Privacy policy

Version applicable as of 10th May 2024

1. WHY SHOULD I READ THIS PRIVACY POLICY?

This Privacy Policy ('policy') describes how Hypnovy, Inc. (hereinafter referred to as the "Company", "We", "Us", "Our") collects, uses, discloses, and stores your personal information and outlines your statutory rights. We protect your personal information under the applicable data protection laws, including the EU General Data Protection Regulation (2016/679) ('GDPR'). We may amend this policy from time to time. Therefore, please visit our website regularly for the latest version of this policy.

2. WHO IS RESPONSIBLE FOR PROTECTING MY INFORMATION?

We are: Hypnovy, Inc.

Our address: 228 Park Ave S, New York, NY 10003

Our e-mail address: support@hypnovy.com

3. WHY AND HOW DO YOU COLLECT MY INFORMATION?

3.1. TO PROVIDE YOU WITH OUR ONLINE SERVICES AND/OR PRODUCTS

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When you use / receive our online services and / or products

First name, last name, email address, password, other data provided during registration, account creation date, user's most recent login date, selected account settings, online services and/or products received, test results, game scores

Contract (Art. 6 (1) (b) of GDPR)

From yourself

It is necessary to enter into a contract. If not provided, you will not be able to use or receive our online services and/or products

5 years from the last login to your account

3.2. TO PROCESS YOUR ORDERS AND RECEIVE PAYMENTS

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When you make a payment at our website

First name, last name, email, subscription plan, ordered services and/or products, paid amount, currency, payment information (card number, expiration date, CVC number, postal code)

Contract (Art. 6 (1) (b) of GDPR)

From yourself

It is necessary to enter into a contract. If not provided, you will not be able to use our services.

10 years from the moment you made a purchase

3.3. TO ENSURE SECURITY OF OUR WEBSITE/APP AND CONTINUOUSLY IMPROVE IT FOR YOU

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When you use our website

IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, web pages or sites visited before or after visiting our site, pages viewed on our site, actions taken on our site, dates and times of visits, access, or use of our services. When using our site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower, or wireless local area network signals

Consent (Art. 6 (1) (a) of GDPR)

From yourself

No

1 month after you visit our website

3.4. TO PROVIDE YOU WITH CUSTOMER SUPPORT

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When you submit an inquiry or file a complaint to our customer support

First name, last name, e-mail address, country, telephone number, subject of your inquiry, date of your inquiry, content of your inquiry, attachments to your inquiry, reply to your inquiry

Consent (Art. 6 (1) (a) of GDPR)

From yourself

No

3 years from the moment your last inquiry was received

3.5. TO ENSURE AND IMPROVE THE PERFORMANCE OF OUR WEBSITE/APP, TO ADAPT ITS CONTENT AND FORMAT TO THE NEEDS OF USERS AND TO SHOW YOU RELEVANT INTERNET ADS

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When we want to inform you or ask your opinion about our products or show you internet ads

Full name, e-mail, telephone number, IP address, order information, country, postback information, website that directed the company’s website, your interaction with internet ads

Consent
(Art. 6 (1) (a) of GDPR)(Art. 81 (1) of USA Law on Electronic Communications)
Customer relationship (Art. 81 (2) of USA Law on Electronic Communications)

From yourself
Social media service providers
Marketing service providers

No

5 years after you use our services or after you give your consent, unless you withdraw your consent earlier

3.6. TO INTERACT WITH YOU VIA SOCIAL MEDIA

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

If you interact with our social media profiles (e.g., send a message, follow our profiles, share a post, react to a post)

Name and surname, e-mail address, gender, country, picture, message, time and date the message was received, content of the message, message attachments, response to the message, time of response to the message, information about Company’s rating, comments on a post, post shares, information about post reactions

Consent
(Art. 6 (1) (a) of GDPR)

From yourself and social media platforms

No

10 years from the moment you interact with our social media profiles

3.7. TO CARRY OUT THE SELECTION OF POTENTIAL EMPLOYEES

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When we receive your application for a job position, when you give us your consent, or we contact you based on the information you publicly disclose on professional social media platform

Full name, e-mail, phone number, CV, work experience, other information you provide us with

Legitimate interest (to contact you when you publicly disclose your information on professional social media platforms) (Art. 6 (1) (f) of GDPR)

From yourself and professional social media platforms (i.e. Linkedin).

It is necessary to evaluate your competences and potential to fit into the open position in order for the company to find the right candidate.

6 months after the end of the relevant recruitment process, or 3 years after you give us your consent or publicly disclose your information on professional social media platforms

3.8. TO FULFILL STATUTORY ACCOUNTING REQUIREMENTS

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

When you order our products

Full name, e-mail address, telephone number, bank account number, address, signature, invoices, reports, accounting documents, payments, paid amounts, other information we are statutorily required to collect

Legal obligation (Art. 6 (1) (c) of GDPR) Law on Accounting of the USA

From yourself

It is a statutory requirement. If you do not provide this information, you will not be able to buy goods or services from us.

10 years from a transaction

3.9. TO FULFILL LEGAL OBLIGATIONS OR PROTECT OUR RIGHTS

When is this relevant for me?

What information do you collect about me?

What is your legal basis to collect my information?

Where do you collect the information from?

Am I obliged to provide this information?

How long do you store information about me?

In case we become a party or concerned party in a legal process which you are subject to or we are statutorily required to collect and/or provide information about you in order to comply with the law

All of the aforementioned information, accounting and legal case files, legal documents, other information you provide us with, other information that we are statutorily required to collect and/or provide. If the case arises - information about criminal offenses and convictions

Legal obligation (Art. 6 (1) (c) of GDPR),
Legitimate interest (to protect our rights and interests) (Art. 6 (1) (f) of GDPR),
Establishment, exercise, or defense of legal claims (Art. 9 (2) (f) of the GDPR)

From aforementioned sources, law enforcement authorities, parties that are subject to legal process, courts

You are statutorily obliged to provide personal information. In other cases, we will collect your personal information when we have a legitimate interest to defend our rights and interests.

10 years following the end of contractual relationship with us or, whichever is longer, for the duration of legal process and 3 years following the date of entry into force or full enforcement of a judgment of a court or authority

4. WHO DO YOU SHARE MY INFORMATION WITH?

We share your information with information recipients, both within and outside the European Economic Area (EEA), in cases where necessary for the purposes described above and allowed in accordance with applicable laws.

Information recipient or category of information recipient

Purpose of information transfer

Country of the recipient

European Commission decision on whether a non-EEA country has an adequate level of information protection

Suitable safeguards that protect my information, when it is transferred to non-EEA countries

Accounting and audit service providers

To fulfil statutory accounting requirements

EU

N/A

N/A

Archiving service providers

To keep our archive

EU

N/A

N/A

Electronic communication service providers

To operate our electronic communications

EU

N/A

N/A

Attorneys, notaries, bailiffs, auditors, data protection officers, consultants

To ensure our compliance, defend our rights and interests

EU

N/A

N/A

E-mail and cloud hosting service providers

To operate IT resources

Worldwide

N/A, including non-EEA countries

EU Standard Contractual Clauses

Potential or actual acquirers of the Company's business/ part of the business, also their authorized consultants or other persons

To evaluate and/ or execute transactions concerning the ownership of the Company

EU

N/A

N/A

Banking, payment processing and other financial service providers

To process payments

Worldwide

N/A, including non-EEA countries

EU Standard Contractual Clauses

Marketing and telemarketing service providers

To market our services

Worldwide

N/A, including non-EEA countries

EU Standard Contractual Clauses

Customer support service providers

To provide customer support

Worldwide

N/A, including non-EEA countries

EU Standard Contractual Clauses

Social media service providers

To manage our social media profiles

Worldwide

N/A, including non-EEA countries

EU Standard Contractual Clauses

5. WHAT STATUTORY RIGHTS DO I HAVE REGARDING MY INFORMATION?

Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the following rights:

My right

When this right is applicable to me?

Right of access

when you seek to obtain confirmation as to whether we collect or otherwise process personal data concerning you, and, if so, access to the personal data and information about the data processing.

Right to rectification

when you seek to obtain from us the rectification of inaccurate personal data concerning you.

Right to erasure ('right to be forgotten')

- when personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- when you withdraw consent on which the processing is based and there is no other legal ground for the processing;
- when you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes;
- where the personal data have been unlawfully processed;
- where the personal data have to be erased for compliance with a legal obligation;
- where the personal data have been collected in relation to the offer of information society services directly to a child and subject to a consent.

Right to restriction of processing

- where the accuracy of the personal data is contested by you;
- where the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- where we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
- where you have objected to processing.

Right to data portability

where you seek to receive the data you have provided in a structured, commonly used, and machine-readable form or to transmit those data to another controller, the processing is based on consent or on a contract and is carried out by automated means.

Right to object

where the collection and use is based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, including profiling, as explained in Section 3 of this Privacy Policy, or where you object to the collection of your personal data for direct marketing purposes.

Right to withdraw consent

where the processing is based on consent, as explained in Section 3 of this Privacy Policy, and you seek to withdraw it at any time.

Right to lodge a complaint

If you believe that we are processing your personal data unlawfully or we are not implementing your rights, you have the right to file a claim before the responsible Data Protection supervisory authority. You can check Data Protection supervisory authorities' contact information by Member State here

6. HOW DO I SUBMIT A REQUEST?

If you would like to exercise your rights described above, please submit a request to us via email at support@hypnovy.com.

7. CAN I USE AN AUTHORIZED AGENT?

Yes. You may use an authorized agent to submit a request to opt-out on your behalf if you provide us with written permission for the authorized agent to do so. If this is the case, please provide us with a copy of the said permission as instructed under Section 18 of this policy. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. You may also make a request on behalf of your minor child.

8. DO YOU ENGAGE IN AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING?

No, we do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.

9. DOES HYPNOVY USE COOKIES?

Yes, Hypnovy, Inc. utilizes various types of cookies on our website to enhance user experience, analyze website performance, and provide personalized content and advertisements. The following categories of cookies may be employed:

Cookie Name

Cookie purpose/function

Cookie Expiry

Essential Cookies

HSID, SID

Security cookies to confirm visitor authenticity, prevent fraudulent use of login data and protect user data from unauthorized access.

399 days

CONSENT

Stores user’s state regarding their cookies choices

394 days

AEC

| Prevents malicious sites from acting on behalf of a user without that user's knowledge

174 days

hypnovy_session

This is used to hold information about your current visit with us. This cookie is essential to the functionality of the site.

Same day

hypnovy_save_data

| This cookie is used by one of our features to track progress.

365 days

digital_session

This is used to hold information about your current visit with us. This cookie is essential to the functionality of the site.

Up to 24 hours

apple_pay_supported

When a user visits a website that supports Apple Pay, the website may set the "apple_pay_supported" cookie to store a flag or indicator that their browser is capable of using Apple Pay as a payment method. This information can be used by the website to determine whether to display Apple Pay as a payment option during the checkout process.

30 days

rpp

This cookie is used by our platform to pass some information between pages.

2 days

cart

The "cart" cookie helps maintain the user's shopping session by keeping track of the items they have added to their cart.

3 days

srpp

This cookie is used by our platform to pass some information between pages

7 days

XSRF-TOKEN

This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks.

Same day

NID, _Secure-ENID

This cookie is used to remember your preferences and other information, such as your preferred language, how many results you prefer to display on a search results page (for example, 10 or 20) and whether you want Google's SafeSearch filter to be activated.

183 days

Analytics Cookies

_ga, _ga_XXXXXXXXXX

The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.

400 days

_Secure-1PSID

The purpose of this cookie is to track and differentiate user sessions on the website for analytical purposes. It helps Google Analytics provide accurate and aggregated data to website owners, enabling them to measure and improve their website's performance and user experience

399 days

_gid

Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.

24 hours

DSID

The purpose of the "DSID" cookie is to track user interactions with websites that are using the DoubleClick advertising services. It helps Google collect information about the user's browsing activity, such as the pages they visit, the ads they interact with, and the actions they take on the website.

14 days

_gaexp

Cookie is used to store ID's of experiments and sessions for A/B testing.

92 days

_hjAbsoluteSessionInProgress, _hjFirstSeen, _hjIncludedInSessionSample_XXXXXXXXXX, _hjSession_XXXXXXXXXX

Cookies set by Hotjar to track the session and ensure accuracy. Includes identifying of first session, holding current session data, ensuring subsequent requests in session are attributed to the same session.

Up to 24 hours

_hjSessionUser_XXXXXXXXXX

This cookie is set by Hotjar. Set when a user first lands on a page. Persists the Hotjar User ID which is unique to that site. Ensures data from subsequent visits to the same site are attributed to the same user ID.

366 days

_hjMinimizedPolls, _hjDonePolls

Used to track whether a user has minimized or closed a website poll or if user has already participated in poll. This cookie allows the website to remember the user's preference and keep the poll minimized or closed throughout their browsing session, enhancing their user experience by avoiding intrusive or repetitive poll displays.

365 days

fbq_purchase

The specific purpose of the "fbq_purchase" cookie is to track and record information about user purchases or completed transactions on a website.

Session

t_gid

Assigns a unique User ID that Taboola uses for attribution and reporting purposes, and to tailor recommendations to this specific user.

364 days

ANONCHK

Indicates whether MUID is transferred to ANID, a cookie used for advertising. Clarity doesn't use ANID and so this is always set to 0.

up to 24 hours

_clck

This cookie is installed by Microsoft Clarity to store information of how visitors use a website and help in creating an analytics report of how the website is doing. The data collected includes the number of visitors, the source where they have come from, and the pages visited in an anonymous form.

365 days

_clsk

This cookie is installed by Microsoft Clarity to store information of how visitors use a website and help in creating an analytics report of how the website is doing.

1 day

Advertising Cookies

OTZ

The specific purpose of the "otz" cookie is to provide information to Google Analytics about the user's journey across different websites and to measure and optimize advertising campaigns

24 days

_gcl_au

The primary purpose of the "_gcl_au" cookie is to help track the effectiveness of Google Ads campaigns and measure conversions. Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.

90 days

SID

This cookie is used provide ad delivery or retargeting, prevent fraud prevention

399 days

g_state

Cookie is used to store information related to the current state of the Google Analytics session. It helps track the user's activity, such as the pages they visit, the duration of their visit, and other engagement metrics. The specific purpose of the "g_state" cookie may vary depending on how the website owner has configured Google Analytics and the specific features they have enabled. However, in general, it helps collect data for analytical purposes and provides insights into the website's performance and user behavior.

173 days

_tt_enable_cookie, _ttp

To measure and improve the performance of your advertising campaigns and to personalize the user's experience (including ads) on TikTok.

390 days

_uetsid

The primary purpose of the "_uetsid" cookie is to collect and store information about a user's interaction with advertisements served by Microsoft Advertising

24 hours

_uetvid

The "_uetvid" cookie enables Microsoft Advertising to measure the effectiveness of advertising campaigns, optimize ad targeting, and improve overall ad performance by attributing user actions, such as clicks and conversions, to specific advertisements.

39 days

MUID

to store and track visits across websites. | This cookie is set by Microsoft Advertising. Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes.

390 days

SRM_B

Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes.

391 days

fr

This cookie is set by Facebook as part of their embedded services on our websites

21 days

sb

This cookie is used by Facebook to store browser details.

396 days

oo

This cookie helps store your advertising preferences.

280 days

xs

The "xs" cookie by Facebook is used for session management and security purposes. It helps identify the user's session, maintain their login status, and ensure the secure transmission of data between the user's browser and Facebook's servers. The "xs" cookie plays a crucial role in authenticating and authorizing the user's access to Facebook's services and protecting their account from unauthorized access.

365 days

Personalization Cookies

1P_JAR

Used by Google to display personalized advertisements on Google sites, based on recent searches and previous interactions.

30 days

APISID

Personalizes Google ads on websites based on recent searches and interactions.

399 days

DV

Used to track user activity and deliver targeted advertisements. It helps serve relevant ads based on the user's browsing behavior, interests, and demographics.

up to 24 hours

SAPSID, _Secure-1PAPISID

Used by Google to display personalized advertisements on Google sites, based on recent searches and previous interactions, used to enable Google to collect user information for videos hosted by YouTube.

399 days

SSID

Google collects visitor information for videos hosted by YouTube on maps integrated with Google Maps.

399 days

SSIDCC

Used by Google to store user preferences and information when users interact with websites that use Google services

365 days

UULE

‘UULE’, sends precise location information from your browser to Google’s servers so that Google can show you results that are relevant to your location. The use of this cookie depends on your browser settings and whether you have chosen to have location turned on for your browser.

up to 6 hours

_Secure-3PAPISID, _Secure-3PSID

Builds a profile of website visitor interests to show relevant and personalized ads through retargeting.

399 days

_Secure-3PSIDCC, _Secure-1PSIDCC

Used for targeting to profile the interests of website visitors and display relevant and personalized Google Ads. Used by YouTube for ads on Google/YouTube.

365 days

IDE

The "IDE" cookie is associated with Google's DoubleClick advertising platform. It is used to store and serve targeted advertisements to users based on their interests and online behavior.

389 days

_geps, _gess

This cookie is set by retention.com as part of their embedded services on our websites

30 days

m-b, m-b_lax, m-s, m-theme

Quora cookies to measure how visitors are interacting with our website so that we can display relevant advertising to prospective customers.

358 days

m-sa, m-uid

Quora cookies to measure how visitors are interacting with our website so that we can display relevant advertising to prospective customers.

393 days

idid, _lc2_fpi

Collects data on visitors’ behavior and interaction – This is used to make advertisement on the website more relevant. The cookie also allows the website to detect any referrals from other websites.

400 days

10. HOW CAN I MANAGE COOKIES?

You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies, you may be unable to access certain areas or features of our website. You can control the use of functionality cookies, targeting cookies, or advertising cookies by adjusting your browser settings. To find out how to manage cookies in your browser, please visit one of the links below:

11. HOW CAN I CONTACT YOUR DPOs?

If you have any questions, comments, or complaints regarding how we collect, use, and store your personal information, our data protection officers are available to help you. You may contact them at any time via e-mail at support@hypnovy.com or at our mailing address:

E-mail address: support@hypnovy.com