HandsDown Privacy Policy

Effective Date: 11.18.21

Last Updated: 11.18.21

We are excited to share our MVP with you, and we welcome your feedback on this policy.

Welcome to HandsDown (the “Platform”). The Platform is provided and controlled by HandsDown Inc. (“HandsDown”, “we” or “us”). At HandsDown, we care a LOT about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. The purpose of this policy is to provide you with a comprehensive description of our practices regarding the collection, use, disclosure, and sale of personal information and of your rights regarding your personal information.

Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Use.

1. CONTACT

Questions, comments and requests regarding this policy should be addressed to:

– Mailing address: 50 Lakeside Avenue #81, Burlington, VT 05401

– Contact us: legal@itshandsdown.com

2. MINORS

For our MVP, our Terms of Use require all users to be at least 18 years of age. We do not knowingly “sell,” as that term is defined under applicable law, including the California Consumer Privacy Act, the personal information of minors.

3. WHAT INFORMATION DO WE COLLECT AND WHEN DO WE COLLECT IT?

We collect information when you create an account or use the Platform. We also collect technical and behavioral information about your use of the Platform. We also collect information contained in the comments you make on our Platform and, if you grant us access, information from your contacts list. More information about the categories and sources of information is provided below.

1. Information you choose to provide. For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

  • Registration information, such as age, username and password, language, and email or phone number;
  • Profile information, such as name, social media account information, and profile image;
  • User-generated content, including content you post to your List, comments, photographs, videos or other content that you choose to upload to the Platform (“User Content”). User Content is uploaded to the Platform and transmitted to others at your own risk. Although you may be able to set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the privacy of your User Content or control the actions of other users of the Platform with whom you may choose to share your User Content.
  • Content, including text, images, and video, found in your browser or device’s clipboard, with your permission. For example, if you choose to paste content from the clipboard into the Platform, we access this information stored in your clipboard in order to fulfill your request.
  • Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
  • Your opt-in choices and communication preferences.
  • Information to verify an account such as proof of identity.
  • Information in correspondence you send to us.
  • Information you share through surveys or your participation in challenges, sweepstakes, or contests such as your gender, age, likeness, and preferences.

2. Information we obtain from other sources.  We may receive the information described in this Privacy Policy from other sources, such as:

Social Media and Login Services. If you choose to link or sign up using a third-party social network or login service (such as Facebook, Instagram, or Google), you authorize us we may collect information from these services that you agreed such third parties could provide us with through their application programing interface (“API”), including for example, your name, third-party username, your contact lists for these services and information relating to your use of the Platform in relation to these services. If you link your HandsDown account to another service, we may receive information about your use of that service.

3. Information we collect automatically. As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  •  Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Contact us for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

4. Other Information we may collect. We may collect other information such as:

  • Location data.We may collect information about your approximate location, including location information based on your IP address. With your permission, we may also collect precise location data (such as GPS).
  • Comments. We collect information you provide when you comment on your own User Content or on the User Content of others.
  • Metadata. When you upload or create User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content the metadata can describe how, when, where, and by whom the piece of User Content was created, collected, or modified and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account. Additionally, metadata includes data that you choose to provide with your User Content, e.g. any hashtags used to mark keywords to the video and captions.
  • Cookies. We may use both cookies which expire when you close your browser and cookies which stay on your computer until you delete them, and other technologies to help us collect data and enhance your experience with the Platform. “Cookies” are small text files a website can use to recognize a repeat visitor to the Platform. We use Cookies to help us improve the Platform and to deliver a better and more personalized service, including by enabling us to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Platform according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Platform.

We may also engage third-party technology providers who use third-party analytics services (such as Google Analytics) to evaluate your use and activity of the Platform among other business purposes. These providers may use Cookies and other technologies for this purpose.

You may opt-out of receiving our cookies through your browser, however some aspects of the Platform may be affected.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

HOW WE USE YOUR INFORMATION

We use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Use. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your experience.

Generally, we use the information we collect:

  • To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
  • To customize the content you see when you use the Platform. For example, we may provide you with services based on the settings you have chosen or show you content that is similar to content that you like or interacted with.
  • To send promotional materials from us or on behalf of our affiliates and trusted third parties. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
  • To improve and develop our Platform and conduct product development
  • To make suggestions and provide a customized experience
  • To support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform
  • To use User Content as part of our advertising and marketing campaigns to promote the Platform
  • To understand how you use the Platform
  • To infer additional information about you, such as your age, gender, and interests
  • To use these understandings and our data analysis to develop insights into subjects such as user interests and consumer trends
  • To help us detect abuse, fraud, and illegal activity on the Platform
  • To prove your identity in order to use certain features, ensure that you are old enough to use the Platform (as required by law), or in other instances where verification may be required
  • To communicate with you, including to notify you about changes in our services
  • To announce you as a winner of our contest, sweepstakes, or promotions if permitted by the promotion rule, and to send you any applicable prizes
  • To enforce our terms, conditions, and policies
  • Consistent with your permissions, to provide you with location-based services, and other personalized content
  • To inform our algorithms
  • To combine all the information we collect or receive about you for any of the foregoing purposes.
  • To facilitate sales, promotion, and purchases of goods and services and to provide user support
  • For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

HOW WE SHARE YOUR INFORMATION

Service Providers and Business Partners

We may share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes, including research, development, database maintenance, administering contests and special offers, technology services, deliveries, sending communications, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing. These service providers and business partners may include:

  • Customer and technical support providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically.
  • Research providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically.
  • Cloud providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically.
  • Advertising, marketing, and analytics vendors, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically.

1. For Corporate Transactions or Legal Reasons.

We may share all of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy. We may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of HandsDown, Inc., the Platform, our affiliates, users, or the public. We may also share any of the information we collect to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law.

2. With your Consent.

 We may share your information for other purposes pursuant to your consent or at your direction.

If you access third-party services, such as Facebook or Google, to login to the Platform or to share information about your usage on the Platform with others, these third-party services may be able to collect information about you, including information about your activity on the Platform, and they may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

If you choose to engage in public activities on the Platform, you should be aware that any information you share may be read, collected, or used by other users. You should use caution in disclosing personal information while using the Platform. We are not responsible for the information you choose to submit.

4. YOUR RIGHTS

You may submit a request to access or delete the information we have collected about you by sending your request to us at the email or physical address provided in the Contact section at the top of this policy. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account. We do not discriminate based on the exercise of any privacy rights that you might have.

As this is the MVP we have no metrics for requests to access and requests to delete received by HandsDown during the previous calendar year. We will post such metrics to this policy when they become available.

5. YOUR CHOICES

We want to provide you with choices regarding the personal information you provide to us. Here are some mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Platform may then be inaccessible or not function properly.
  • You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.
  • If you previously chose to share precise location information, you can prevent your device from sharing precise location information (e.g. GPS location information) with the Platform at any time through your device’s operating system settings. 
  • If you have registered for an account, you may access, review, and update certain personal information that you have provided to us by logging into your account, and using available features and functionalities. You may also be able to opt out of certain information practices.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address legal@itshandsdown.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Platform’s home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Platform and this privacy policy to check for any changes.