OUR COMMITMENT TO YOUR PRIVACY
Your privacy is important to us. To better protect your privacy, we developed this policy as an extension of our commitment to combine quality services with integrity in dealing with our users. The Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using Hornet.
- We will be transparent about the information we are collecting and what we will do with it
- We will also use the information to help us understand you better and so that we can give you relevant services and information
- If you tell us you don’t want to receive marketing messages we will stop sending them. We will, of course, continue to send important information relating to the Hornet service and your account with us.
- We will put in place measures to protect your information and keep it secure
- We will protect your data protection rights and aim to give you control over your own information.
If you have any further questions please get in touch with us by writing to:
Data Protection Officer
Hornet Networks Limited
50 Wong Chuk Hang Road
Wong Chuk Hang
Hong Kong Island
You may also contact us by email at: email@example.com
CONTROLLER OF PERSONAL INFORMATION
WHAT DO WE MEAN BY PERSONAL INFORMATION?
Personal information means details which identify you or could be used to identify you, such as your name and contact details, age, profile, comments, photographs, geographic locations, ethnic background, preference data and more. It may also include information about how you use our websites and mobile applications.
WHEN DOES THIS POLICY APPLY?
HOW CAN YOU KEEP YOUR PERSONAL INFORMATION SECURE?
We take great care to protect the personal information you provide to us. Here are some things that you can do to keep your information secure.
KEEP YOUR HORNET REGISTERED CUSTOMER LOG-IN DETAILS CONFIDENTIAL
To make sure your access to our websites and mobile applications is secure, you should not share your log-in details with anyone else. When you finish using the website or mobile app you should log out if others may be able to access your computer or device. This is especially important if you are using a publicly accessible computer.
BE AWARE OF AND PROTECT YOURSELF AGAINST INTERNET FRAUD AND PHISHING
There is an internet fraud practice known as phishing which is the illegal gathering of personal information by deception. Unsolicited emails are sent to individuals from lists illegally gathered by a third party, and recipients are asked to enter login, password or other personal details into a cloned or illegal copy website. You should ensure that you always have up-to-date protection software on your devices to minimise the risks of becoming the target of an attack.
We will never ask you to disclose your password to any of our staff. If you receive a suspicious request purporting to be from us, do not take any actions before confirming the authenticity of the request with us directly, using the contact details provided in this policy.
WHEN DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
We collect personal information about you whenever you use our products or services (whether these products or services are provided by us or by other companies or agents acting on our behalf), including when you use our website or mobile applications, or interact with us via email or use our contact centres. For additional details see ‘What information do we collect and retain?’ below.
WHAT INFORMATION DO WE COLLECT AND RETAIN?
In order to gain use of Hornet with your device we generate an ID that is unique to the device or browser on which you install and/or access Hornet. Unless legally obliged, we will never disclose or share this identifier to other parties.
INFORMATION WE SHARE WITH HORNET USERS
When using Hornet, you may provide Hornet with certain personal information specifically:
- The name you choose
- Description of yourself for your profile
- Any photos you upload
- Any comments you make on content or posts on our discussion forums
- Your geographic information
- Your ethnic background
- Your height
- Your weight
- Your preferred sexual role
- Your relationship status
- Your HIV status and if you take pre-exposure prophylaxis (“PrEP”)
- What you’re looking for: chat, dates, friends, networking or friendships
- Whether you have ‘liked’ content shown to you: events, articles and photos posted by Hornet members.
Hornet provides a social network service for connecting gay people. We use your information to help other users find and connect with you.
We may show the personal information listed above as part of our feed or on your profile page.
We provide users the ability to find you based on this information.
Geographic information is made available to our users as a relative distance or on the level of city, region or country.
INFORMATION WE DO NOT SHARE WITH HORNET USERS
You may provide us with the following information, which is used by us to identify you for logging in or for contacting you.
This is not shared with Hornet users.
- Your email address.
- Your Facebook ID, if you choose to login using Facebook.
- Your Google ID, if you choose to login using Google.
When using Hornet, you may use our in-app messaging service to communicate with other Hornet users either on our web app or in our mobile apps. We store messages, photos and stickers from your chats on our servers, so that you can have seamless access to your messaging history on your device at any time.
When you delete your account, we delete your chat messages as well as your user profile, subject to certain conditions set out below in the section “How long will we keep your personal information?”
INFORMATION WE COLLECT FROM YOUR USAGE OF THE MOBILE APP OR WEB SITE
We may also collect:
- Your contact with our support team — We collect information about you contacting our support team to help us answer your queries. We also gather information about any suggestions or complaints you make in order to help your with your queries and improve the products we offer you.
- IP address — The last IP address associated with a profile or user account is stored. This is used to control spam and fake account creation and identify illicit access to the Hornet service.
- Anonymous usage information — Your usage of the mobile app or website. We anonymize this information so we can no longer link it to your user account. We collect this to guide our product development so that we can continuously improve the services to our members.
- How you pay for premium subscriptions — If you have a current premium subscription and the details of how you pay for this so that we can continue taking payments for your subscription.
- Email preferences — Your preferences for receiving emails from us so we know which emails to send you and which you would rather not receive.
- Information about violations of our terms of service — We store information about incidents we feel are violations of our terms of service to help control and suspend users who are repeatedly breaking our terms of service.
- Violation reports you make about other users — If you report another user for violations of our terms of service, we collect information on what you feel the violation is, the time of the report, the user you are reporting and other further details you give us.
WHEN AND WHY DO WE COLLECT ‘SENSITIVE PERSONAL DATA‘?
Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “sensitive personal data“.
You may choose to give us the following specific sensitive personal data, which we show on your profile and provide users the ability to find you based on it:
- Your ethnicity
- Your preferred sexual role
- Your relationship status
You may also choose to share your HIV status with us and if your take pre-exposure prophylaxis (“PrEP”).
Your HIV status is only searchable by users who have defined themselves as HIV positive.
You may opt to receive in-app reminders to undergo HIV tests and receive information on the location of nearby testing centers.
We do not share any sensitive personal data information with third parties unless required to do so by law.
You may edit or delete this information any time.
HOW IS YOUR INFORMATION USED BY OTHERS THAT HAVE LINKS ON HORNET?
You may be able to access other websites or apps through Hornet via links or ads. When you do so, you are subject to their policies regarding privacy and data collection and you should read those policies carefully before using the same. Hornet does not accept responsibility for their use of your personal information, their privacy and data collection practices.
WHEN WILL WE SEND YOU MARKETING AND NEWSLETTERS?
For users joining our community who are subject to the data protection legislation of the EU, we will specifically ask them whether they wish to receive our newsletters. All other new users will automatically benefit from our newsletters, and all users can unsubscribe from our newsletters at any time. Please be aware that we do sometimes send marketing communications that promote a third party’s products and services (for example, those of our business partners) as well as our own.
We may ask if you consent to receiving marketing communications from other members of our group or from third parties.
We will respect your choice as to what communications you wish to receive and the methods by which you are sent them.
HOW CAN YOU CHANGE WHAT MARKETING COMMUNICATIONS YOU RECEIVE AND HOW YOU RECEIVE THEM?
If you decide you would no longer like to be sent marketing communications, you can change your mind at any time.
If you are a registered user of Hornet, you can change your marketing preferences at any time by amending your profile on the web site or in the mobile app.
You may also unsubscribe from our newsletter or all email communication by following the unsubscribe link on the bottom of relevant emails received from us.
Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications which are necessary, such as membership and other important service information. If you ask us to stop sending marketing communications, please note we will retain your personal information for the purposes of indicating that you do not want to receive marketing communications.
WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION?
Hornet will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons Hornet collected and needs to use your information. Under most relevant laws (EU, UK and others) in almost all cases the legal basis will be:
- Because we need to use your information so that we can provide the products and services to you and otherwise perform the contract we have with you.
- Because it is in Hornet’s legitimate interests to use your personal information to operate and improve our business.
- Because Hornet needs to use your personal information to comply with a legal obligation.
- To protect the vital interests of you or another person.
- Because you have consented to Hornet using your information for a particular purpose.
If processing of your data is subject to any other laws then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Your personal information may be shared with companies within our group to assist us in providing the services to you. We may also disclose your personal information to the following third parties for the purposes described here:
- Credit and charge card companies and anti-fraud screening service providers to process payments and (where necessary) to carry out fraud-screening.
- In response to a valid legal request from Government, regulatory authorities and law enforcement agencies.
- Third parties such as law firms and law courts to enforce or apply any contract with you or including subpoenas, court orders, legal process.
- In order to improve our business services, we may share information about your age and location, as well as non-personally identifiable information, with our advertising and analytics providers and with related service providers.
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
We will keep your personal information for as long as is necessary to provide you with our services and as permitted by the relevant legal requirements.
When you delete your account, it will be removed from our active database, but in some circumstances, it may remain in certain archives where it is not practical or possible to delete it.
In addition, we may keep your personal data and usage history (which includes a history of text or photos that have been censored, banned) as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
WHAT COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT TO?
Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area (EEA) and the United Kingdom (UK).
The nature of our business means it is often necessary for us to send your personal information outside the EEA or the UK to fulfil your use of our products and services. This occurs because our business and the third parties identified in ’Who do we share your personal information with?’ have operations in countries across the world. For example, you may be based in the European Economic Area or UK, your personal information will be transferred to other Hornet members outside of those territories.
In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.
This may involve sending your data to countries where under their local laws you may have fewer legal rights.
REQUESTING A COPY OF YOUR PERSONAL INFORMATION
Under the relevant data protection laws, you may request a copy of any personal data about you held by Hornet Networks Limited. In most instances, this is provided free of charge.
You can request your personal data from the mobile app or website.
We will need to verify your identity in order to request your data and we prefer to send your data to you by email.
If you no longer can access your account, our support team (firstname.lastname@example.org) can help you find your account details so you can login again.
If you have deleted your account, we no longer hold your personal information, subject to certain conditions set out above in the section “How long will we keep your personal information?”.
WHAT ARE YOUR OTHER RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT?
Dependent on the jurisdiction you are subject to, you may have some additional rights in relation to your personal information. Should you be subject to EU data protection legislation, for instance, you have, under certain circumstances, a right to:
- Access your personal data, rectify inaccurate data or erase your personal data, as well as request a restrictiction of or object to the processing of your personal data. Your profile can be amended by you at any time, allowing you to update your personal data as necessary;
- Withdraw your consent at any time where consent forms the legal basis of the data being processed. Note that a withdrawal of consent may impact the services we will be able to offer to you; and
- Get in touch with your relevant data protection authority to file a complaint. For a list of EU data protection authorities please see: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
In order to make our services more relevant to you and to improve our overall services, we may use automated processing of some of your personal information. We may use such automated processing in the following instances:
- In relation to your interactions with other users and certain content on the Hornet platform (such as who you communicate with, which profiles you have viewed and/or follow, contents of your profile, which content you and other users liked or similar activities) to suggest other users you may wish to talk to and vice versa (our “HornetSuggest” feature); and
- To allow us to moderate the large number of images submitted to us, our dedicated software automatically analyses and categorizes such images. If any of your images are not accepted or you have any queries in relation to our categorisation of images, please contact us using the contact details in this policy.
PERSONAL INFORMATION OF CHILDREN
Our services are intended only for users aged 18 or above. We do not knowingly collect, maintain or use any personal information of anyone below the age of 18. Should you become aware of anyone under 18 having submitted personal information to us, please contact us using the contact details contained in this policy and we will address the issue accordingly.
Your use of Hornet means that you accept the Policy above. We expressly reserve the right to make changes to the Policy from time to time at our discretion. Your continued use indicates your agreement to those changes.
Our EU representative for the purposes of GDPR Article 27 is:
c/o Hornet Networks Limited
50 Wong Chuk Hang Road
Wong Chuk Hang
Hong Kong Island
Email address: email@example.com
Last updated: May 2018
The English text of this policy is the authoritative version.