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Study Buddy Learning – Privacy Policy

Effective Date: 12-10-2020

Welcome to Study Buddy Learning!  

Higher Level Learning, Inc.  (“HLL”, “we” or “us”) is committed to respecting privacy of the information of its Users. This Privacy Policy forms part of, and is governed by the Agreement and explains how we collect, use, store and disclose the information of our Users.

To know when the changes to this policy are effective, please review the “Effective Date” at the top of this page.

When you read the Privacy Policy, you will come across certain capitalized terms. These capitalized terms which are not defined in this policy, will have the same meaning as set out in the Terms of Use, which you can view here.

1              Privacy Policy

1.1          Who do these Terms of Use apply to?

This Privacy Policy applies to all Users.

1.2          How do I accept the Privacy Policy?

By accessing or using the Services, or by checking the box to confirm that you agree to our Privacy Policy, you confirm that you accept and agree to comply with the Privacy Policy, and to the collection and use of your Personal Information in accordance with this Privacy Policy and the Agreement.

If you disagree with anything in this Privacy Policy or the Agreement, you should not use the Services. 

1.3          Will this Privacy Policy ever change?

HLL may change this Privacy Policy from time to time, like when HLL offers a new Service, with changes in technology or when legal requirements arise, and you should review this page periodically. After each change to the Privacy Policy, HLL will send you an email notification and update the ‘Effective Date’ at the top of this page.

If you continue to use the Services or provide HLL Information (defined below) after any change to the Privacy Policy, you are taken to have accepted the changes to the Privacy Policy from the ‘Effective Date’.

2              What information does HLL collect about me?

2.1          Types of information that we collect about you

HLL collects and receives the following types of information about you when you access or use the Services:

·                 Personal Information: Such information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”); and

·                 Non-Personal Information: Such information which by itself cannot be used to identify or contact you (“Non-Personal Information”).

We refer to the Personal Information and Non-Personal Information collectively, as ‘Information’. 

2.2          What Personal Information do we collect about you?

HLL may require you to provide, or collect the following Personal Information from you:

·                 Identifiers such as your first and last name, any photographs or video recordings voluntarily uploaded by you on the Platform, Student’s name, grade, and school in which Student studies, name of Student’s day teacher at school and his or her age or date of birth. Your contact information such as your email, phone number and geographical location along with any notes about Student that a Parent may provide to Instructor;

 

·                 Internet or your connection related information such as your Internet Protocol (“IP”) address and mobile device unique identifier;

 

·                 Commercial Information such as information about your credit or debit card or other financial account information required to process payment for the Services;

 

·                 Audio, visual, or similar information such as video recording of Students and the Instructor, any audio and videos that are uploaded by Users, such as by Instructors at the time of registration etc.;

 

·                 Professional or employment related information of Instructors such as skills that Instructors possess and their qualifications and certifications; and

 

·                 Other Information that allows you to be identified personally such as information related to the Classes purchased by you, or Classes conducted by you using our Platform. This also includes information that we collect from the social media accounts linked to your account.

2.3          What Non-Personal Information do we collect about you?

HLL may collect Non-Personal Information about you such as your age, zip code, information about where Students will disperse after their Classes etc.

The limitations and requirements contained in this Privacy Policy only apply to collection, use, disclosure, transfer and storage, or retention of Personal Information by HLL, and not to Non-Personal Information.

HLL may combine your Non-Personal Information with information of other Users to improve the Services. At times, HLL may also amalgamate your Personal Information with other Non-Personal Information we have about you (including Non-Personal Information that HLL collects from third parties) to offer you a better experience. In such event, HLL will treat the combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.

2.4          Does HLL collect Personal Information about third parties from you?

HLL may collect information about you via a third-party, like your friend referring you to try HLL, and we will use that information to contact you.

3              How does HLL collect my Information?

3.1          Information you provide to HLL

HLL collects all Information which you voluntarily provide to HLL by using the Platform or interacting with HLL. This includes but is not limited to, Information that you provide to HLL in the following instances:

·                Register and operate your account: HLL receives Information when you register with HLL, update your account, and when you close your account with HLL;

 

·                Communicate with HLL: Such as when you contact HLL support, or when you communicate with an Instructor or other Parents using chat, audio or video call facility offered by HLL or any third-party communication service provider of HLL;

 

·                Use social media platforms: Such as when you link your social media accounts to your HLL account. HLL will use the Personal Information you have provided to the social media platform to create your account, and to enable you to access your HLL account;

 

·                Use the Services: Such as when you purchase and book any Classes, or when you offer, and conduct any Classes;

 

·                Through audio, visual, or similar medium: Such as through any documents, audio, or video messages that Instructors may upload about themselves on the Platform;

 

·                Set-up payment instructions: Commercial Information such as your credit or debit card information or other financial account information that you provide HLL when you set-up payment instructions for the Services; and

 

·                Participate in any promotional activities and referral programs conducted by HLL.

3.2          Information HLL automatically collects about you

HLL automatically collects certain Information about you that gets sent to HLL from the computer, mobile device and, and the Internet browser through which you access the Platform (“Automatic Data”).

Automatic Data includes but is not limited to, the following Information:

·                Your IP address;

 

·                Information about the device you use to access the Platform;

 

·                The web address or the advertisement that brought you to HLL;

 

·                The terms that you searched on a search engine that brought you to HLL;

 

·                Statistics about your use of the Platform, such as the links you clicked on, the time and date of your visit, the content that you viewed and duration of your stay on the Platform;

 

·                Times taken by you to download any content and information from the Platform; and

 

·                Details of the Classes you have enquired about, or purchased and booked, and any information that HLL needs to respond to your queries.

HLL collects Automatic Data based on your consent, which you provided when you registered as a User and accept this Privacy Policy.

How is Automatic Data collected?

HLL, its marketing partners, analytics, and service providers use small files that store information on the device you use to access the Services called cookies, and other tracking technologies to collect Automatic Data. HLL uses Automatic Data to identify different Users, improve browsing experience of the Users and to generally understand the online behavior and interests of people who interact with HLL. To know more about how HLL uses cookies, please see Section 20 of this Privacy Policy.

3.3          Information about you that HLL obtains from others

HLL may also collect or receive Information from the social media platform that you use to log-in to your account or from any service providers that HLL uses. HLL may combine this information with information that HLL already has about you. This helps HLL to update, expand and analyze its records, identify new customers, and create more tailored advertising that may be of interest to you. 

4              For what purposes does HLL collect my Information?

4.1          HLL uses the Information HLL collects from you for the following purposes:

·                    Provide the Services: HLL uses your Information to deliver the Services, like to enable you to register your account, to facilitate Parents to search and book Classes, and for Instructors to provide the Classes; 

·                    Maintain and improve the Services: HLL uses your Information to make sure that the Services work as intended, such as troubleshooting issues that you report to HLL, and to provide customer support as needed. When you contact HLL, we will keep a record of your request to solve any issues you might be facing;

·                    Develop new services: HLL uses your Information to develop new services with the hope that they benefit you;

·                    Provide personalized Services, including content: HLL uses your Information to customize the Services for you, like showing you relevant results when you search the Platform and to provide you recommendations;

·                    Protect against security threats, abuse, and illegal activity: HLL cares about keeping you secure and safe while using the Services. Keeping you safe requires HLL to process your Information such as your device information, monitor your activity on the Platform and other relevant information. HLL uses this information to combat spam, malware, malicious activities, security risks and to verify your identity so that unauthorized users are not able to access your Information;

·                    Measure performance: Such as for analytics and measurement to understand how the Platform and the Services are being used. For example, HLL analyzes data about your visit to the Platform to better design the Platform and the Services to improve your experience;

·                    Marketing communications: In accordance with your communication preferences, HLL will occasionally contact you to announce new services and features HLL builds for you, share tips for using the Services, make offers and provide information on how you can use the Services. If you wish to stop receiving marketing emails, please follow the instructions contained in the emails to opt-out of receiving further email marketing communications from HLL;

·                    Comply with law: The Services are subject to certain laws and regulations. HLL also uses your Information to satisfy applicable laws or regulations, and discloses Information in response to legal process or requests from government and law enforcement agencies; and

·                    Enforce the Agreement: Your use of the Services is subject to the Agreement. To ensure that you comply with the Agreement, HLL processes your Information to investigate, prevent or reduce violations of the Agreement.

HLL may also use your Information for other purposes. HLL will inform you and ask for you consent before using your Personal Information for a purpose that is not covered by this Privacy Policy.

5              To whom does HLL disclose my Information? 

5.1          HLL is not in the business of selling or renting your Information. HLL may share your Information with the following persons or entities, all of whom may use your Information only for the purposes described in the Privacy Policy.

·                   HLL employees and other companies owned or controlled by HLL;

·                   Third party suppliers and service providers (such as service providers whose services HLL uses to deliver the Services to you, customer management services who process data on behalf of HLL, or third-party advertising networks so that they can deliver HLL advertisements to you across the Internet);

·                   Professional advisers and agents of HLL;

·                   Payment system operators whose services are required to process payments for Services (e.g. merchants receiving card payments such as Stripe);

·                   Our tax compliance service providers;

·                   Our existing or potential agents or business partners;

·                   Sponsors or promoters of any promotional activity that HLL carries on the Platform;

·                   In the event of a merger, sale, or reorganization of all or part of our business, Information covered by this Privacy Policy may be transferred in connection with that deal; and

·                   Third parties, whenever you specifically consent or direct HLL to share the Information.

5.2          Sharing aggregate and anonymous Non-Personal Information

HLL may aggregate Non-Personal Information about Users and share it with third parties. Though this information will be anonymous and will not identify any User personally, in some cases the third parties may be able to combine this information with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally. 

6              How does HLL collect, use, and disclose Personal Information relating to children?

6.1          Collection of Children’s Data

HLL collects Children’s Data directly from Parents or from the Children during Classes. HLL also receives Children’s Data in the form of video, still images and voice of the child from the Recordings of the online Classes.  

HLL does not allow children to post any Personal Information about themselves on the Platform, or collect any Personal Information directly from the children, until they participate in the Classes.

6.2          Use and disclosure of Children’s Data

HLL shares necessary Children’s Data with Instructors to enable them to conduct the Classes. HLL may also share Children’s Data with other third parties in response to any instruction, or authorization that HLL receives from the school organizers, or Parents. 

 

Like other Personal Information that HLL receives from you, HLL may also share Children’s Data in accordance with Section 5 with its employees, vendors, service providers, following any transfer of its business, and to comply with its legal obligations.

 

Bear in mind that HLL cannot control or monitor what Personal Information your child shares with Instructors and the other Students who participate in the Classes with your child, nor what these third parties ultimately choose to do with such Personal Information.  You agree that HLL disclaims all liability in that regard.

6.3          Consent of Parents to collect Children’s Data

Where Parents register themselves on the Platform, HLL obtains verifiable consent of the Parent’s before collecting Children’s Data. HLL does not knowingly collect any Children’s Data unless and until the Parent’s allow their children to use the Services.

 

If a Parent does not consent, HLL will neither collect, use, or disclose Personal Information relating to their child, nor allow their child to use the Services.

 

Please contact HLL at [email protected] if you believe HLL has inadvertently collected Personal Information of a child under 13 without proper consent, so that we may delete such information as soon as possible.

6.4          Parental Control and choices regarding Children’s Data

As a Parent, you can update the Children’s Data HLL has about your child by logging-in to your account. You can also email HLL at [email protected] to access, update or delete any Children’s Data about your child.  HLL will honor all your requests within a reasonable time.

 

As a Parent, you can also refuse to permit HLL from collecting any Children’s Data for your child(ren). Since Children’s Data is required to book the Classes, without Children’s Data, Parents will not be able to book the Classes. You can also ask us to delete all Children’s Data that we have for your child(ren) in our records. Bear in mind that a request to delete your Children’s data may result in deactivation and ultimately closure of your account.

 

HLL is also entitled to delete the Children’s Data about your child, when HLL reasonably believes that such information is no longer needed.

6.5          Recordings

HLL enables recording of all group Classes. Parents may, upon request, be permitted to record certain Classes strictly for personal use.

Uses of the Recordings

HLL may monitor, collect, record, store and use the details and content of the Recordings and the related Children’s Data such as the name and likeness of the children participating in the Class in any manner or form, for the following purposes:

·                Providing customer support;

·                Resolving any User issues;

·                Improving the Services;

·                Obtaining, or providing feedback to Users;

·                Analytics; and

·                To maintain the quality and safety of the Services etc.

Safety measures for the Recordings

Parents agree not to share the Recordings with any Instructors, Parents, or third parties who did not subscribe to the concerned Classes on HLL. However, HLL cannot prevent unauthorized copying or sharing of the Recordings taken by the Parents, and that HLL cannot control or monitor what they choose to do with the Recordings. You agree that HLL disclaims all liability in that regard.

7              How does HLL use my Personal Information for marketing?

7.1          Communications data

HLL enables (or may enable in the future) Users to communicate with each other and with HLL using text messages, audio, and video calls and in app messages and calls, using the Platform and, or third-party communication services.

HLL and the third-party communication service providers providing these communication services may monitor, collect, record, store and use the details and content of the communications and the related Personal Information, like time and duration of communication, and the name and likeness of the Users involved in any manner or form, for the purposes specified in Section 6.5 above.

All Users have the right to request that HLL cease to use any communication involving them and, or their Personal Information for marketing purposes. 

7.2          Audio or video uploaded by Users

HLL may use the whole or any part of any Feedback and User Content, like any audio or video uploaded by the Users on the Platform in any manner or form for the purposes specified in Section 6.5 above. All Users have the right to request that HLL cease to use any Feedback or User Content involving them and, or their Personal Information for marketing purposes. 

8              Does HLL respond to legal requests for my Information?

8.1          Sharing your Information in response to court orders and subpoenas

HLL will disclose your information to law enforcement or other governmental authorities where HLL believes disclosure is required to comply with warrants, court orders, subpoenas, or other lawful government requests.

HLL narrowly interprets information requests and will only disclose Information that has been specifically requested or where you provide your explicit consent.

8.2          Sharing your Information with third parties

HLL may also share your Information with third parties as HLL believes in good faith is necessary to investigate or act regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate the Services, or as otherwise necessary to comply with HLL’s legal obligations.

9              How can I manage my Information stored with HLL?

You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information. In most cases, you can manage your Information simply by logging into your account and directly editing your information.

If you prefer, you can also contact HLL at [email protected] to ask us to provide access to, correct, update, or delete your Personal Information. If you request to access the Personal Information you have submitted, HLL will respond to your request within 45 days or as required by law. Please note that HLL may ask you for proof of account ownership and, or identity before fulfilling your request.

If you are a California resident please visit the “Privacy Rights of California Residents” in Section 19 of this Privacy Policy to know about your rights and how to exercise them.

10           How does HLL secure my Information?

HLL takes commercially reasonable physical, administrative, personnel and technical measures to secure your Information. Unfortunately, no method of transmission over Internet, or form of electronic storage is completely secure. As a result, though HLL strives to protect your Information, HLL cannot ensure and does not warrant the security of your Information that is held by HLL.

Any transmission of Information is at your risk. HLL is not responsible if any User circumvents any privacy settings or security measures contained on the Platform.

11           Where does HLL store my Information?

We will store and process your Information in the United States. Our service providers may store and process your Information in the United States and elsewhere where they maintain facilities.

You consent to the transfer of your information to the United States or any other country in which HLL, other companies owned or controlled by HLL and their service providers maintain facilities. 

12           Links to other sites

The Services contain links to third-party websites, which if you click will take you to these third-party websites. HLL does not exercise any control over these third-party websites. HLL also does not endorse, authorize, or make any representation about these websites or their privacy and information protection policies.  These websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Information from you. HLL encourages you to read the privacy policies or statements of these websites when you visit them.

13           Is Instructor’s profile public?

Currently, we do not display the Instructor’s profile on the Platform However, the profile that an Instructor creates on the Platform or the credentials otherwise provided by the Instructor to us may be shared by HLL with the Parents before or after the commencement of the Classes, and the Instructor expressly consents to such disclosure.

14           Personal Information provided to others

This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through our Platform, such as posting the Personal Information in the public areas of our Platform. For example, any Feedback that you provide to another User or Personal Information that you post in your public profile are not in our control and are therefore, not subject to this Privacy Policy.

15           Can I ask HLL to delete my Personal Information?

15.1       All Users can request deletion of all Personal Information HLL has about them.

15.2       HLL will use commercially reasonable efforts to honor your requests for deletion of your Personal Information. Bear in mind that not all Personal Information can be deleted and that certain Information will continue to remain on the Services even after you close your account, for example any Feedback that you publicly posted.

15.3       Please note that your right to request deletion of your Personal Information may be limited. For example, if you ask HLL to delete information, that HLL is required to retain by law, or which HLL has a compelling legitimate interest in keeping (such as for fraud prevention purposes).      

15.4       If you request HLL to delete all your Personal Information, then your account may become deactivated. If your account is deactivated or you close your account, you will no longer be able to use the Services or avail the Classes. 

16           What happens if I want to stop using HLL or close my account?

16.1       You can close your HLL account at any time through the account closure feature provided on the Platform or by contacting us at [email protected] Please remember that you will not able to use the Services after closure of your account.

16.2       Even after closure of your account, HLL may retain your Personal Information for a commercially reasonable time for back-up, archival, legal, tax or audit purposes and for legitimate and lawful business purposes. 

16.3       In addition, any Personal Information that you have shared with other Users through the Services or with social media sites cannot be deleted.

17           What happens if my account is inactive?

If your account is inactive for an extended period, HLL may close your account to comply with its legal obligations, and in accordance with its data retention policy. If that happens, HLL will try to notify you before taking any action.

18           Can I opt out of receiving marketing communications?

18.1       A registered HLL User can choose what communications they want to receive from HLL and, or third-party service providers of HLL. These communications may be in the form of SMS, emails, or other forms of communication.

18.2       Users may opt-out of receiving marketing related text messages by emailing HLL at [email protected] Users may also opt-out of receiving marketing related emails by emailing us as above, or by unsubscribing using the unsubscribe link provided in these emails.

18.3       HLL reserves the right to continue to send you certain communications like, administrative and service messages, any information that you may request, even after you opt-out from receiving marketing communications. 

19           Privacy Rights for California Residents

19.1       Users residing in California have been provided certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.). If you are a California resident, these terms and conditions apply to you. 

19.2       HLL uses and collects your information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA. HLL makes the following additional disclosures relating to the collection, use and disclosure of your Personal Information under the CCPA.

19.3       Users residing in California have additional rights in the Personal Information that HLL collects about them. These rights are discussed in Sections 19.4 to 19.8. All these rights are subject to certain exceptions. For instance, HLL will not be required to disclose your Personal Information if HLL is unable to verify your identity, or if HLL has already provided Personal Information to you during the 12 months preceding the receipt of your request in accordance with CCPA.

19.4       Right to Know

You have the right to request the following information about you in writing:

Categories of Personal Information collected by HLL

In the preceding 12 months, HLL collected the following categories of Personal Information about you:

·                Identifiers such as your first and last names, email address, phone number, IP address, unique device identifiers or another online identifier;

·                Commercial information such as your payment information and related information to enable you to pay for the Services, information about the Classes you purchased or considered to book;

·                Internet or your connection related information such as the name of your internet provider, Internet browser type and version, your IP address;

·                Electronic, audio, visual or similar information such as photos and videos uploaded by Instructors and recordings of the Classes;

·                Professional or employment related information (such as those provided by Instructors); and

·                Other information that relates to or is capable of being associated with you.

For additional examples of the types of Information that HLL collects, see Section 2 “What information does HLL collect about me?”.                

Business or Commercial purposes for collecting your Personal Information

HLL collects your Personal Information for the business and commercial purposes described in Section 4 “For what purposes does HLL collect my Information?”.

Categories of sources from which HLL collected your Personal Information

HLL collects your Personal Information in the following manner: (i) directly from you when you use the Services; (ii) automatically when you use or access the Services, and (iii) from third-party sources described in Section 3 “How does HLL collect my Information?”.

Categories of Personal Information HLL has disclosed about you

In the preceding 12 months, HLL has disclosed the following categories of your Personal Information for business or commercial purposes: identifiers, commercial information, internet or other electronic network information, and geolocation data. 

Categories of third parties with whom HLL shares Personal Information

HLL shares your Personal Information with third parties as described in the Section 5 “To whom does HLL disclose my Information”.

19.5       Right against Discrimination

You have a right to receive the same Services and price as other Users and cannot be discriminated against for exercising any of the rights described in Sections 19.4 to 19.8. HLL will not discriminate against you in any manner for exercising any of these rights.

19.6       Right to access your Personal Information

You have the right to request access to the specific pieces of Personal Information HLL has collected about you in the last 12 months.

19.7       Right to ask for deletion of your Personal Information: You have the right to ask HLL to delete any Personal Information that HLL has collected about you. This right is subject to certain exceptions and HLL may retain your Personal Information where HLL cannot verify your request, or where HLL needs to retain the Personal Information to comply with its legal obligations, etc.

19.8       Right to opt-out of having your Personal Information sold

You have the right to opt-out of having your Personal Information sold. To clarify, HLL does not sell your Personal Information.

19.9       How do you exercise your rights?

Users residing in California may exercise these rights by emailing HLL at [email protected] Please note that HLL may ask you for proof of account ownership and, or identity before completing your request. HLL will only use such Information to verify your identity, and for fraud prevention or security purposes.

20           Cookie Policy

20.1       What are Cookies?

Cookies are small text files that each website that you visit sends to your computer, mobile device, or browser. Cookies are stored on your computer or mobile device. 

20.2       What are Cookies used for?

Cookies help the website remember information about your visit, like things that you viewed or searched on the website, help remember your preferences, etc. This makes your next visit to the website easier and the website more useful to you.

HLL uses Cookies for many purposes. For example, HLL uses Cookies to remember your search preferences, to protect your data and to make the ads you see more relevant to you. 

20.3       What type of Cookies does HLL use?

HLL broadly uses four types of Cookies. You can read more about each type of Cookie below.

·                Essential: These Cookies are essential for you to able to experience the full functionality of our Platform. These Cookies allow you to log-in to your account, add Classes, and checkout securely, besides allowing you to edit your HLL account. These Cookies allow HLL to maintain user sessions and prevent security threats. Without these Cookies, you will not be able to properly access and use our Platform.

 

·                Functionality Cookies: Functional Cookies allow HLL to remember the choices you make on the HLL Platform and to provide you an enhanced and more personalized experience, like helping HLL remember your User name, the region you are in and assisting you during log-in. These Cookies also help HLL remember any pages that you customized, and provide services you request such as viewing photos, videos or providing any Feedback. 

 

·                Performance Cookies: The main purpose of performance Cookies (also called analytics Cookies) is not to identify you, but to collect information about how you use our Platform. For example, performance Cookies show HLL which pages you view most frequently on our Platform, the types of Classes that you are most interested in, and help HLL take note of any difficulties that you faced while using the Platform. Performance Cookies also show HLL whether our advertising is effective or not. All this information is collected on an anonymous basis and is used to improve your visit to the HLL Platform.

·                Targeting or advertising Cookies: These Cookies can remember that your device has visited a website or service, and can also track your activity across other websites and services, besides HLL. HLL may share the information collected by these Cookies with its service providers, such as advertisers who may use this information to show you advertisements that HLL believes are more relevant to you and your interests. These Cookies may also be used by our service providers to measure the effectiveness of our advertising campaigns.

20.4       Third-party analytics providers, ad servers and similar third parties

HLL may use third-party service providers to monitor and analyze the use of its Platform. For example, HLL may use a product analytics service provider to collect Information about how you use the Services, which part of the Services you frequent most, and the time you spend using the Services etc. HLL may also use marketing service providers who use information about your visit to other websites to target advertisements for the Services. The third-party service providers engaged by HLL may use Cookies to collect Information about you. HLL may not always control the type of Information these third-party Cookies collect and store about you.

20.5       How long will the Cookies stay on my device?

The length of time a Cookie will stay on your device will depend on the type of Cookie. If the cookie is a ‘session’ Cookie, it will stay on your device until you stop browsing. A ‘persistent’ Cookie on the other hand will stay on your device till the cookie expires or is deleted.

20.6       How do I control Cookies?

You may refuse to accept Cookies from our Platform at any time by activating the setting on your browser which allows you to refuse Cookies. These instructions are usually located within the “Help”, “Tools” or “Edit” facility. Some third-party websites or applications also provide the option to reject Cookies, by allowing you to opt-out.

Please be aware that if Cookies are disabled, not all features of our Platform may operate as intended.

21           How does HLL respond to do-not-track signals?

21.1       When you browse the Internet on computers or mobile devices, you can send a request to websites not to collect or track your browsing data.

21.2       What happens to your data depends on how a website responds to the request. HLL does not change its behavior upon receiving a do-not-track request. HLL will still collect and use your browsing data to improve security, provide content, services, ads, and recommendations on their websites, and generate reporting statistics.

22           How can I contact HLL?

22.1       For further information about HLL’s Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact HLL at [email protected]