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HOMETALK PRIVACY POLICY

Welcome to hometalk.com and the products and services offered by Hometalk, Inc,
together with its Affiliates ("Hometalk") including but not limited to its web
site, applications and features (collectively, the “Site”).  We value your
privacy, and have posted this Privacy Policy to explain what information we
collect from you, how we use it, and your rights in connection with that
information. If you have questions about this Privacy Policy or your Personal
Information, you may contact us at support@hometalk.com. 
 

 This Privacy Policy was last updated as of January1st, 2020. 
 

What Information We Collect From You
 

Any time you visit the Site, and depending on your activities on the Site, we
collect certain Personal Information from you.   

1.       When registering to the Site you shall be required to provide us with:

1.1.    Your name, address and e-mail address. If you choose to login with your
Facebook or Google account, we shall receive the following information from
Facebook or Google: name, email address.

2.       When editing your Hometalk account, you may choose to provide us with
the following information:

2.1.    Upload a picture or import one from your social media profile

2.2.    Country of residence

2.3.    Zip Code

2.4.    Your website domain

2.5.    Any other information you choose to share with us in a form of free text
on your Hometalk account page. We strongly advise you do not include any
personal data in such content.

3.       When using the Site you may choose to provide us with the questions
and/or description of your project in a form of free text, upload pictures,
videos, links and. We strongly advise you do not include any personal data in
such content.

4.       When registering to the Site with one of your social media profile
and/or linking your Hometalk account with your social media profiles, the
Persona Information items provided to Hometalk shall be determined and governed
by the terms of use and privacy policy of the applicable social network. We urge
you to review carefully terms of use of such social network for more details.

5.       When you are using the Site and functions available to you through the
Site, we collect information automatically about your use of the Site, including
– your operating system, browser type and version, browser window size, ISP name
and IP address, referring and exit pages, platform type, date/time stamp of
browsing/logging in/out, number of clicks through our site and where you
clicked.  You may exercise choices regarding the use of cookies from Google
Analytics by going to https://tools.google.com/dlpage/gaoptout. For more
information on this type of data that is collected please see our Cookie Notice
below.

 

You are not obligated to provide us with any of the above information under any
applicable law. You may browse the site without providing any information to us
and in this case we shall collect only the information as per Section ‎5 above,
however you may not be able to enjoy all of the features and functionalities of
the Site and your browsing experience may be compromised, if you do not  provide
these data items. .  

How We Collect Your Information

We collect Personal Information: (a) directly from you,  when you register to
use the Site, uploading your projects fill out forms and interacting with other
Hometalk users; (b) using third party services such as cookies. For more
information please look at the Cookie Notice section below.
 

How We Use Your Information
 

 1.       We use your Personal Information for the following purposes:

1.1.    Operate, maintain, and provide to you with the Site and its features and
functionality.

1.2.    We use the e-mail address to identify you as a user, establish your
Hometalk account, and let you manage your account through the Site.

1.3.    We use your information to send you emails with regards to your
operation on the Site (e.g., account verification, notify you of changes/updates
to features, alerts about your activity (as you define in your account
settings), credentials change, technical and security notices), as well as to
send you marketing communications (please see more details regarding this under
“Marketing Messages” section below).

1.4.    We may use the above information to respond to your requests and
messages, including with respect to your rights as data subject, as well as to
initiate contact with you on issues related to the Site or support and
maintenance issues.

1.5.    To prevent, detect and fight fraud or other illegal or unauthorized
activities, including in contrary to the Site terms of use, guidelines,
acceptable use policy and the like

1.6.    To open a ticket on our customer support system and provide you with
customer service and support.

1.7.    We use the data we gather in an aggregated manner, in order to gain
insight on how you and other users use the Site and try and improve our Site as
well as to plan our marketing and advertisements.

1.8.    To ensure legal compliance – from our side (to legal requirements that
apply to us and to our obligations under the Terms of Use) and from your side
(Compliance with laws applicable to you and with the Terms of Use) and to the
extent applicable, are required to conduct any litigation in relation to the use
of the Site by you.

1.9.     We transfer this information to third parties for valuable
consideration as part of our business model.

1.10.                      We use this information to facilitate the use of the
Site according to its functionality, to allow other users to interact with you
based on your actions in the Site, to encourage you to use the Site, to
establish a community of Hometalk users, increase visibility of users on the
Site, encourage discussion and communication between the users of the Site.

1.11.                      We use this information for the purpose of providing,
developing, enhancing, customizing and improving the Site, based on users’
preferences and usage patterns and interactions with the Site; perform research,
as well as for analytical and statistical purposes (such as analyze trends,
optimize user interface flow); detecting, preventing, or otherwise addressing
fraud, security or technical issues. To provide offers and improve the content
of the Site for each user
 

2.       Our legal Bases for processing

We will only process your Personal Information where we have a legal basis to do
so. The following are the legal bases under which we process your information in
the manners specified above:

2.1. Performance of a contract to which Hometalk and you, the data subject, are
parties. Many of the uses described above are actions that involve processing of
your information in order to meet our undertakings to you and respond to your
requests and indications within the services provided by the Site.

2.2. Legitimate interests: We may use your information where we have legitimate
interests to do so. For instance, we analyze users’ behavior on the Site to
continuously improve our offerings, and we process information for
administrative, fraud detection and other legal purposes.

2.3. Consent – some of the information you provide is based on your consent and
will to provide it. In addition, we may ask you from time to time, through the
Site interface, to provide your consent for specific uses (for example, to
provide your data to third parties for their purposes, add you to our newsletter
or send marketing communications to you in case we have never had any commercial
relations regarding the products or services subject matter of such
communication)
 

How We Share Your Personal Information
 

1.         Sale to Third Parties:  we provide third parties with the following
personal data 1. Hashed email addresses 2.  the fact that you have visited a DIY
site and thus may be interested in related content,  in exchange for valuable
consideration; as part of our business model. These third parties make use of
that data for their own commercial purposes, such as,  further resale and/or
re-targeting (which means generally, offering you advertisements or content
based on your past visits or clicks) 

2.        Service Providers: we employ other companies and people to perform
tasks on our behalf or to fulfill certain services and features on the Site and
need to share your information with them in order to provide the Services. The
categories of third party recipients of the Personal Information from us are as
follows: email campaign automation, marketing automation, social media
advertisement, CRM platform, analytics tools providers, web page building tools,
cloud services, support and maintenance operation tools. Where we use a third
party to process any Personal Information in any way, that third party is under
contractual obligations not to use your Personal Information in any way except
to provide us with the services.

3.         Compliance with the Law: We may disclose your information if we
believe it’s necessary in order to comply with the law, such as to comply with a
subpoena, regulation or legal request, respond to a government request, to
address fraud or security issues, to protect the safety of any person, to
enforce our agreements with you; to investigate, prevent, or take other action
regarding illegal activity, suspected fraud or other wrongdoing or to protect
our own rights or property. If you are located in the EU, we may only do so
based on legal requirements specified above of EU.

4.         Business Transfers: If we are in a bankruptcy, merger, acquisition,
reorganization or sale of assets, your information may be transferred as part of
that transaction to a successor in interest and to the applicable legal
authorities as well as legal counsels and other professional counsels involved
such as accountants, and other officers of the government or of the applicable
judiciary instance.

5.         Anonymized Information: We may provide third parties with aggregated
anonymized information and analytics about our customers and, before we do so,
we will make sure that it does not identify you.

6.         Advertising and Analytics: We may use third parties to serve ads on
the site. Certain third parties may automatically collect information about your
visits to this and other websites, your IP address, the browser you use to visit
the site, and in our emails/communications. The personally identifiable
information (PII) that we capture is an IP address and an email address. When we
share information with advertisers or data partners, the shared information
includes hashed email addresses and cookie data. Our partners may link the
information we share with them to the cookie stored on your browser or device.
Our partners use this information to recognize you across different channels and
platforms over time for advertising, analytics, attribution, and reporting
purposes.  To opt out, please visit here. To opt-out of LiveRamp’s targeted
advertising, please go here: https://liveramp.com/opt_out/. However, for users
for whom GDPR regulation applies (i.e. European Economic Area users), we will
not sell their information to advertisers and/or data partners.

The Site may use Google Analytics, Looker, or other service providers for
analytics services. These analytics services may use cookies and other tracking
technologies to help us analyze users and how they use the Site. The information
generated by these services may be transmitted to and stored by these service
providers on servers in the U.S. (or elsewhere) and these service providers may
use this information for purposes such as evaluating your use of the Site,
compiling statistic reports on the Site’s activity, and providing other services
relating to Site activity and other Internet usage.
 

Data Transfers and Global Processing 
 

Why Personal Data is Transferred?

1.   As we operate globally, we may on occasion allow your personal data to be
accessed and/or processed and from and/or transferred to countries other than
your own location.  We may do this where data is accessed/processed:

1.1. By companies within Hometalk for operational, administrative and compliance
purposes; by our sales, operational or global customer support teams (located in
US and Israel);

1.2. By our service providers, for the purposes we specified above under the
chapter “How we Share Your Personal Information”.

2.   By consenting to the collection and use of your personal information, you
agree to your personal information being transferred and stored in this manner
and for the specified purposes.
 

Our Legal Basis for performing such transfers across boundaries (when we act as
Controllers):
 

1.   Model Clauses. With some of our processors, we use standard contractual
clauses that are binding standards of processing of personal data committed to
contractually by third parties processing information for us and on our behalf,
such standard clauses are approved by the European Commission.

2.   Consent. In the absence of Model Clauses, Your consent. By using the Site,
you agree and understand that your information may be transferred from the EEA
or other countries  in which you may be using the Site, to other countries
outside your own location (including outside the EEA), and specifically to the
USA and Israel. The transfer will be to such third parties as described under
“How we Share Your Personal Information”. You agree to such transfer, and you
understand that data processed in these countries/regions is subject to
different data protection laws, which may sometimes grant lesser degree of
protection that the privacy laws and regulations applicable within the EEA for
example.
 

How Long We Hold Your Personal Data 
 

For Personal Information gathered for specific purposes (such as service
requests), we will keep Personal Information only for as long as it takes us to
fulfil the purpose for which the data was collected and processed.  Other
Personal Information you submit may be kept until you request its deletion.
Please note that de-activating your account does not automatically delete your
data.
 

 If you are an (1) EEA User, (2)California, USA user,  you can request that your
Personal Information be deleted, subject to the GDPR or CCPA provisions (e.g.,
to the extent you have the right under the circumstances in accordance with the
laws applicable to you) by contacting us as described in the section “Your
Rights Regarding Your Information”.

We may however retain and use Personal Information as necessary to comply with
our legal and regulatory obligations, to resolve disputes and to enforce our
agreements, and we may retain and use anonymous and aggregated information for
performance reporting and analytic purposes and for product and service
improvement.
 

Marketing Messages 
 

You can stop receiving marketing messages from us at any time. You can do this
by clicking on the ‘unsubscribe’ link in any email, and by personalizing and
modifying "Email Settings" in your Hometalk account.
 

Your Rights Regarding Your Information 
 

You may have the rights prescribed below in relation to personal data processed
by us, subject to the specific laws applicable to your personal data, certain
limitations and restrictions as set forth in applicable law, and depending on
the lawful basis upon which the processing of your personal data is based.

If you are a resident of California USA, please see a separate section related
to you.

If you are an European Economic Area data subject, all of the following rights
may apply to you.

1.       The right to be informed about how your personal information is being
used.

2.       The right to access the personal information we hold about you.

3.       The right to request the correction of inaccurate personal information
we hold about you.

4.       In some circumstances, the right to request that we delete your data

5.       The right to Restrict processing your personal data

6.       The right to object to processing activities, if the processing is
based on our legitimate interest;

7.       The rights to withdraw consent at any time, if the processing is based
on consent

8.       The right to object to processing of personal data for direct marketing
purposes

9.       In some circumstances, the right to request that we transfer or port
elements of your data either to you or another service provider – if the
processing is based on your consent, and is made by automated means.

10.   The right to file a complaint with your Supervisory Authority (in the EEA,
as prescribed by GDPR). 
 

You may exercise these rights to the extent these rights apply to you by
emailing Hometalk via support@hometalk.com or use any of the contact information
listed below. We will undertake to respond to your request within the applicable
time frame prescribed by applicable law, and in any event we will make efforts
to respond within 30 days of receipt of your request. Although Hometalk will
make reasonable efforts to accommodate your requests, in some circumstances we
may deem your request unfounded or not eligible under applicable law. If that
should happen, Hometalk expressly reserves the right to refuse your request.
Before Hometalk is able to accommodate any request, provide you with any
information or correct any inaccuracies we shall require to verify your identity
by providing us with certain information or identification to ensure that all
data subjects’ privacy is protected.
 

Changes To This Privacy Policy
 

We may change this Privacy Policy from time to time, to reflect how we are
processing your data, including following any regulatory changes or our internal
policies.

If we make significant changes, we will make that clear on the Site or other
services, or by some other means of contact such as email, so that you are able
to review the changes before you continue to use the Site. 
 

Cookie  Notice 
 

A cookie is a small piece of data (text file) that a website – when visited by a
user – asks your browser to store on your device in order to remember
information about you, such as your language preference or login information.
Those cookies are set by us and called first party cookies. We also use third
party cookies – which are cookies from a domain different than the domain of the
website you are visiting – for our advertising and marketing efforts.

More specifically, we use cookies and other tracking technologies for the
following purposes:

 * Assisting you in navigation;

 * Assisting in, login and your ability to provide feedback;

 * Analyzing your use of our products, services or applications;

 * Assisting with our promotional and marketing efforts. (including behavioral
   advertising)

Below is a link in which you can review a detailed list of the cookies we use on
our Website.

You can opt-out of each cookie category (except strictly necessary cookies ) by
clicking on the “cookie settings” button here, however, please note that If you
choose to decline cookies, you may not be able to fully experience all the
features of the Website
 

Notification and Rights of Users who are California Residents Under CCPA
 

1.       Definitions:

1.1.     Business Purpose means a use of your Personal Information for our
operational purposes and such other purposes as disclosed in section 1
hereinabove, which are (1) reasonably necessary and proportionate to achieve the
operational purpose for which the personal information was collected or
processed, or (2) for another operational purpose that is compatible with the
context in which the personal information was collected. For the avoidance of
doubt, using your personal information for marketing to you is not a Business
Purpose.

1.2. CCPA means California Consumer Privacy Act OF 2018.

1.3.     Personal Information means information that identifies, relates to,
describes, is capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer or household, of California
Residents, as more fully defined by CCPA.

2.       The categories of Personal Information we have collected about Site's
users in the preceding 12 months are as follows: the categories listed under
CCPA sections: 1798.140 (o)(1)A, F, G, H, K

3.       The categories of Personal Information we have sold in the preceding 12
months are as follows: the categories listed under CCPA sections: 1798.140
(o)(1)A, F, G, K

4.       The categories of Personal Information we disclosed for a business
purpose within the preceding 12 months are as follows: the categories listed
under CCPA sections: 1798.140 (o)(1)A, F, G, H, K

5.       As of January 1st, 2020, Users who are California residents have the
following rights:

5.1.1.  To request are entitled to request a disclosure of information collected
about them

5.1.2.  To request a disclosure of information sold about them

5.1.3.  To not be discriminated on the grounds of exercising CCPA rights

5.1.4.  To opt out of processing of their personal data (excluding for a
Business Purposes, as defined above).

5.1.5.  To opt out of sale of Personal Information to third parties (you can opt
out right here). 

5.1.6.  To request that we delete personal information that we collected about
the User (subject to certain exemptions prescribed under the CCPA).
 

6.       You may exercise any of the foregoing rights by submitting a request to
us in one of the following ways: by here.; or by contacting out toll-free number
here: (833) 680-0389 you can also write to us at legal@hometalk.com

7.     Pursuant to California Civil Code Section 1798.83, residents of the State
of California have the right to request from companies conducting business in
California a list of all third parties to which the company has disclosed
certain categories of personal information during the preceding year, and the
categories of personal information the company shares with its service
providers. To make such a request, California residents can write to us at
legal@hometalk.com, and include your name and the address to which you would
like us to respond.

8.       Generally, We shall respond to your request within 45 days, which may
be extended by an additional 45 days upon notice to You, accompanied by an
explanation of the reasons for the delay.

 

California and Delaware “Do Not Track” Disclosures

California and Delaware law require to indicate whether We honor “Do Not Track”
settings in your browser concerning targeted advertising. Hometalk adheres to
the standards set out in this Privacy Notice and does not monitor or respond to
Do Not Track browser requests.

Links to other sites

The Site contains links to other sites. Please be aware that Hometalk is not
responsible for the privacy practices of such other sites. We encourage users to
be aware when they leave the Site and to read the privacy statements of each and
every website that collects personally identifiable information. This Privacy
Policy applies solely to information collected and processed by this Hometalk.

How to Contact Hometalk

You can contact us any time by email: support@hometalk.com.

We can also be reached by post: 

Hometalk 

137-139 West 25th St.

10th Floor

New York, NY 10001

United States of America



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