Hornet Privacy Policy

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 Applications.

We will be transparent about the information we are collecting and what we will do with it
We will use the information you give us for purposes described in our Privacy Policy, which include providing you with services you have requested and enhancing your experience with Hornet Applications
We will also use the information to help us understand you better and so that we can give you relevant services and information
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.

CONTROLLER OF PERSONAL INFORMATION

Any personal information processed by Queer Networks, Inc. in connection with this Privacy Policy is controlled by Queer Networks, Inc., which is considered the data controller of your personal information under relevant data protection laws.

You can contact the data controller by writing to:

Data Protection Officer
Queer Networks, Inc.
750 N San Vicente Blvd, Suite 800
Los Angeles, CA 90069
Los Angeles, CA

You may also contact the data controller by email at: feedback@hornet.com

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?

This Privacy Policy applies to personal information about you that we collect, use and otherwise process regarding your relationship with us as a customer or potential customer, including when you engage with us or use our other products or services, use our websites or mobile applications or contact us.

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 Applications 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 Services with your device we generate an ID that is unique to the device or browser on which you install and/or access Hornet Services. Unless legally obliged, we will never disclose or share this identifier to other parties.

Information we share with Hornet Services users

When using Hornet Applications, you may provide Queer Networks, Inc. with certain personal information specifically:

The name you choose
Description of yourself for your profile
Any photos or videos you upload
Any comments you make on content or posts on our discussion forums
Your gender
Your sexuality
Your pronouns
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, photos, and videos posted by users of Hornet Services or Spaces you joined.

Queer Networks, Inc. provide a social network service for connecting queer people to their community. 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, on your profile page, or in suggestion displays.

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 other users of Hornet Services

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 other users of Hornet Services.

Your email address.
Your mobile phone number.
Your Facebook ID, if you choose to login using Facebook.
Your Google ID, if you choose to login using Google.

In-app chats

When using Hornet Applications, you may use our in-app messaging service to communicate with other users either on our web app or in our mobile apps. We store messages, photos, awards 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?".

When a user is reported for a potential violation of our Terms of Service, our moderation team may investigate the conversation in which the reported content occurred, as well as the context in which it was reported. We value user privacy, so access to chat messages is restricted and only granted when there is a specific need, such as when messages are relevant evidence of harassment, abuse, or other violations. This access is limited to authorized team members, is never made public, and data is retained only as long as needed for the investigation.

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 you 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 Services.
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. This includes data such as debit or credit card numbers or other financial data.
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.
Mobile phone number – We only may store your phone number in case of suspicious activity on your account and for SMS-verification purposes only. It will never be used for other purposes.

WHEN AND WHY DO WE COLLECT 'SENSITIVE PERSONAL DATA'?

Certain categories of personal information, such as that about race, ethnicity, religion, health, gender, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and are 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 gender
Your sexuality
Your pronouns
Your ethnicity
Your preferred sexual role
Your relationship status
Your location

You may also choose to share your HIV status with us and whether you 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.

Face Liveness and Identity Verification

To help maintain the safety and authenticity of our platform, we may use identity verification technologies such as Amazon Rekognition Face Liveness. This process may involve collecting a short video or image to confirm that a user is a real person and matches their profile.

The media collected for this purpose is stored securely in a restricted-access AWS S3 bucket. Only authorized systems and personnel may access these files. While these materials are primarily processed automatically, we reserve the right to make them visible to authorized moderators or administrators for moderation and safety purposes, such as verifying user authenticity or investigating reports.

We do not share, sell, or disclose this data to third parties, and it is never made public. The data is retained only for as long as needed for verification, moderation, or fraud prevention, in accordance with applicable laws and privacy regulations.

By using Hornet, you acknowledge and agree that we may request identity or liveness verification, and that this may involve the temporary collection and review of biometric data.

HOW IS YOUR INFORMATION USED BY OTHERS THAT HAVE LINKS ON HORNET SERVICES?

You may be able to access other websites or apps through Hornet Services 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. Queer Networks, Inc. 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 Services, 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?

Queer Networks, Inc. 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 Queer Networks, Inc. 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 Queer Networks, Inc.’ legitimate interests to use your personal information to operate and improve our business.
Because Queer Networks, Inc. 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 Services using your information for a particular purpose.
If you choose to provide us with information that is considered ‘special’ or ‘sensitive’ in certain countries, such as your sexual orientation, you consent to the processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your exact location or to use your data for specific reasons. In some cases, you can withdraw your consent by adjusting your settings (e.g. in relation to the collection of your precise location data) or by deleting your content (e.g. if you have entered data in your profile that may be considered ‘special’ or ‘sensitive’). In any case, you can withdraw your consent at any time by contacting us at the address at the end of this Privacy Policy.

Legitimate interests. To the extent permitted by applicable law, we rely on our legitimate business interests to process your personal information. The following list contains examples of business purposes for which we have a legitimate interest in processing your data:

Detect, track and prevent fraudulent activities and unauthorized payment transactions;
Minimize financial losses, claims, liabilities or other damages to end customers, end users, business customers, financial partners and Hornet;
Determination of suitability for new Hornet services and their offering;
Responding to inquiries, delivering service notifications and providing customer support;
Marketing, analyzing, modifying and improving our Services, systems and tools and developing new products and services, including improving the reliability of the Services;
Manage, operate and improve the performance of our websites and services using information about their effectiveness and the optimization of our digital assets;
Analyze and promote our Services and related improvements;
Comprehensive analysis and development of business intelligence solutions to help us run and protect our business operations, make informed decisions and report on the performance of our business;
Disclosure of personal information to the third party service providers who provide services on our behalf and to business partners who assist us in conducting and optimizing our business;
Ensuring network and information security at Hornet and the services provided by Hornet; as well as
Sharing personal information with our affiliates.

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 Hornet 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.
We may share your personal data with any subsidiaries, joint ventures, or other companies under common control. If another company acquires our company, business, or our assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Privacy Policy.
We use Zendesk to manage customer support requests. When you contact us, certain pieces of your personal information (such as your name, email address, and the content of your request) may be processed and stored through Zendesk. By creating a support ticket with us, your data may also be subject to Zendesk’s own policies (https://www.zendesk.com/company/policies-and-guidelines/).
We partner with ParshipMeet Group to provide live streaming functionality and moderation services within the Hornet app. When you use live streaming features, certain personal data such as your username, video content, and chat activity may be processed by ParshipMeet Group in accordance with their own privacy and moderation standards. These services are essential for the functionality and safety of live content on the platform.
Fraud prevention and security providers. We may share device, network, and other technical information with trusted third-party service providers that assist us in detecting automated activity, preventing fraudulent account creation, and protecting the security and integrity of our services.

If we use contracted service providers for individual functions of our offer or use your data for advertising purposes, we will always carefully select and monitor these service providers and inform you in detail below about the respective processes. We will also state the specified criteria for the storage period.

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will keep your personal information for as long as is necessary to provide you with Hornet Services and as permitted by the relevant legal requirements.

When you delete your account, it will be removed from our active database.

To protect the security of our users, we have set a period of three months after the closure of an account or one year after an account suspension. During this period, we will retain your data in case it is necessary to investigate unlawful or harmful behaviour. The retention of data during this period is based on our legitimate interest and that of potential third-party victims.

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:

We retain certain data to fulfil our legal retention requirements. In particular, this includes transaction data, which we retain for 10 years to comply with tax and accounting legislation, credit card data (for as long as the user can dispute the transaction) and ‘traffic data’ / log data (for one year to comply with statutory storage obligations). We also retain records of consents provided by our users for five years to demonstrate our compliance with applicable law.
Based on our legitimate interest, we retain the following specific data: Customer service records and supporting data and approximate location details of downloads/purchases (five years to support our customer service decisions, enforce our rights and defend ourselves in the event of a claim), information about the existence of previous accounts and subscriptions (will be deleted by us three years after your last account is closed, to ensure proper and accurate financial forecasting and reporting), profile data (one year in view of possible litigation as well as for the establishment, exercise or defense of legal claims) and data necessary to exclude users who have been prohibited from opening a new account (for as long as necessary to ensure the security and essential interests of our users).
Furthermore, we retain data on the basis of our legitimate interest if there is an outstanding or potential issue, claim or dispute that requires the retention of data (in particular, if we receive a valid court subpoena or request relating to the retention of data - in which case we would need to retain the data to comply with our legal obligations - or if the data is otherwise required as part of legal proceedings.

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), including the USA

The nature of our business means it is often necessary for us to send your personal information outside the EEA or the UK to fulfill 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 users of Hornet Services outside of those territories.

We also use tools on our website from companies based in third countries, including the USA. If these tools are active, there is a possibility that your personal data will be transferred to the US servers of the respective companies. In this respect, we would like to point out that the USA is not a safe third country according to the understanding of EU data protection law. In the USA, companies are obliged to disclose personal data to security authorities without providing sufficient legal means to take action against such disclosure. Therefore, it cannot be ruled out that US authorities, such as intelligence agencies, may process, analyse and permanently store your data stored on US servers for surveillance purposes. We have no influence on this processing activity.

In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.

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 Queer Networks, Inc. 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 (feedback@hornet.com) 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?

Depending 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 restriction 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;
rectification and erasure of personal data;
to restrict processing of the collected data;
data portability; 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 of Hornet Services (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.

CHANGES AND UPDATE TO THIS PRIVACY POLICY

Your use of Hornet Services 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.

COOKIES

In addition to the above-mentioned data, we use technical aids for various functions when you use our website, in particular cookies, which can be stored on your device. When you access our website and at any time thereafter, you have the choice of whether you generally allow cookies to be set or which individual additional functions you would like to select. You can make changes in your browser settings or via our Consent Manager.

This website uses the following types of cookies, the functioning of which and legal basis are explained below:

Transient cookies: Such cookies, especially session cookies, will be automatically deleted when the browser is closed or by logging out. They contain a so-called session ID. This allows various requests from your browser to be assigned to the shared session and your computer can be recognised when you return to our website.
Persistent cookies: These will be automatically deleted after a specified period, which varies depending on the cookie. You can review the cookies set and the duration hereof at any time in your browser settings where you can also delete the cookies manually.

The technical structure of our website requires us to use certain technologies, in particular cookies. Without these technologies, our website cannot be displayed correctly, or the support functions could not be enabled. The cookies affected are basically transient cookies that will be deleted at the end of your visit to the website, at the latest when you close your browser. You cannot deselect these cookies if you wish to use our website. The individual cookies are available in the Consent Manager.

Some of the cookies that we use are optional. We only set those cookies with your consent, The functions are only activated if you give your consent via the cookie consent tool and can be used in particular to enable us to analyse and improve visits to our website, to make it easier for you to use different browsers or end devices, to recognise you when you visit us again or to display advertising. You can withdraw your consent at any time. your withdrawal does not affect the lawfulness of processing your data up to the point of withdrawal.

ANALYTICS AND TRACKING TECHNOLOGIES

We use the web analysis service Google Analytics from Google Inc. (hereinafter referred to as “Google”) and the Facebook Pixel from Meta Platforms Inc. (hereinafter referred to as “Meta”) on our website. The data processing serves the purpose of analyzing this website and its visitors, as well as for marketing and advertising purposes. These tools help us understand user behavior and the effectiveness of our campaigns so we can optimize our services accordingly.

Google and Meta will use the information obtained on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity and advertising performance, and to provide other related services to the website operator. The following information may be collected: IP address, date and time of the page view, click path, information about the browser and device you are using, pages visited, referrer URL (the website from which you accessed our website), location data, and purchase activities. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.

These technologies use cookies, web storage in the browser, and tracking pixels to enable analysis of your use of the website. The information generated is usually transferred to servers in the USA and stored there. The data transfer takes place, among other things, on the basis of the Data Privacy Framework (DPF) and standard contractual clauses as suitable guarantees for the protection of personal data, which can be viewed at: https://policies.google.com/privacy/frameworks and https://business.safety.google/adsprocessorterms/.

Both Google and Meta, as well as U.S. government authorities, may have access to your data. Your data may be linked by these providers with other data, such as your search history, personal accounts, usage data from other devices, and other data collected by Google or Meta.

IP anonymization is activated on this website for Google Analytics. As a result, your IP address will be shortened by Google if you are based in a member state of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

Your personal data is processed on the basis of Art. 6 para. 1 lit. f GDPR, due to our overriding legitimate interest in the needs-based and targeted design of the website. You have the right to object to this processing of your personal data at any time for reasons arising from your particular situation.

You can prevent the collection of data generated by Google Analytics and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can manage or opt out of data collection by Meta through the settings in your Facebook account or via the Digital Advertising Alliance opt-out page: https://www.youronlinechoices.com/.

Further information on terms of use and data protection can be accessed at:

EU REPRESENTATIVE

Our EU representative for the purposes of GDPR Article 27 is:

Christof Wittig
c/o Queer Networks, Inc.
750 N San Vicente Blvd, Suite 800
Los Angeles, CA 90069
Los Angeles, CA
Email address: gdpr-eu-representative@hornet.com

KOREA POLICY

For Korea Notice of Overseas Transfer, please see WHAT INFORMATION DO WE COLLECT AND RETAIN? above.

To request expedited removal of the information we retain, please contact customer service from within any of our other services or products. You may request expedited removal if:

you believe that it is no longer necessary for us to hold your personal information;
we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
where our processing of your personal information is for direct marketing purposes and you object to such processing;
you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or
you believe the personal information we hold about you is being unlawfully processed by us.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents (“Notice”) supplements the information contained in the Privacy Policy of Queer Networks, Inc. (“we,“” “our” or “us”) and applies in certain circumstances solely to all natural persons who are California residents (“consumers” or “you”).

The California Consumer Privacy Act of 2018, as amended (collectively, the “CCPA”) defines “personal information” broadly as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This Notice also uses that definition for personal information.

US STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia provide their states residents with rights to:

Confirm whether we process their personal information
Access and delete personal information
Correct Inaccuracies in their personal information, taking into account the information’s nature processing purpose (does not apply in Iowa and Utah)
Data portability
Opt-out of personal data processing for:
- Targeted advertising
- Sales
- Profiling in furtherance of decisions that produce legal or similarly significant effects (does not apply in Iowa and Utah)
Either limit, opt out of or require consent to process personal sensitive information.

Nevada allows for residents to opt out of the sale of their personal information.

To exercise any of these rights, please contact privacyteam@hornet.com. If you wish to appeal a decision made about a consumer right request, please write to privacyteam@hornet.com.

APPLICABLE LEGISLATION IN OTHER COUNTRIES CONCERNING DATA PRIVACY

Australia. If you are an Australian resident and are dissatisfied with our handling of any complaints you make under this Privacy Policy, you may contact the Office of the Australian Information Commissioner.
Brazil. To exercise your rights, you can contact our data protection officer at privacyteam@hornet.com . Residents of Brazil to whom the Lei Geral de Proteção de Dados Pessoais (“LGPD”) applies have the rights set out in Article 18 of the LGPD.
Canada. In this statement, the term “applicable law” includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information Protection Act, SBC 2003 c 63 in British Columbia, the Personal Information Protection Act, SA 2003 c P-6.5 in Alberta and the Act Respecting the Protection of Personal Data in the Private Sector, CQLR c P-39-1 (Quebec Private Sector Act) in Quebec. “Personal Data” includes “personal information” as defined in these laws.
Quebec. Hornet’s Privacy Team is responsible for personal data within the meaning of the Quebec Private Sector Act. You can contact him by email at privacyteam@hornet.com. When we collect personal information from Quebec residents, we may transfer that information to data centers in the United States. Service providers that we use to process personal data may also be located outside of Quebec.
India. In this statement, the term “applicable law” includes the Digital Personal Data Protection Act (DPDPA) as soon as it comes into force. In addition, the term “data controller” also includes “data trustee” and the term “data subject” also includes “client”, each as defined in the DPDPA.
In some cases we may rely on “authorized use” as a legal basis where permitted by the DPDPA. This is the case, for example, if you voluntarily provide us with your personal data. “Consent Managers” within the meaning of the DPDPA may make a request to withdraw or grant consent using the methods described in the “Contact Us” section below, or as described in the following paragraph, or through such other means as Hornet may make available in the future provides. Before processing such a request, we may require proof of authorization and identity.
If you have any questions or complaints regarding the processing of your personal data in India, you can contact our privacy team at privacyteam@hornet.com . If we are unable to address your complaint or concern, you have the right to refer the matter to the Data Protection Board of India.
Indonesia. In this Privacy Policy, the term “applicable law” includes Law No. 11 of 2008, as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the introduction of electronic Systems and Transactions and the Regulation of the Minister of Communications and Informatics No. 20 of 2016 on the Protection of Personal Data in Electronic Systems and, from September 2024, the Law No. 27 of 2022 on the Protection of Personal Data (PDP Law) . If you have any questions or complaints about this privacy policy, please contact our data protection officers at privacyteam@hornet.com .
Japan. In this Privacy Policy, the term “applicable law” includes the Act on the Protection of Personal Information (APPI). When we transfer personal data of data subjects in Japan to countries that are not recognized as “adequate” by the Personal Data Protection Commission, we enter into written contracts with third parties located outside Japan. These written contracts provide for rights and obligations equivalent to those under the Japanese Act on the Protection of Personal Information. For more information about how we ensure third parties protect your information and where your information is located, please see above or contact us as described below.
In some cases and to the extent permitted by the APPI, we may rely on the “public interest” as a legal basis, such as in detecting fraud and preventing loss.
Malaysia. If you have any questions or complaints about this privacy policy, please contact our privacy team at privacyteam@hornet.com .
Singapore. In this privacy policy, the term “applicable law” includes the Personal Data Protection Act 2012 (PDPA) (No. 26 of 2012) as amended from time to time. In some cases and to the extent permitted by the PDPA, we may rely on “presumed consent” as a legal basis. This is the case, for example, if you voluntarily provide us with your personal data.
If you have any questions or complaints about this privacy policy, please contact our privacy team at privacyteam@hornet.com .
Switzerland. In this data protection declaration, the term “applicable law” includes the Federal Data Protection Act (DSG) in its revised version. To exercise your rights under the DSG, please contact our privacy team at privacyteam@hornet.com . You may also have additional rights under the Swiss-US Data Privacy Framework once it comes into effect.
Thailand. In this privacy policy, the term “applicable law” includes the Personal Data Protection Act 2019 (PDPA). If we rely on certain legal bases (for example “legal obligation” or “contractual necessity”) and you do not provide us with your personal data, we may not be able to lawfully provide our services to you. If you have any questions or complaints about this privacy policy, please contact our privacy team at privacyteam@hornet.com

YOUR RIGHTS AND CHOICES

Your Rights to Know

You have the right to request that we disclose certain information to you about our collection, use, disclosure and sale of your personal information in the preceding twelve (12) months. Once we receive and confirm your request to know, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business purpose or commercial purpose for collecting or selling that personal information.
The categories of third parties to whom we disclose that personal information.
The specific pieces of personal information we collected about you (also called a request to know data portability request).

Your Deletion Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, in certain circumstances. Once we receive and confirm your request to delete, we will delete from our records, and direct our service providers to delete from their records, your personal information, in certain circumstances.

Exercising Requests to Know and Requests to Delete

To exercise the request to know and request to delete rights described above, please submit a verifiable consumer request to us by emailing us at feedback@hornet.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

A verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only make a request to know twice within a twelve (12)-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to requests to know and requests to delete within forty-five (45) calendar days. If we require more time (up to an additional forty-five (45) calendar days), we will provide you with notice and an explanation of the reason that we will take more than forty-five (45) calendar days to respond to the request.

We will deliver our written response in writing and delivered through your registered account with us.

The response we provide will also explain the reasons we cannot comply with a verifiable consumer request (including, regarding a request to delete, whether we have complied with that request), if applicable.

Any disclosures we provide will only cover the twelve (12)-month period from the date that we receive the request to know.For request to know data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.Unless permitted by the CCPA, we will not:

Deny you services or goods.
Charge you different prices or rates for services or goods, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of services or goods.
Suggest that you may receive a different price or rate for services or goods or a different level or quality of services or goods.

CONTACT INFORMATION

If you have questions about our privacy policies, notices or practices, please contact us at:

feedback@hornet.com

privacyteam@hornet.com

Last updated: 2024

The English text of this policy is the authoritative version.