Privacy Policy

Last updated: 04/08/2024.

This Privacy Policy is edited by Headstrong Internet Services Ltd, a legal entity having its registered office at 9 Riverside, Waters Meeting Road, Bolton BL1 8TU, United Kingdom, and registered in England & Wales under registration number 06500823 (hereafter, the "Data Controller").

The Data Controller (collectively referred to as "Headstrong Internet Services Ltd ", "we", "us" or "our" in this privacy policy) offers this website and related services (hereafter, the "Platform") to its users, some of whom may have subscribed on the Platform and as such have a user account (hereafter, the "Users"). The Platform is available at the following web address https://headsnet.com/.

This privacy policy will inform you as to how we look after your personal data when you visit our website or Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how the Data Controller collects and processes your personal data through your use of our website and the Platform, including any data you may provide through this website and the Platform when you sign up, create an Account or use the Platform.

This website and the Platform are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy the Data Controller may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

In this regard, the Data Controller collects and processes User's personal data in accordance with the Privacy Policy and Cookie policy.

The Data Controller is particularly aware and sensitive with regards to the respect of its Users privacy and personal data protection. The Data Controller commits to ensure the compliance of the processing it carries out as data controller in accordance with the Data Protection Law.

Data Protection Law is the EU Regulation n°2016/679 regarding data protection dated April 27, 2016 named General Data Protection Regulation or "GDPR".

The Data Controller has put in place an appropriate privacy and cookie policy to be fully transparent on how the personal data of Users are processed within the use of the Platform and services provided.

This privacy policy is intended for the Users of the Platform of the Data Controller.

The Data Controller has appointed a Data Protection Officer (hereinafter "DPO"), who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your Legal Rights, you may contact us at [email protected].

Contact Details

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our website and the Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Commitment of the data controller

The Data Controller commits to process User's personal data in compliance the Data Protection Law and undertake to, notably, respect the following principles:

Process User's personal data lawfully, fairly, and in a transparent manner;

Only collect and process the Users' data for the strict purpose as described under article 2 of the present privacy policy;

Ensure that the personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

Do the best efforts to ensure that the personal data processed are accurate and, if necessary, kept up to date and take all reasonable steps to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

Keep personal User's data for no longer than is necessary for the purposes for which they are processed;

Put in place all necessary technical and organizational appropriate measures in order to ensure the security, confidentiality, integrity, availability and the resilience of the process systems and services;

Limit the access to the Users' data to the persons duly authorized to this effect;

Guarantee to the Users their rights under the Data Protection Law in relation to the processing of their data and make the best efforts to satisfy any request, where this is possible.

Collected Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms, registering an account with us, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services;
• create an account on our website or app;
• subscribe to our service;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website or service, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
  1. analytics providers such as Google based outside the UK; and
  2. search information providers based both inside and outside the UK.
• Contact and Transaction Data from providers of technical, payment and delivery services based both inside and outside the UK.
• Identity and Contact Data from data brokers or aggregators based both inside and outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

The User is aware that when using the Platform, the User may decide to provide Special Categories of Personal Data within the meaning of Data Protection Law, for example, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, concerning sexual orientation, etc. By providing such Special Categories of Personal Data, the User agrees to their processing by the Platform in the conditions set out in this Privacy Policy.

The Purpose Of The Data Processing

The Data Controller and its subcontractors process personal data that are freely transferred by the User when accessing the services proposed by the Platform for the following purpose:

• To provide the services of the platform.
• Creation and management of a user account and to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation

Providing the User with all functionalities of the Platform, meaning:

• Sending invitations for events organised by Data Controller or other Users, if the User has accepted to receive such invitations;
• Sending offers from the Data Controller or its partners if the User has accepted to receive such offers.
• Invite the User to events organized by the Platform

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or joined the Platform and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Platform or service experience or other transactions.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties.
• External Third Parties as set out in the 'List of Main Service Providers'.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Retention Period

The Data Controller informs the User that the personal data related to the User Account is retained during the length of the User's subscription on the Platform and for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Following the termination of said subscription to the Platform, the data collected upon the subscription as well as the content published by the User on the Platform shall be deleted after a period of 2 years (unless otherwise stated above).

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Transfers

The Users' data is stored in the European Economic Area (EEA) by the Data Controller and its trusted service providers. However, depending on the processing, the Users' data may also be transferred in a country outside the EEA, to our trusted service providers.

When transferring data outside the EEA, the Data Controller ensures that the data is transferred in a secured manner and with respect to the Data Protection Law. When the country where the data are transferred does not have a protection comparable to that of the EU, the Data Controller uses "appropriate or suitable safeguards".

When the service providers to whom personal data are transferred, are located in the United States, these transfers are governed by the standard data protection clauses adopted by the Commission.

Exercise of the users' rights

Your Legal Rights

The User has at any time, depending on the legal basis of the processing, a right to access, to correction, to erasure, to restriction of processing, to request a transfer of their personal data, to object to processing, and to withdraw consent:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

The User can exercise their rights by sending an email provided that the User confirms their identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies

The Data Controller informs the User that tracking technologies such as cookies may be used whenever the User navigates on the Platform subject to the conditions defined in our cookie policy.

Recipient and persons authorised to access the users' data

Only authorised persons working for the Data Controller, can access your personal data. The Data Controller makes its best effort to ensure that these groups of people remain as small as possible and maintain the confidentiality and security of User's personal data.

The Data Controller also uses trusted service providers to carry out a set of operations on his behalf for hosting. The Data Controller can also use service providers in the tech industry, editors of specific tools integrated in the Platform for technical purposes.

The Data Controller only provides service providers with the information they need to perform the service and ask them not to use your personal data for any other purpose. The Data Controller does his best to ensure that all these trusted service providers only process the personal data on our documented instructions and provide sufficient guarantees, in particular in terms of confidentiality, expert knowledge, reliability and resources, to implement technical and organisational measures which will meet the requirements of the applicable legislation, including for the security of processing.

The Data Controller may be required to disclose or share your personal data to comply with a legal obligation, or to enforce or apply our Terms of Use or any other conditions you have accepted; or to protect the rights, safety or property of Headstrong Internet Services Ltd, its customers or employees.

List of the main service providers:

Digital Ocean

• 101 6th Ave New York, NY 10013
• Delivery of services provided, data storage and backups.
• https://www.digitalocean.com/legal/privacy-policy

Stripe

• 510 Townsend Street, San Francisco, CA 94103, USA
• Payment service provider.
• https://stripe.com/fr/privacy

Sentry

• 132 Hawthorne Street San Francisco, CA 94107,USA
• Production and storage of error logs.
• https://sentry.io/privacy/