Hopin Privacy Policy

Table of Contents

• Important information and who we are
• The data we collect about you
• How is your personal data collected
• How we use your personal data
• Disclosures of your personal data
• International transfers
• Data security
• Data retention
• Your legal rights
• Contacting Hopin
• Glossary
• California Supplemental Privacy Notice

1. Important information and who we are

Purpose of this privacy policy

‍Hopin’s purpose in establishing this privacy policy is to give you information about how Hopin collects and processes your personal data through your use of the Hopin Services, including any data you may provide through the Hopin platform.  If you do not agree with the terms, do not access or use the Hopin Services, websites or any other aspect of Hopin’s business.

This privacy policy applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy policy, such as the StreamYard Privacy Policy, Streamable Privacy Policy, or Jamm Privacy Policy. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller/Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information.  Hopin and Event hosts are independent controllers of certain types of your personal data, such as your registration data (like name and email) and attendance data (like Event name, date and time of Event, and Event sessions attended).  Event hosts are the controller, and Hopin is the processor, of Event data, such as information and materials submitted to or during an Event.

Changes to our privacy policy and your duty to inform us of changes to your personal data

We keep our privacy policy under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this privacy policy on our website. If we make changes that materially alter your privacy rights, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law.  Accordingly, please keep your account information, including email address, updated.    

Your access to and use of third party websites or services accessible through the Hopin Services

The Hopin Services include links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a particular Event.

Third party web sites and applications.

Clicking on links to third party websites, content or applications may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.

Where you access or use third party services provided by an Event organiser, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the privacy policy of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data which includes your image and first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. This may also include other audio-visual content which you appear in as you contribute to or interact with an Event.
• Contact Data which includes your home address, email address and telephone numbers.
• Transaction Data which includes details about payments you have made and other details of products and services you have accessed or used through the Hopin Services. We do not store card details on our server. Credit and debit card payments are processed by Stripe on their secure payments server and all card details are fully encrypted and stored by them.
• Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting and location, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the Hopin Services.
• Profile Data which includes your username and password, purchases or orders made by you, your interests, volunteer record, preferences, feedback and survey responses.
• Usage Data which includes information about how you use our Services, as well as third-party platforms which you have linked to your use of our Services. Usage data includes metadata which provides additional context about the way the Services are being used such as length of visit, page views, navigation paths, and page interaction information (such as scrolling, clicks, mouse-overs, and mouse tracking) as well as information about the timing, frequency and pattern of use.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• User Generated Content which includes data you submit as part of an Event or as a result of your interactions with the Hopin Services such as Event materials, videos, chats, and messaging.  Please note, the host of the Event is the controller of this data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to the Hopin Services).

Children

We do not knowingly collect or process personal data from children, and no part of our Services is directed to them.  A “child” is a person (a) under 13 years old (for residents outside of the EEA, except for the Republic of Korea); (b) under 16 years old or such age needed to consent to the processing of personal data in their country of residence (for residents of the EEA); or (c) under 14 years old (for residents of the Republic of Korea). If you are a parent or guardian and you learn that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child without verification of parental consent, we take steps to remove that information from our systems.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and other Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: (a) create an account with us; (b) subscribe (or are subscribed) to our services; (c) interact in an Event; (d) request marketing to be sent to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.
• Automated technologies or interactions. As you interact with the Hopin Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We also collect Usage Data via automated technologies as a result of your interaction with the Hopin Services. We collect this personal data by using cookies, server logs and other similar technologies.
• Third-Parties.  Depending on your use of the Hopin Services, we may collect data about you from third-party service providers which you have linked to your use of our Services (including social media account and single-sign-on services), your employer, your administrator, the host of organizer of an Event you register for or attend, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.

4. How we use your personal data

The legal bases for using your information as set out in this Privacy Policy are as follows:

• Where we need to perform the contract we are about to enter into or have entered into with you (e.g. to provide you with access to the functionality of the Hopin Services).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we have your consent.
• Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Recommendations from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you. Subject to applicable law, we may send you information that we think may be of interest to you.

Third-party marketing

We will get your express opt-in consent before we share your email with any third party for their marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time. You can contact us at the email below or, where applicable, use the instructions located at the bottom of your email. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.

Cookies

We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Hopin Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.  Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Advertising and Analytics Services Provided by Others

We may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Hopin Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Hopin and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Hopin Services and other websites and better understand your online activity. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• External Third Parties as set out in the Glossary.
• Third parties in connection with, or during negotiations of, any merger, sale or transfer of company assets, financing or acquisition of all or a portion of our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Where third parties provide Events or support the provision of Services made available to you, these third parties may receive certain personal data about you. Whilst we are not in control of these third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.

To help constantly improve and tailor the service we provide to you, we may use aggregated information so that we can administer and improve our services, analyze trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymized format.

Your disclosure to third parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, different rules may apply to their use or disclosure of the information you provide to them. Hopin does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

6. International transfers

We may transfer your personal data outside your country of residence, including the European Economic Area (EEA), in our performance of services.

Whenever we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we only transfer data to them under the scope of a Data Processing Agreement which incorporates Standard Contractual Clauses, or another legally applicable data transfer mechanism, which require them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. That said, no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you provide personal data in connection with the submission of Event Content, we may process sensitive personal data as part of the Hopin Services.

This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Object to processing of your personal data.  We will assess your request and determine whether we have any legal or other justification for continued processing.  
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us as set forth in the Contacting Hopin section below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month or within the timeline provided by applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  Contacting Hopin

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:

• Full name and address of legal entity: Hopin Limited
• Email address: [email protected]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You may also direct your complaint or concern to your applicable data protection authority. We would, however, appreciate the chance to address your concerns before you approach the ICO or another data protection authority.

11. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to Hopin, that is the performance of our agreement with you to make the Hopin Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third party partners.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External Third Parties

• Service providers acting as processors who provide our IT and system administration services.
• Providers of our cloud services such as AWS and Google.
• Stripe – for the purposes of payment transaction management. https://stripe.com/gb/privacy
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Our third-party partners and affiliates whom you engage with through the use of the Hopin Services in order to facilitate the provision of the Hopin Services.
• Hosts or Event organizers whose Events you attend through your use of the Hopin Services.

12.  California Supplemental Privacy Notice

In addition to the rights described in our Privacy Notice above, California law grants California residents certain rights as set forth below:

• Notice: You have a right to be provided with a notice at minimum of the categories of personal information collected and the purposes for which it is used at or before the points of collection.  
• Right to non-discrimination: The California Consumer Protection Act (“CCPA”), prohibits discrimination against California residents for exercising their rights under the CCPA, such as by denying or providing a different level or quality of goods or services, or charging different prices or imposing penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Submitting Requests

Requests to exercise your rights may be submitted by emailing us at [email protected].  Please be prepared to provide your first and last name and email address that matches information we currently have on file.  Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.

California Shine the Light Law

Under California’s Shine the Light law, California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any, and as defined under the law) that we have shared with third parties during the preceding calendar year for their own direct marketing purposes. Such requests may be made once per calendar year by emailing us at [email protected] In your request, you must include the statement “Shine the Light Request,” provide your first and last name, email address and residential address, and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.