PRIVACY NOTICE

Last updated November 20, 2022

This privacy notice for Hbrothers L.L.C. (doing business as Hbrothers L.L.C.) (“Hbrothers L.L.C.,” “we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

  • Download and use our mobile application (Clever Cleaner), or any other application of ours that links to this privacy notice.
  • Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

If you still have any questions or concerns, please contact us at info@hbro-studio.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find more details about these topics in the full sections below.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Hbrothers L.L.C. and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, support security and fraud prevention, and comply with the law.

We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information.

However, no electronic transmission over the internet or information storage technology can be guaranteed to be completely secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located, applicable privacy laws may grant you certain rights regarding your personal information.

How do you exercise your rights?

The easiest way to exercise your rights is by visiting the Hbrother website or contacting us directly.

We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we process your information?
  3. What legal bases do we rely on to process your information?
  4. When and with whom do we share your personal information?
  5. What is our stance on third-party websites?
  6. How long do we keep your information?
  7. How do we keep your information safe?
  8. What are your privacy rights?
  9. Controls for Do-Not-Track features
  10. Do California residents have specific privacy rights?
  11. Do we make updates to this notice?
  12. How can you contact us about this notice?
  13. How can you review, update, or delete the data we collect from you?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.

Sensitive Information

We do not process sensitive information.

Application Data

If you use our application or applications, we may collect the following information if you choose to provide us with access or permission:

  • Mobile Device Access: We may request access or permission to certain features on your mobile device, including your device’s camera, contacts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Push Notifications: We may request permission to send you push notifications regarding your account or certain features of the application. If you wish to opt out of these communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our applications, for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate. You must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol address and browser or device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services.

This information does not reveal your specific identity, such as your name or contact information, but may include device and usage information such as:

  • Your IP address
  • Browser and device characteristics
  • Operating system
  • Language preferences
  • Referring URLs
  • Device name
  • Country
  • Location
  • Information about how and when you use our Services
  • Other technical information

This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

The information we collect includes:

  • Log and Usage Data: Service-related diagnostic, usage, and performance information that our servers automatically collect when you access or use our Services and which we record in log files.
  • Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, information about your activity in the Services, timestamps associated with your usage, pages and files viewed, searches, features used, system activity, error reports, crash dumps, and hardware settings.
  • Device Data: Information about the computer, phone, tablet, or other device you use to access the Services.
  • Depending on the device used, this information may include your IP address or proxy server, device and application identification numbers, location, browser type, hardware model, internet service provider, mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, support security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate the delivery of services to the user: We may process your information to provide you with the requested service.
  • To save or protect an individual’s vital interests: We may process your information when necessary to save or protect an individual’s vital interests, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason, or legal basis, to do so under applicable law.

This may include processing information with your consent, to comply with laws, to provide Services, to enter into or fulfill contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely upon to process your personal information.

We may rely on the following legal bases:

  • Consent: We may process your information if you have given us permission to use your personal information for a specific purpose. You may withdraw your consent at any time.
  • Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or responding to your request before entering into a contract.
  • Legal Obligations: We may process your information when we believe it is necessary to comply with our legal obligations, cooperate with law enforcement or regulatory agencies, exercise or defend our legal rights, or disclose information as evidence in litigation.
  • Vital Interests: We may process your information when we believe it is necessary to protect your vital interests or those of another person, including situations involving potential threats to someone’s safety.

If you are located in Canada

We may process your information if you have given us specific permission, known as express consent, to use your personal information for a particular purpose.

We may also process your information where your permission can reasonably be inferred, known as implied consent.

You may withdraw your consent at any time.

In certain exceptional cases, applicable laws may permit us to process your information without your consent, including:

  • When collection is clearly in an individual’s interests and consent cannot be obtained in a timely manner.
  • For investigations and fraud detection or prevention.
  • For business transactions where certain conditions are met.
  • When the information is contained in a witness statement and collection is necessary to assess, process, or settle an insurance claim.
  • To identify injured, ill, or deceased persons and communicate with their next of kin.
  • When we have reasonable grounds to believe that an individual has been, is, or may become a victim of financial abuse.
  • When obtaining consent would reasonably be expected to compromise the availability or accuracy of information needed to investigate a breach of an agreement or a violation of Canadian federal or provincial laws.
  • When disclosure is required to comply with a subpoena, warrant, court order, or applicable court rules.
  • When information was produced by an individual during their employment, business, or professional activities and the collection is consistent with the purpose for which it was produced.
  • When collection is solely for journalistic, artistic, or literary purposes.
  • When the information is publicly available and specified by applicable regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and with certain third parties.

We may need to share your personal information in the following situations:

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations concerning, a merger, sale of company assets, financing, or acquisition of all or part of our business by another company.
  • Affiliates: We may share your information with our affiliates. In such cases, we will require those affiliates to honor this privacy notice. Affiliates include our parent company, subsidiaries, joint venture partners, and other companies that we control or that are under common control with us.
  • Offer Wall: Our applications may display a third-party-hosted “offer wall.” An offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in exchange for accepting and completing an advertising offer.

An offer wall may appear in our applications and may be displayed based on information such as your geographic area or demographic information.

When you click an offer wall, you will be taken to an external website operated by another party and will leave our application.

A unique identifier, such as your user ID, may be shared with the offer wall provider to prevent fraud and properly credit your account with the applicable reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of information you share with third parties that we link to, or that advertise on our Services, but are not affiliated with us.

The Services, including our offer wall, may link to third-party websites, online services, or mobile applications. They may also contain advertisements from unaffiliated third parties that link to other websites, services, or applications.

We do not make any guarantees regarding these third parties and will not be liable for any loss or damage caused by your use of their websites, services, or applications.

The inclusion of a link to a third-party website, service, or application does not imply our endorsement.

We cannot guarantee the safety or privacy of data you provide to third parties. Data collected by third parties is not covered by this privacy notice.

We are not responsible for the content, privacy practices, or security policies of third parties, including other websites, services, or applications linked to or from the Services.

You should review the policies of these third parties and contact them directly if you have questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes described in this privacy notice, unless a longer period is required by law.

We will keep your personal information only for as long as necessary for the purposes described in this privacy notice, unless a longer retention period is required or permitted by law, including for tax, accounting, or other legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it.

If deletion or anonymization is not immediately possible, for example because your personal information has been stored in backup archives, we will securely store the information and isolate it from further processing until deletion becomes possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the personal information we process.

However, no electronic transmission over the internet or information storage technology can be guaranteed to be completely secure.

We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmitting information to and from our Services is at your own risk.

You should only access the Services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In certain regions, including the European Economic Area, United Kingdom, and Canada, you have rights that provide greater access to and control over your personal information. You may review, change, or terminate your account at any time.

Depending on applicable data protection laws, your rights may include:

  • The right to request access to your personal information.
  • The right to obtain a copy of your personal information.
  • The right to request correction or deletion.
  • The right to restrict the processing of your personal information.
  • The right to data portability, where applicable.
  • The right to object to the processing of your personal information in certain circumstances.

You can exercise these rights by contacting us using the details provided in the “How Can You Contact Us About This Notice?” section below.

We will consider and act upon requests in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe that we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority.

Contact details for European data protection authorities are available on the European Commission website.

If you are located in Switzerland, contact details for the relevant data protection authorities are available on the Swiss Federal Data Protection and Information Commissioner’s website.

Withdrawing your consent

If we rely on your express or implied consent to process your personal information, you have the right to withdraw that consent at any time.

You may withdraw your consent by contacting us using the details provided below.

Withdrawing your consent will not affect the lawfulness of processing carried out before the withdrawal. Where permitted by applicable law, it will also not affect processing carried out based on lawful grounds other than consent.

If you have questions or comments about your privacy rights, email us at info@hbro-studio.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (“DNT”) feature or setting.

You can activate this feature to communicate your preference not to have information about your online browsing activities monitored and collected.

At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized.

We do not currently respond to DNT browser signals or other mechanisms that automatically communicate your choice not to be tracked online.

If a standard for online tracking is adopted that we are required to follow, we will explain that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. If you are a California resident, you have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to request and obtain from us, once per year and free of charge:

  • Information about the categories of personal information, if any, that we disclosed to third parties for direct marketing purposes.
  • The names and addresses of the third parties with which we shared personal information during the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing using the contact information below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post through the Services.

To request removal, contact us using the information below and include:

  • The email address associated with your account.
  • A statement confirming that you reside in California.

We will ensure that the data is no longer publicly displayed through the Services. However, the data may not be completely or comprehensively removed from all our systems, including backups.

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

  1. Every individual who is in the State of California for something other than a temporary or transitory purpose.
  2. Every individual domiciled in the State of California who is outside the state for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must comply with specific rights and obligations regarding your personal information.

Categories of personal information we collect

We have collected the following categories of personal information during the preceding twelve months:

CategoryExamplesCollectedA. IdentifiersReal name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, IP address, email address, and account nameNoB. California Customer Records informationName, contact information, education, employment, employment history, and financial informationNoC. Protected classifications under California or federal lawGender and date of birthYesD. Commercial informationTransaction information, purchase history, financial details, and payment informationYesE. Biometric informationFingerprints and voiceprintsNoF. Internet or similar network activityBrowsing history, search history, online behavior, interests, and interactions with websites, applications, systems, and advertisementsNoG. Geolocation dataDevice locationNoH. Audio, electronic, visual, thermal, olfactory, or similar informationImages, audio, video, or call recordings created in connection with our business activitiesNoI. Professional or employment-related informationBusiness contact details, job title, work history, and professional qualificationsNoJ. Education informationStudent records and directory informationNoK. Inferences drawn from other personal informationInferences used to create a profile or summary of an individual’s preferences and characteristicsNo

We may also collect other personal information outside these categories when you interact with us in person, online, by phone, or by mail in connection with:

  • Receiving help through our customer support channels.
  • Participating in customer surveys or contests.
  • Facilitating the delivery of our Services.
  • Responding to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices is provided throughout this privacy notice.

You may contact us by email at info@hbro-studio.com or use the contact details at the end of this document.

If you use an authorized agent to exercise your right to opt out, we may deny the request if the agent does not provide proof that they are validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information to service providers under written contracts between us and each service provider.

Each service provider is a for-profit entity that processes information on our behalf.

We may use your personal information for our own business purposes, including internal research for technological development and demonstration. This is not considered a sale of your personal information.

Hbrothers L.L.C. has not disclosed or sold personal information to third parties for business or commercial purposes during the preceding twelve months.

Hbrothers L.L.C. will not sell personal information belonging to website visitors, users, or other consumers in the future.

Your rights regarding your personal data

Right to request deletion

You may ask us to delete your personal information.

If you ask us to delete your information, we will respect your request and delete your personal information, subject to exceptions provided by law.

These exceptions may include:

  • Another consumer’s exercise of their right to free speech.
  • Our compliance with legal obligations.
  • Processing required to protect against illegal activities.

Right to be informed

Depending on the circumstances, you have the right to know:

  • Whether we collect and use your personal information.
  • The categories of personal information we collect.
  • The purposes for which collected personal information is used.
  • Whether we sell your personal information to third parties.
  • The categories of personal information sold or disclosed for a business purpose.
  • The categories of third parties to whom personal information was sold or disclosed.
  • The business or commercial purpose for collecting or selling personal information.

Under applicable law, we are not required to provide or delete de-identified consumer information in response to a request or to re-identify individual data to verify a consumer request.

Right to non-discrimination

We will not discriminate against you for exercising your privacy rights.

Verification process

When we receive a request, we will need to verify your identity to confirm that you are the person whose information is held in our systems.

We may ask you to provide information that we can compare with information you previously provided to us.

Depending on the type of request, we may contact you through a communication method you previously provided, such as email or telephone. We may also use other verification methods where appropriate.

We will only use the personal information provided in your request to verify your identity or your authority to make the request.

Where possible, we will avoid requesting additional information for verification purposes.

If we cannot verify your identity using the information we already hold, we may request additional information for identity verification, security, or fraud-prevention purposes.

We will delete this additional information as soon as the verification process is complete.

Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of personal information that is incorrect or no longer relevant.
  • You may ask us to restrict the processing of your information.
  • You may designate an authorized agent to submit a CCPA request on your behalf.
  • We may deny a request from an authorized agent who does not provide valid proof of authorization.
  • You may request to opt out of future sales of your personal information to third parties.

After receiving an opt-out request, we will act upon it as soon as reasonably possible and no later than fifteen days after receiving it.

To exercise these rights, contact us by email at info@hbro-studio.com or use the contact information below.

If you have a complaint regarding how we handle your data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes. We will update this notice when necessary to remain compliant with relevant laws.

We may update this privacy notice from time to time.

The updated version will be identified by an updated “Revised” date and will become effective as soon as it is made available.

If we make material changes to this privacy notice, we may notify you by prominently posting a notice of the changes or by sending you a direct notification.

We encourage you to review this privacy notice regularly to remain informed about how we protect your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer:

Robert Fok
Hbrothers L.L.C.
71–75 Shelton Street
London WC2H 9JQ
United Kingdom

Email: info@hbro-studio.com
Phone: 07557057887

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws applicable in your country, you may have the right to:

  • Request access to the personal information we collect from you.
  • Request that we change or correct your personal information.
  • Request deletion of your personal information.

To submit a request to review, update, or delete your personal information, visit the Hbrother website.

MEDICAL DISCLAIMER

This application provides health-related information and services for informational purposes only.

It is not a substitute for professional medical advice, diagnosis, or treatment.

Always seek advice from your physician or another qualified healthcare provider regarding any medical condition.

Never disregard professional medical advice or delay seeking it because of something you have read or seen in this application.

The information and services provided through this application are not intended to constitute medical advice or a medical diagnosis and should not be used as the basis for healthcare decisions.

This application does not provide emergency services.

In the event of a health emergency, contact your local emergency services immediately.

By using this application, you acknowledge and agree that the application is not responsible for health decisions made based on the information provided.

We recommend consulting a healthcare professional for personalized medical advice.

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