PRIVACY POLICY

Last update: [2019.05.06]

This privacy policy (“Policy”) describes how honeygain.com (“honeygain”, “we”, “us”, “our”) collects and uses personal information that we gather about end users of our applications and website visitors. This Policy also outlines your rights and choices regarding the personal data collected about you.

This Policy may be updated from time to time in accordance to our new practices or developments in the fields of privacy and personal data. In case of any considerable changes to this Policy, honeygain will take measures to notify you in advance via email (if possible), pop-up on our website or by other means which we will deem the most fitting in a particular case.

If you have any questions regarding our Policy or the way we collect and process your data, do not hesitate to contact us at: [email protected]

INFORMATION OF END USERS OF HONEYGAIN APPLICATION

Purposes and Data Collected

Honeygain gives rewards in exchange of a small amount of your network connection and device’s resources. For such an arrangement to work, we require access to a limited amount of your personal data.

We categorize the data we have access to through our application into the following categories:

User email. It is used as your user name and is necessary to log-in into honeygain application. We also use your email to contact you regarding important announcements related to your account and service updates.

User payment information. Necessary for transferring collected rewards to your preferred account. We process information depending on your choice of payment method (bank card, Wire payment or WebMoney payment).

Device information. Your IP address, operating system version, device model, charging state, last seen timestamp and location (city and country). We use this information to check if your device resources can be used and for accessing and collecting data from public internet resources.

Network information. We need to know if your Wi-Fi is on or off, to avoid engaging your device when it is using cellular data.

Information provided above is necessary for the performance of the contract between you and honeygain.

In order to analyse and improve our services we also collect some aggregated statistics related to the use of our application. Said information may include crash and error reports, also application usage analytics provided by Google and Facebook Analytics. We process such data based on our legitimate interest to improve functionality and usability of our applications. Users can opt-out from such processing by changing the settings in the application.

INFORMATION OF WEBSITE VISITORS

We automatically collect certain information from you when you visit our website. The data we collect through our website includes your internet protocol address, location data, type of browser, device and the operating system you use. This information is collected based on our legitimate interest to ensure a thorough functioning of our website.

In collecting your information through our website, we make use of cookies and other similar technologies. If you wish to read about the cookies we use, their purpose and duration, please see a detailed cookie table we incorporated at the end of this Policy.

We may also collect your personal information when you contact us via email or a dedicated contact-us form. In such case, we will use your personal data to administer your inquiry as well as adequately address any issue or question that you may have. The basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.

DATA SHARING

We use our service providers (data processors) to help deliver our services. Such data processors are data storage providers, payment providers, email delivery service providers, performance analytics providers (for crash and error reporting), web and application usage analytics providers (such as Google and Facebook Analytics) and others. Our service providers are obligated to keep your information in a secure manner and do not have the right to access your information for their own purposes. Our data processors are also obligated to not disclose your information to any third parties not related to the provision of the said services.

We may share your location and IP data with our partners in order to enable them to access and collect data from public internet resources (e. g. various websites from the internet). Such data sharing is necessary for the performance of the contract between you and honeygain.

We will not share or otherwise disclose your personal information in any other case than described above unless:

You request or authorize us to do so;

We are obliged to disclose the information by law (complying with a court order, enforcing an agreement between us, protecting the rights and/or property of our company, its employees or other stakeholders);

The disclosure of such information is necessary for our agents in order to function on our behalf;

It is necessary to address emergencies.

Data transfers outside the European Economic Area (EEA)

We strive to ensure that even in cases your personal data leaves the EEA our partners or service providers would comply with European privacy standards. We include data protection related clauses to agreements with our partners and service providers, and in case they are located in countries lacking adequacy decisions from the European Commission, we enter into agreements with standard data protection clauses adopted by the European Commission.

DATA STORAGE

Your personal data that we process for any purpose shall not be kept for longer than is necessary for a particular purpose or purposes. In any case it shall be kept for no longer than 5 years after the end of contractual or other relations with you.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

As a data subject, you retain the following rights with regard to your personal information:

Right to access. We have an obligation to provide you access to the data that we have collected on you. If we are not able to identify you, we may require you to give us additional information in order to be able to satisfy your request. The usage of such additional information will be strictly limited to helping you exercise your right of access;

Right to amend. You can enter and update your information in our application;

Right to delete. You have the right to request us to delete your personal information. However, we will only comply with such request where: (a) we no longer need it for reasons it was collected for; (b) the erasure of data will not prevent us from complying with a legal obligation; (c) we do not need the data in order to establish, exercise or defend against legal claims.

You retain the rights to access, edit and delete information that we hold on you. In most cases, any of the above can be done by you by simply logging-in and/or updating honeygain settings.

You are also entitled to exercise the following rights under the General Data Protection Regulation:

Limit the processing of your personal data if it is being processed unlawfully;

Object the processing of your personal data if such processing is legally based on honeygain’s ‘legitimate interests’ and is violating your fundamental rights and freedoms. However, please note that we retain the possibility to be able to show that our legitimate interest outweighs your rights and freedoms;

Receive your personal data in a computer-friendly form and/or ask us to transmit your personal data to another controller;

File a complaint about the use of your personal data. If you believe that we mishandled your personal information or otherwise acted unlawfully in relation to your privacy rights, you have the right to file a complaint with a local supervisory authority.

You can exercise any of these rights, as well as discuss other issues you may have with this Policy by contacting us at [email protected]

INFORMATION ON CHILDREN

We do not intend to collect any personal information of children under the age of 14 or any other age which would require authorisation and/or consent of a holder of parental responsibility for the collection and/or processing of the personal data of such child. In a case of us accidentally collecting personal information of children, we undertake to delete or otherwise dispose of such information as soon as possible after we become aware of having received it. If you are a holder of parental responsibility of a child that has provided us their personal information without your consent and/or supervision, please contact us so that we can take relevant actions to stop collecting and processing your child’s personal data and erase the data that we may have already collected.

INFORMATION SECURITY

We collect, process and otherwise handle your data with a high level of care and responsibility. We take necessary measures in order to make sure that your information is being kept and handled in a secure and lawful manner, such as regular updates, testing, access restriction. However, have in mind that no company, including honeygain, can guarantee the absolute security of internet communications.

INFORMATION ON COOKIES

We use the following technologies (e. g. cookies, pixels and beacons) to collect information from your device you use to access our services:

Essential cookies are essential for enabling user movement around our website and providing access to various features of the website. This category of cookies cannot be disabled.

ESSENTIAL COOKIES COOKIE NAME PURPOSE / DESCRIPTION COOKIE DURATION TYPE dc_gtm_<property-id> Used by Google Tag Manager to throttle request rate 1 minute 3rd party cookieConsent Determines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon re-entry. 30 days 1st JWT Local storage token used to track user session Persistent 1st

Usage statistics cookies collect information about how visitors use our website. These cookies collect information in the aggregate to give us insight into how our website is being used.

USAGE STATS COOKIE NAME PURPOSE / DESCRIPTION COOKIE DURATION TYPE _ga Used to distinguish users. 2 years 3rd party _gid Used to distinguish users. 24 hours 3rd party _gat Used to throttle request rate 1 minute 3rd party _gaexp 3rd party (google optimize 360) Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in. 90 days 3rd party _cfduid Cloudflare cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. 1 year 3rd party AMP_TOKEN Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service. 30 seconds to 1 year 3rd party

Audience data cookies are placed by third party advertising platforms or networks in order to deliver ads, track ad performance, and enable advertising networks to deliver ads that may be relevant to you based upon your activities.