Privacy Policy

Introduction

Huddol (the “Platform”) is a place for collaborating, earning and redeeming Huddol Tokens (“HDL”) for discounts on offers. Members exchange knowledge, experiences, and insights with one another, as well as transacting tokens for offers. Based on the information you provide, we connect you with people, communities, topics and marketplace offers matched to your profile and needs.

Participating in the Platform depends on sharing experiences and details about your situation. It does not require providing personally identifiable information. At Huddol, we are concerned about you and your privacy. We employ best practices from industry to protect you every step of the way.

Please read this privacy policy (the “Policy”) carefully to understand how we collect, use, protect and otherwise handle your information.

In addition to the definitions found in this Policy, there are definitions in our Terms of Use Agreement which apply equally in this Policy.

Huddol and its affiliates reserve the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Platform following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, you will be notified upon logging in to the Platform or via email.

General Statement of Privacy and Protection of Personal Information

We take your privacy and security of Personal Information very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information.

What Does This Privacy Policy Cover?

This Policy covers the treatment of personally identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”) and other information gathered when you are using the Platform. This Policy also covers our treatment of any Personal Information that we may share with third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that we do not own or control, including but not limited to any third-party websites or services (“Third Party Website” or “Third Party Service”) that you elect to access through the Platform or via a link from the Platform, or to individuals that we do not manage or employ. While we attempt to facilitate access or link only to those third-party Websites or Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party Websites or Services. We encourage you to carefully review the privacy policies of any third-party Website or Service you access.

Finally, this Policy does not cover any Personal Information you send to us via any non-secured mode of communications such as email, instant messenger or Twitter, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to us via these methods.

No Collection of Personal Information as a Matter of Course and Informed Consent

Personal Information is only gathered with your informed consent, except for cookies. Where you have provided Personal Information, it will only be used for the purposes of providing you Platform Services.

What information do we collect?

Shared information

Members on the Platform provide general information about themselves, their situation and the people in their care. This general information is shared with members of the platform and our partners (“Shared Information”). There are three sources of Shared Information on Huddol.

1. Information Members add to register and make a profile;
2. Information Members add through using the Platform, including:
   • The posts, contributions, comments, votes, images, video and other media members post on Huddol.
   • The connections a member makes on the site with people, topics and communities.
   • Chat or messaging services, either individual or group.
3. Periodically, we will ask our members to complete optional surveys to improve the Platform or as part of a research study. The responses to these surveys will be treated like other types of Shared Information as described in this Policy.

Restricted information

In addition to the Shared Information, we ask for a few pieces of information that are never shared with other Members (“Restricted Information”). We collect it for our use to communicate with you information and news about the Platform and to improve your experience on the Platform. Restricted Information includes your email address, password, IP address, credit card details, and marketplace related transactions. Marketplace related transactions are only known to the Member and the Pro listing the offer, unless otherwise disclosed by the Member.

Restricted Information about your Devices

We may collect information from or about the computers, phones, or other devices where you install or access our Platform. This information will not appear on the Platform. We will treat it like other Restricted Information on the Platform. For example, we may collect:

• Attributes such as the operating system, hardware version, and device settings.
• Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
• Connection information such as the name of your browser type, language and time zone, and IP address.

How do we protect your information?

We use only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure.

We implement a variety of security measures when a member enters, submits, or accesses their information to maintain the safety of your Personal Information.

We use end-to-end encryption for email address, password and IP address to guard against anyone accessing this Personal Information.

You may notice that you are automatically logged out if you have not used the Platform in a while. This is because we use a token-based authentication system. The same system used by other social networks to protect you from unknown people accessing your profile and viewing your content on Huddol.

Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

We use certain vendors and hosting companies to provide the necessary hardware, software, networking, storage, and related technology required to run the Platform, and these third parties have been selected for their high standards of security, both electronic and physical. For example, we use Heroku, a recognized leader, for hosting the Platform, AWS for image and database storage. You acknowledge that our third-party vendors and hosting partners may be located in jurisdictions or countries where the privacy laws may not be as protective as those in your home province, state, country or other governmental jurisdiction.

We do use cookies for tracking purposes.

How is your Information used and shared?

Members should expect that every piece of information they enter (even if it is not currently displayed), except for Restricted Information, may be shared with other Members, and partners. We make sure that when information is shared with third parties that all personally identifiable information is excluded.

There are instances where both Shared Information and Restricted Information, may be used and disclosed including, but not limited to, the following:

• Huddol uses Shared Information and Restricted Information internally, as needed, for product enhancements, for maintenance and operation of the Platform, and to create the best possible tools and functionality for our Members.
• Huddol may share or disclose a Member’s information (including Personal Information) where required by law or to comply with legal processes.
• If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, any violation of the user agreement, or situations that involve abuse of the Platform infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Platform infrastructure or the Platform generally).
• In the event that Huddol goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, the Shared Information and Restricted Information, including Personal Information, might be among the assets transferred. Members will be notified via the Platform or via email of any such change in ownership or control of Personal Information.
• In the event that an adverse event is reported by a Member as it relates to a medication, we may be required to report that information to a third-party who is legally bound to monitor and intervene in instances of adverse medication reporting. We will only report to the third-party with your consent.

How is Shared Information used?

To make recommendations to people, topics and communities

We use the information we have, to personalize your experience on the Platform and improve our recommendations. Based on the information you provide, we show you relevant people, topics and communities. Over time, we will measure the interest in particular recommendations and improve our recommendation system through updating our algorithms.

To show non-registered visitors the value of joining the Platform

Public activity on the Platform is viewable by non-registered visitors and can be indexed by search engines like Google.

To better tailor the services of the Platform

We will use certain Shared Information in the aggregate in order to improve the Platform and better tailor the Platform to the needs of our Members.

To inform research and policy work by partners and other third parties

We work with companies and organizations to conduct relevant research with the goal of improving healthcare. Research on the Platform may cover a range of topics ranging from the effect of using the Platform (e.g. the impact of Platform use on members) to medical research (e.g. the impact of health related challenges).

We will not share information that can personally identify you (e.g. email address). However, we may share free-text entered into Huddol with partners. We cannot pre-screen this data to guard against users sharing personally identifiable information in free text within, for example, a profile or community, so avoid adding information to free text that could uniquely identify you if this is a concern.

This does not include website hosting partners and other parties who assist us in operating our Platform, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.

How do we treat third-party links?

In your use of Huddol, you may encounter links to third-party products or services on our Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Platform and welcome any feedback about these sites.

Additional privacy protections

Data Integrity

Huddol cannot guarantee that the information entered into the Platform by Members is accurate. You may, in the course of using the Platform, come across Members who do not represent themselves accurately or enter misleading information. However, they do so in violation of our user agreement.

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track or plant cookies when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It's also important to note that we do not use or allow third-party behavioral tracking.

What if a data breach occurs?

If there is a data breach, we will notify you via email within 7 business days.

Email

As a member of Huddol, we will periodically send you emails about activity or news related to the Platform or notifications for you personally. We will send these emails in accordance laws protecting people against spam, including but not limited to the Canadian law informally known as Canada’s Anti-Spam Law (“CASL”, S.C. 2010, c. 23). If you believe you have received emails from us in violation of this law, please contact us using the contact information further below in this Policy.

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email.

General Information Transfer from the Platform

Any information (personal or not) the Platform collects while you use it may be stored locally on your Device and then transferred to servers controlled us, and we may obtain this information as a result of the data being sent to our servers from the Platform. The information, however, is only used (or not used) by us as described elsewhere in this Policy.

Permissions

The following is a complete listing and description of what functions on your Device that were developed by third parties are accessed and / or modified by the Application.

• Notifications. Allows the Application to send you notifications, but only with your express permission. You can turn off notifications at any time through your Device Settings.
• Push Notifications. Huddol makes use of push notifications on mobile devices but only with your express permission.
• Cookies. Huddol stores cookies in your browser to identify you. This information is used for the sole purpose of authentication.
• Browser Headers. Huddol gathers and stores your browser information for security reasons.
• Analytics. Huddol tracks your navigation behavior for analytical purposes.
• Transaction Emails. Huddol may send you transactional emails related to your behavior on the Platform. You can turn off these emails at any time through the Platform or by unsubscribing at the bottom of emails.

User Control and Uninstall for the Application

For the Application, you can access and change certain user settings from the settings menu on your Device. You may also uninstall; uninstall methods may vary depending on your Device or OS version. Huddol has no control over these functions and denies any responsibility of your use thereof, and any data or Personal Information sent to third parties as a result of said activities.

Risks Associated with the Internet and Wireless Data Transmission

Despite our best efforts to ensure that third parties will not access or obtain your Personal Information through your use of the Platform, complete confidentiality and security cannot currently be guaranteed on the Internet and / or where data is transferred via wireless digital technology of any type. Communication via the Internet or wireless digital technology is subject to interception, loss, or alteration. You acknowledge and agree that Huddol and its Representatives cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information over the Internet or wireless digital technology and that such communications are at your own risk.

Access, Correction and Deletion of Personal Information

If you wish to inquire about and access what Personal Information we hold about you to verify and / or correct it, or if you wish to delete any Personal Information held about you from our databases, please contact us using the information further below in this Policy. You may also delete your account (and thus your Personal Information) through your settings when you are logged in. Please note that if you request deletion of your Personal Information, we reserve the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations. Please note that deletion of your Personal Information as described in this section will make it impossible for you to use the Platform.

Compliance with Privacy Laws

This Policy and our practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5) and Quebec’s An Act Respecting the Protection Of Personal Information in the Private Sector (R.S.Q. c. P-39.1). If you have any questions regarding this compliance, please contact us using the contact information further below in this Policy.

Contacting Us

If there are any questions regarding this Policy, you may contact us at privacy@huddol.com.

Last edited on May 1, 2019.