PRIVACY POLICY

17 January 2021

This Privacy Policy applies to all personal data of the data subjects located in the EEA that HintED located on the domain name hinted.me processes while using the site, programs, and products.

HintED is also the name of the digital adoption platform that eases the mastering of digital platforms. Access to the HintED service is provided under the Service Agreement.

 

Who we are?

This Privacy Policy explains how personal data is processed by Hinted LLC (“Hinted”), a company incorporated in the Russian Federation and having its registered office at room 10, str. Novo-Sadovaya 23, Samara, Samara Region, 443110, Russia.

The words “we”, “our”, “us”, and hinted.me refer to HintED.

In case you have questions about the processing of your personal data, or you want to exercise your rights, please contact us using:

our email: privacy@hinted.me

 

For your convenience, our Policy is divided into the following sections

What data, for what purposes, how long, and based on what grounds do we process as a Controller?

What data do we process as a Processor of our Customers (Controllers)?

Who do we share your data with?

Automated decisions

Cookies

Your rights

Changes to this Policy

 

What data, for what purposes, how long, and based on what grounds do we process as a Controller?

Purpose of Processing

Data Subjects:

Categories of Data

Storage Period

Legal Basis

to offer access to a demo of the HintED service

Our potential customers and their representatives:

name, phone number, email address, information that you provide about yourself (in the message field), your browser information (including IP-address)

until the termination of a contract in case it is concluded and within the terms specified by law

processing is necessary in order to take steps at your request prior to entering into a contract with us

We will not be able to provide access to the demo if you fail to provide the data

to negotiate and enter into a contract with our customers

Our customers and their representatives:

name, phone number, email address, position, company (customer) name, proof of the authority of the person to act on behalf of the customer

5 years after the termination of a contract

processing is necessary for the performance of a contract to which you are party

We will not be able to provide you with our service if you fail to provide the data

to create a HintED account for you

Our customers and their representatives:

full name, email address, information that you provide about yourself (in the comments field), registration date, level of your access rights (user, administrator, manager, client), status (blocked, unblocked, confirmed, unconfirmed), logs of your actions on our platform

until the termination of a contract and within the terms specified by law

to support you with various help queries received from you

Our website visitors, potential customers, customers and their representatives:

Troubleshooting and support data (content of a message) including your name and email-address

until the termination of a contract and within the terms specified by law

to send you direct email marketing communications about our service

Our customers and their representatives:

name, email address

until you unsubscribe from our mailing list, until the end of campaign, or until the purpose of processing personal data is achieved whichever happened earlier

your consent to receive our newsletter

You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you

to better understand your preferences, to help you navigate our website, to personalize and provide a more convenient experience to you, to analyze which pages you visit, and to measure advertising and promotional effectiveness

Our website visitors:

IP-address, GEO (country or town), OS type and version, browser type and version, type of device and its display resolution, traffic source for the visitor, OS and browser language, which buttons are being clicked and what pages are being opened

14 months or until you withdraw your consent whichever happened earlier

your consent to store cookies in your browser

You may withdraw your consent at any time by email privacy@hinted.me

 

 

What data do we process as a Processor of our Customers (Controllers)?

We process personal data on behalf of our customers located in the EEA and therefore acts as a processor in the sense of the GDPR.

Our Customers determine the purposes and means of the processing of personal data related to their end-users in respect to the HintED service and therefore act as controllers in the sense of the GDPR.

The data processing practices related to cases when we act as a processor and process on behalf of our customers are described in our Data Processing Agreement based on the EU Standard Contractual Clauses and incorporated into our Service Agreement with our customers.

 

Specific categories of data which we process on our customers’ behalf include, in particular, full name, email address, nickname, scenario name, id of the played scenario, playback "iteration" ID, uniquely generated user ID, sequence number of the step, step ID, date / time of the event, step playback status (displayed, hidden), absolute X coordinate, absolute Y coordinate, relative X coordinate, relative Y coordinate, identifier of the element on which the tooltip is displayed, the link on which the hints are played, the date the record was created in the database, the date the record was edited in the database, the date the record was deleted in base, script playing status (started, in progress, completed), link to the site, statistics id, organization id, script id, user id, number of plays, number of stops, number of completions, number of interrupted plays.

 

We process the data provided by our customers until the termination of our Service Agreement with them and within the terms specified by law.

Who do we share your data with?

Acting as a Controller we share your data with the following processors:

Processors, their Location and the Link to Privacy Policy / Website if applicable

Purpose of Transfer

Obukhov N. V. d/b/a Tilda Publishing (Russia), Privacy Policy

Website Builder Provider

Yandex LLC (Russia), Privacy Policy

Web Analytics Service Provider (Yandex Metrica)

HubSpot Ireland Limited (Ireland), Privacy Policy

CRM Service Provider

Rocket Science Group LLC d/b/a Mailchimp (the USA), Privacy Policy

Website Builder Provider

DigitalOcean LLC (the USA), Privacy Policy

Hosting Provider

Yartsev S. E. (Russia)

Affiliated party

Google LLC (the USA), Privacy Policy

Email Service Provider

Web Analytics Service Provider (Google Analytics, Google Tag Manager)

Facebook Ireland Limited (the EU) and Facebook Inc. (the USA), Privacy Policy

Contextual Advertising Service Provider (Facebook Pixel)

Mailgun Technologies, Inc. (the USA), Privacy Policy

Email Service Provider


 

Acting as a Processor we share the data provided by our Customers with the following sub-processors:

Purpose of sub-processing

Processors, their Location and the Link to Privacy Policy / Website if applicable

Safeguards for restricted transfers (outside the EEA and ‘adequate’ jurisdictions)

Hosting Service Provider

DigitalOcean LLC (the USA), Privacy Policy

We transfer your data according to the Data Protection Agreement and Standard Contractual Clauses between us and DigitalOcean

Affiliated party

Yartsev S. E. (Russia)

We use Standard Contractual Clauses to ensure that your data is properly protected

 

Automated decisions

We do not make any automated decisions about you that would result in legal or other similarly significant effects on you.

 

Cookies


 

 

What can you do if you do not want storing cookies to be set or want them to be removed?

You are able to withdraw the consent to store cookies by selecting the "Withdraw your consent" option in the Cookies section of this page.

 

Your rights

You have the following rights under the GDPR concerning personal data: the right to information, right to access, right to rectification, right to withdraw consent, right to object against processing for specific purposes (such as direct marketing), right to object to automated processing, right to be forgotten and right for data portability (copy of personal data in a commonly used machine-readable format).

 

You may also exercise the mentioned rights by contacting us via email at privacy@hinted.me.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

 

Changes to this Policy

We regularly update this Policy in case there are significant changes in the way we process your personal data.

You will receive a notification prior to such significant changes become effective by email if you provided us with your email address or by pop-up notice on our website.