings and financial institutions.

Browsing activity, device information, and Usage Details

Web tracking technology such as browser cookies, flash cookies, and web beacons and information about your collection on the App.

App functionality, customization, and security.

 

Advertising and marketing.

Yes

Third party web tracking providers.

 

 

Video and Audio Data.

When you subscribe to or use DeepHow’s video- or audio-based Services, you are enabling us, and certain of our third-party service providers, to record, store, view and process video and/or audio recordings from your device or video equipment. This may include capturing and sending you portions of this data through our services or analyzing the data to identify and translate speech data or performing other functions. We may process information from your monitoring equipment so that we can send you alerts.

Data protection and privacy laws in your jurisdiction may impose certain responsibilities on you and your use of video recording equipment and other devices with recording capabilities. You (not DeepHow) are responsible for ensuring that you comply with any applicable laws. For example, you may need to display a notice that alerts employees, customers, subcontractors, and other third parties that they may be photographed or recorded and that the photographs or recordings may be shared with other parties. DeepHow takes absolutely no responsibility for your compliance with these laws.

Other Information Collection Technologies.

The technologies we use for automatic information collection may include:

  • Cookies. A cookie is a small file placed on your smartphone or browser. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting, you may be unable to access certain parts of our App. Please refer to our for further information.
  • Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit DeepHow, for example, to count users who have visited those pages and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).

Third-party Information Collection

When you use the App, certain third parties may use automatic information collection technologies to collect information about you or your device. Those third parties may have their own privacy practices and policies. These third parties may include but are not limited to:

  • Advertisers, ad networks and ad servers.
  • Analytics (including, but not limited to, marketing analytics) and digital platform management companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.

You may find a complete list of third parties with whom we may share your information at _____. Those third parties include, in part, the following, which each provide certain additional rights and protections as detailed below.

HubSpot

This website uses the CRM-System “HubSpot“, provided by HubSpot, Inc. HubSpot is a company from the USA with Headquarters in (Cambridge, MA) 25 First St., 2nd floor Cambridge, Massachusetts 02141, USA) and with a branch office in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Telephone: +353 1 5187500, for our online marketing activities.

Hubspot is an integrated software solution that we use to cover different aspects of our online marketing. This includes, among others: marketing reporting (e.g., traffic sources, accesses, etc. …), contact management (e.g., user segmentation & CRM) and blog.

All information collected by us is subject to this data privacy policy and collected on the basis of our legitimate interests (exclusively for optimizing our marketing measures and improving the quality of our website.) based on Art. 6 para. 1 lit. of GDPR.

For this purpose, we have concluded a data processing agreement with HubSpot, Inc. in which HubSpot commits itself to process user data only in accordance with our instructions and compliance with the EU data protection standard.

For more information about Hubspot´s privacy policy, please visit: https://legal.hubspot.com/privacy-policy.

If you generally do not want HubSpot to collect your data, you can prevent cookies from being saved at any time by changing your browser settings accordingly.

Google Analytics Remarketing

Our websites use the features of Google Analytics Remarketing combined with the cross-device capabilities of Google AdWords and DoubleClick. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

This feature makes it possible to link target audiences for promotional marketing created with Google Analytics Remarketing to the cross-device capabilities of Google AdWords and Google DoubleClick. This allows advertising to be displayed based on your personal interests, identified based on your previous usage and surfing behavior on one device (e.g. your mobile phone), on other devices (such as a tablet or computer).

Once you have given your consent, Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that signs in to your Google Account can use the same personalized promotional messaging.

To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.

You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account; follow this link: https://www.google.com/settings/ads/onweb/ .

The aggregation of the data collected in your Google Account data is based solely on your consent, which you may give or withdraw from Google per Art. 6 (1) (a) General Data Protection Regulation. For data collection operations not merged into your Google Account (for example, because you do not have a Google Account or have objected to the merge), the collection of data is based on Art. 6 (1) (f) General Data Protection Regulation. The website operator has a legitimate interest in analyzing anonymous user behavior for promotional purposes.

For more information and the Google Privacy Policy, go to: https://www.google.com/policies/technologies/ads/ .

Other Disclosures of Your Information

In addition to the disclosures described above, we may disclose personal information that we collect or you provide:

  • To our affiliates, group companies, holding companies, located within and outside the US.
  • To a buyer or other successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of DeepHow Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our App users is among the assets transferred.
  • To comply with any court order, investigation, law or legal process, including, without limitation, to respond to any government or regulatory request.

The App will also allow you to intentionally interact with third parties, such as those whose businesses, products, or services are reviewed, advertised, or made available through the App.

We do not necessarily control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Children under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16, we will delete that information to the best of our ability. Please be aware that we may not be able to fully delete certain user information if a user’s account remains open. If you believe we might have any information from or about a child under 16, please contact us at the e-mail address provided to you below.

Do Not Track

We treat the information of everyone who comes to our App in accordance with this Privacy Policy. We do not monitor or respond to any “Do Not Track” setting that may be available through certain browsers. 

Information Security

We have implemented measures designed to secure your personal information against accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. 

If you receive a suspicious email on our behalf, we suggest you do not reply to it and do not open any attachments, click on links contained in the e-mail or provide any information in response to it. You can report suspected fraud involving us by sending an e-mail to _ support@deephow.com. Please include the word "phishing" in the subject line of your e-mail and provide as much information as possible about the fraudulent activity or message. We do not send e-mails requesting a user for payment information, username or passwords.

If you identify a vulnerability, please contact us to make a responsible disclosure at the following address: support@deephow.com.

Online Account Management

If you elected to subscribe to any online services provided via the App, including, without limitation, the ability to access any password-protected areas of the App, you will be required to submit personal information for the purpose of verifying your identity and your authority to manage the account (“Access Credential Information”). This Access Credential Information will be used exclusively by DeepHow, our agents, suppliers and third-party service providers for internal use and to respond to your service requests.

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time and may amend it at any time to incorporate additional terms specific to additional features, applications, opportunities, or services that we may make available on or through the App. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy.

You should review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the App signifies your continuing consent to this Privacy Policy.

The most recent version of the Privacy Policy is reflected by the effective date specified in this Privacy Policy. The version of this Privacy Policy posted at https://storage.googleapis.com/deephow-public/policies/Deephow-App-Privacy-Policy.pdf on each respective date you use the App shall be the Privacy Policy applicable to your access and use of the App on that date. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you used the App.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: _ +1 (510) 283-8197.

Special Notice to Residents of California – “Your California Privacy Rights”

If you are a California resident and a “consumer” as defined under the California Consumer Privacy Act, including the California Privacy Rights Act and any successor legislation and associated regulations (collectively, the “CCPA”), then the CCPA may provide you with specific rights regarding your personal information.

You have the right to request that businesses subject to the CCPA disclose certain information to you about their collection and use of your personal information over the past 12 months. In addition, you have the right to ask such businesses to delete personal information collected for you, subject to certain exceptions. If you choose to exercise your rights, you also have the right not to be discriminated against and will not be charged different prices or provided different quality of services.

DeepHow may not delete some or all requested personal information as allowed or required by applicable law. Moreover, please be aware that we may not be able to fully delete certain user information if the user’s account remains active. We do not sell personal information to third parties.

You may request to receive details about how we collect, use, and share your personal information. Specifically, you may request to receive the specific pieces of personal information that we have collected about you. 

You may also request to receive:

  • the categories of personal information that we have collected about you, 
  • the categories of personal information that we have disclosed for a business purpose,
  • the categories of sources from which we collected the personal information,
  • our purposes for collecting that personal information, and
  • the categories of parties with whom we share your personal information.

We do allow third parties to collect personal information through our Services and share personal information with third parties for the business purposes described in this Privacy Policy.

You can exercise your applicable CCPA rights by contacting us at support@deephow.com or at +1 (510) 283-8197.

Please note that the CCPA requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We may need more information when we receive your request before taking further action in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification. 

 

Special Notice to Residents of Mainland China

This Special Notice to Residents of Mainland China sets forth certain of DeepHow’s obligations and compliance measures under personal information Protection Law of the People's Republic of China (“PIPL”), including with respect to “personal information” under PIPL. To the extent DeepHow handles any personal information subject to PIPL, DeepHow will handle such personal information in accordance with PIPL and any other applicable privacy related Chinese rules and regulations incorporated in PIPL by reference.

Legal Bases for Handling Personal Information

DeepHow will handle personal information in accordance with law, when it is necessary, with justified reason, in good faith, and pursuant to the principles of openness and transparency. To the extent you voluntarily provide us with your personal information, we will handle such information for the purposes for which it was provided to DeepHow as set forth in the DeepHow Privacy Policy. For example, if you submit feedback about our Services, we may use that information to improve our Services. You may withdraw your consent at any time in the manner prescribed in this Privacy Policy; we will use commercially reasonable efforts to provide you with any portions of the Services that are functional in the absence of any information for which you choose to revoke consent to processing.

Where legally required (and where no other legal basis for handling exists), we will obtain your consent before handling your personal information. For example, if we want to handle your sensitive personal information, or to handle your personal information for a new purpose for which no other legal basis for handling exists, we will obtain your consent including separate consent or written consent as required by PIPL and related administrative regulations.

If we handle your personal information beyond the scope of this Privacy Policy, we will separately explain the purpose, method, and scope of such handling to you and obtain any additional consents as required by PIPL.

DeepHow may handle your personal information without your consent, under any of the following circumstances:

  • Where it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with PIPL.
  • Where it is necessary for the performance of statutory duties or statutory obligations.
  • Where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person.
  • Where it is necessary to handle the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the provisions of PIPL.
  • Other circumstances stipulated by laws and administrative regulations.

How We Share Your Personal Information

DeepHow will only share your personal information if we have obtained your separate consent as required by PIPL or in circumstances where your consent is not required according to laws and regulations.

DeepHow will provide you with the name and contact information of specific personal information handlers (as defined under PIPL), purpose and method of handling, and type of personal information related to you, before your personal information is shared as required by PIPL. For example, if you choose to enable the use of cookies or other tracking technologies, your information will be processed by the entities described in this Privacy Policy under Third-party Information Collection.

Where DeepHow needs to share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event, notice will be provided of the name and contact information of the recipient.

Cross-Border Transfers of Personal Information

In general, we handle personal information of residents of mainland China within China. However, in certain circumstances, personal information may be provided to our parent companies, subsidiaries and/or affiliates including those established outside the territory of the People's Republic of China as necessary for our global business purposes. We may, in the future, transfer your personal information to personal information handlers and entrusted persons (e.g., service providers) located outside the territory of the People's Republic of China. If we do, any such personal information handlers will be listed here.

We will take necessary measures required by law including entering into standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us and ensuring the foreign receiving party provides adequate protection for the personal information under applicable laws. We will separately obtain your consent and provide detailed information about the cross-border transfer of your personal information, as required by PIPL.

Your Privacy Rights

Under PIPL, you may have the following rights under certain circumstances:

  • the right to be informed regarding the handling of your personal information.
  • the right to request access or obtain a copy of your personal information.
  • the right to request deletion of your personal information.
  • the right to transfer your personal information to another personal information handler.
  • the right to make certain decisions on whether and how DeepHow handles your personal information.
  • the right to withdraw your consent at any time, as to any handling based on such consent. Certain of our Services need personal information to function; and your withdrawal of consent will not affect earlier handling based on your consent.

You can exercise the above rights by contacting us as explained in the Contact Us section below. We will not be able to respond to your request if your request occurs under the following circumstances:

  • conflicts with our responsibilities under applicable laws or regulations.
  • impacts national security or defense.
  • impedes public security, health, or other such interests.
  • relates to criminal justice process, court proceedings, or other such.
  • the request is made for an unlawful or improper purpose.
  • as necessary to protect life, property, or other important legal rights and interests.
  • endangers trade secrets.

Contact Us

Please contact us with any questions at support@deephow.com.

 

Special Notice to Residents of the European Union and Certain Other Global Jurisdictions

If you are a natural person who is a resident of the European Union, then the following Special Notice to Residents of the European Union and Certain Other Global Jurisdictions applies to you.

Similarly, if you are a natural person who is a resident of the following jurisdictions, then the following Special Notice to Residents of the European Union and Certain Other Global Jurisdictions, or certain portions thereof, may apply to you:

  • Liechtenstein;
  • Norway;
  • Iceland;
  • United Kingdom;
  • Switzerland;
  • Hong Kong;
  • Canada;
  • Brazil; or
  • other such jurisdictions which provide individual access and correction or deletion rights or certain other rights with respect to personal information.

Scope

This Privacy Policy applies to our privacy practices for your use of (i) this website and any mobile sites or applications operated by DeepHow (the "User Interfaces") and (ii) any combination of DeepHow's products and services purchased or accessed via any User Interface (the "Services"), and all personal data we directly receive or collect from you in the course of doing business.

 

Data Collection and Use

Data You Provide to Us – If you are an individual user of DeepHow or an owner, agent, or employee of a corporate user, you may provide us with personal data when you register with DeepHow, engage with customer support or marketing, and transact business with DeepHow.

Further, you may provide us with personal data when you set up your account with DeepHow and use DeepHow User Interfaces or Services.

We may use this information for our business operations, to communicate with you or your employer (as applicable), to comply with the law, and to protect the security and integrity of the User Interfaces and Services.

When using the User Interfaces, you may provide us with personal data including, but not limited to, your name, home or business address, phone number, email address, location, or zip code.

When using our Services, you or your employer may provide us with certain additional information (e.g., business description, business size, business location, account information, and device settings) in order to help us personalize your Services. DeepHow may also receive personal data that you have provided to our partners to enable DeepHow to provide our Services.

On behalf of you or your employer, DeepHow may process information regarding your use of the DeepHow Services. We receive this type of information from your devices that are monitored by DeepHow and your computer or other electronic device through which you may access, browse, download, receive, or otherwise use the DeepHow User Interfaces or Services (each a "Personal Device"), and we may also receive and collect such information from third parties.

DeepHow will process all personal data received by employers via contractual arrangements and may use compiled aggregate statistics about the User Interfaces and Services to improve our Services.

 

Data We Collect Automatically – When you use the User Interfaces or access DeepHow Services using your Personal Device, certain information may be collected by automated means, such as cookies. Further information about DeepHow’s use of cookies can be found in DeepHow’s Cookie Statement.

 

Legal Basis for Processing Personal Data

We will only collect and process personal data about you where we have a legal basis. Legal bases include consent (where you have given consent), contract (where processing is necessary for entering into or the performance of a contract with you), compliance with a legal obligation, and "legitimate interests."

Where we process personal data based on consent, we will ask for your unambiguous consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit. We process your personal data based on legitimate interests in order to:

  • Protect you, us, or others from security threats by enhancing the security of our network and information systems;
  • Identify and prevent fraud;
  • Comply with applicable laws and industry regulations;
  • Enable or administer our business, such as for invoicing Employers and maintenance of User Interfaces; and
  • Improve our User Interfaces and Services by enabling us to enhance, modify, or personalize them for your benefit.

 

Data Sharing

DeepHow will not disclose your personal data to any other entity except:

  • as is necessary to provide the DeepHow User Interfaces and Services to you;
  • to your employer or the company through which you subscribed to our Services;
  • when you have opted in to share the information;
  • to third party suppliers, subcontractors or business partners who work or perform services on our behalf and are only permitted to use the minimum amount of information necessary to assist in providing the Services;
  • as necessary in connection with other lawful business purposes; and
  • as otherwise necessary when required or permitted by law.

In addition, we may disclose your personal data when the personal data has been converted to a form that cannot be used to identify you. It may also be necessary for us to disclose your personal data in case of a merger or combination with, or acquisition of a portion of our business by, another company or entity, in which case personal data collected by DeepHow would be expected to be one of the transferred business assets.

 

International Data Transfers

Our servers and offices are located around the world, so your personal data will be transferred to, stored, or processed in many international jurisdictions. We rely on legally provided mechanisms to lawfully transfer personal data across borders, as approved by the relevant supervisory authorities.

 

Exercising Your Rights

You may view, update, or delete certain personal data at any time by contacting us at the contact details set forth below. If you access this site on behalf of your employer, you should also contact your employer directly to make changes to its records.

You may be able to exercise the following rights:

  • You may be able to ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Object to, or Limit or Restrict, Use of Data. You may be able to ask us to stop using all or some of your personal data (e.g., if there is no legal right to keep using it) or to limit use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Take Your Data. You may be able to ask for a copy of your personal data provided in a machine-readable form.

If we have collected and processed your personal data with your consent, then 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 data conducted in reliance on lawful processing grounds other than consent.

We do not make use of automated decision-making. As defined under current data protection laws, automated decisions are defined as decisions about individuals that are based solely on the automated (i.e., no human involvement) processing of data and that produce legal effects or that significantly affect the individuals involved.

You have the right to register a complaint with a data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA, the UK and Switzerland are available at https://edpb.europa.eu/about-edpb/board/members_en).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

 

Retention Period

We retain the personal data that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you requested or to comply with an applicable legal requirement).

 

Third Party Websites

For your convenience, some hyperlinks may be posted on the DeepHow website that link to other websites not under DeepHow's control. DeepHow is not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that DeepHow does not own or control. DeepHow does not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. DeepHow encourages you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website linked to the DeepHow website, even if you reached that site through the DeepHow User Interfaces, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website's privacy policies to understand how personal data that is collected about you is used and protected.

 

Contact Information

You can contact our data protection officer (DPO) at ­­­­­­­support@deephow.com