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.

If you have any further questions please get in touch with us by writing to:

Data Protection Officer
Hornet Networks Limited
Unit 2908
29/F, W50
50 Wong Chuk Hang Road
Wong Chuk Hang
Hong Kong Island
Hong Kong

You may also contact us by email at: feedback@hornet.com

CONTROLLER OF PERSONAL INFORMATION

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

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 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:

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.

In-app chats

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:

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:

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:

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:

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 (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?

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:

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:

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 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.

EU REPRESENTATIVE

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

Christof Wittig
c/o Hornet Networks Limited
Unit 2908
29/F, W50
50 Wong Chuk Hang Road
Wong Chuk Hang
Hong Kong Island
Hong Kong
Email address: gdpr-eu-representative@hornet.com


Last updated: May 2018

The English text of this policy is the authoritative version.