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Last Updated: October 23, 2015

Privacy Policy

1. Doppler Labs' approach to privacy
www.hereplus.me (the “site”) is a website operated by Doppler Labs, Inc. (we, our, us).  We also operate the Here app (the “app”) through which you can control your Here Active Listening system.

We are committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, use and share information that identifies you or is associated with you (“personal information”) when you use the site and the app (collectively, our “service”).

2. Personal information we hold about you
We collect personal information from you when you voluntarily submit information directly to us or our website. This can include information you provide when you register to use the site, create an account on our site, complete a form, enter competitions through our site, correspond with us, purchase products from the site, subscribe to our email lists or respond to surveys or promotions.

We also collect personal information indirectly from you such as information about the pages you look at on the site or the device you connect to the site with. We may also collect personal information about you from third parties such as other users of the site.

We describe the categories of personal information we collect in more detail below:

  • Contact details: such as your name, your email address, your telephone number and addresses associated with your account.
  • Comments and opinions: such as comments and opinions when you respond to our surveys, competitions and promotions.
  • Private messages to us: private messages you send to us such as email and written correspondence.
  • Information provided by social networks you connect to our service: if you are given the option to connect a social network, such as Facebook, Twitter or Google+, to our service we will collect personal information from the social network in accordance with your privacy settings on that network. The connected social network may provide us with information such as your name, Facebook id, twitter handle, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share.
  • Payment and transaction information: we will keep records of the products and services you purchase from us and the payment method you use for the transaction.
  • Your preferences: choices you make such as notification preferences or choices about how the site is displayed.
  • Website and app login details: where you create an account with us we will hold your user name and password details. Where you are provided with the option to log-in using a social network, for example through Facebook, Twitter or Google+ sign-in, we will not be provided with your password or other account login details for those accounts.
  • Information about how you use and connect to our service

We collect information about how you use our service such as the pages and links you access, the time you access the service and how long you use it for, the website you come to the service from or go to after leaving the service and selections and choices you make when using the service

We collect information about the computer or other electronic devices you use to connect to the service such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

We collect information about how you use the app such as when you use it and how long you spend using it, what functions you use, information about your settings and preferences on the app and application crash logs. 

Typically, the information we collect about how you use or connect to the service is associated with your device and not you as a named individual. However, if you are logged into a registered account this information may also be associated with you directly.

  • Information about your location

Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.

  • Information provided by other users

Sometimes, other visitors to our site provide information that is associated with you. For example, other visitors may provide information that is associated with you when they invite you to use the website, or they order a product to be delivered to you.

  • Information provided by other organisations

Other organizations may provide information that we associate with you where they are lawfully permitted to share it, such as contact details, demographic data, or Internet navigation information.

  • Information from fraud and crime prevention organizations

If fraudulent or other criminal activity is suspected relating to your account, we may be provided with information by credit reference, fraud and crime prevention organizations.

3. How we use your information
We will also use your personal information for the purposes specifically described below:

  • Contact details: we will use your contact details so that we can communicate with you directly about the products we sell and the service we provide and about queries, issues or concerns you or other users have. We may also use your contact details to send you information about products and services that may be of interest to you in accordance with your marketing preferences.
  • Comments and opinions: we will use your comments and opinions to address your queries, issues and concerns and improve our products and services.  We will also use your comments and opinions to determine products and services that may be of interest to you and to send you marketing communications in accordance with your marketing preferences.
  • Payment and transaction information: we will use payment and transaction information you provide to process payment for any product you purchase from us. We may also use the history of your transactions with us to determine products and services that may be of interest to you.
  • Information provided by social networks you connect to our site or our app: if you connect to our service with a social network, we will use the personal information provided by the network to help create an account for you on our service and, where we provide the functionality, we will also use the information provided to assist you in sharing your experiences on our service with your friends, followers or contacts on the connected social network. We may also use the connection between the social network and our service to provide you with updates on the social network that are relevant to any account you have with us or promotion you are taking part in. Such updates will only be provided with your consent, we will not post to your social network or to your friends, followers or contacts without your consent.
  • Private messages to us: we will use private messages you send to us to help us respond to any query, issue or concern you raise.
  • Your preferences: we will use your preference settings for the purpose of providing notifications, displaying the site and following other choices you make about how the site is displayed to you.  We store your Here ‘saved settings’ so that you can load these when you use the Here buds with a new device or retrieve them for use on your existing device.
  • Website and app login details: we hold your user name and password details so that we can keep your account secure.
  • Information about how you use and connect to the online service: we will use this information to help us assess the performance of the service and make improvements to the service based on user usages. We also use this information to present the service to you on your device. We use this information to provide custom, personalized content and information, including advertising.
  • Information about your location: we may use an approximate location to ensure content on the site is relevant to the city, state or country you are using your device in.  We will not collect or track your exact location without your consent.
  • Information provided by other users: we will use your personal information contained in private messages sent to us by other users to respond to any query, issue or concern they raise. We will use your personal information that is contained in forms submitted by other users to contact you, if they indicate you would like to receive a communication from us.
  • Information about fraudulent or criminal activity relating to your account: we will use information about fraudulent or criminal activity relating to your account for the purposes of detecting and preventing fraud or crime.
  • All personal information: will use all the personal information we collect to: (i) monitor and improve the service and our procedures and processes; and (ii) to help us develop new products and services. Our use of your personal information in this way will not result in information that was not previously publicly available being made public on the service. We will also not use information about fraudulent or criminal activity relating to your account in the development of new products and services.

We may anonymize and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the service and developing new products and features.

4. Information we share with third parties
We may share your personal information with the following parties:

  • Companies in the same group of companies as us: our subsidiaries (i.e. any organization we own or control) or our holding company or ultimate holding company (i.e. any organization that owns or controls us) and any subsidiaries they own. These companies will only use your personal information in the same way as we can under this privacy policy.
  • Service providers and advisors: third parties who provide a service to us, for example, we use a third party delivery service to deliver any products you buy to your address. These third parties will only be allowed to use your personal information in accordance with our instructions and will be required to keep your information secure.
  • Selected third parties: with your permission, we may share your contact details with selected third parties so that they can provide you with information about products and services that they believe may be of interest to you.
  • Purchasers of our business: personal information may be disclosed or transferred to buyers or perspective buyers of our business or any of our assets as part of the sale.
  • Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or who we need to disclose your personal information to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of the service but we will make sure no one can reasonably be identified from this information before we disclose it.

5. Marketing and Advertising
Email Marketing - From time to time we may contact you by email with information about our products and services. If you do not want us to send you email marketing, please let us know by sending an email to us [email protected] You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

Where you have given us your permission to do so, we may share your contact details with selected third parties so they can provide you with information about products and services they believe may be of interest to you. If you decide you no longer want us to share your contact details with selected third parties for marketing purposes, you can let us know by sending an email to us [email protected]

App push notifications - You can change your push notification preferences anytime in the account settings for the app.

Online Advertising – We, or our advertising partners, may show advertisements to you on our service or on other websites or apps. To do this we, or our advertising partners, may collect information about how you use or connect to our service or the types of other web pages, social media services, content and ads you, or others who are using the device you connect to our service with, interact with, visit or view. The information collected might also include the IP address of the device you connect to our service.

We, or our advertising partners, use the information that is collected to make sure adverts you see either on the site or other websites or apps (where our partners have advertising space) are more relevant to your interests.

6. Storing and transferring your personal information
International Transfers of your Personal Information: the personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. Some of these jurisdictions offer differing levels of protection in respect of personal information and may, in certain instances, be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is treated securely and in accordance with this privacy policy. By using our service and purchasing products from our service you are consenting to your personal information being transferred to countries outside of the jurisdiction you are in.

7. Accessing and correcting your personal information
You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; and (iii) the right to request the correction of inaccurate personal data we hold about you and to request the blocking or deletion of your personal information where the processing does not comply with local data protection laws.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us [email protected] Please provide as much information as you can about the personal information you are looking for and we will be happy to try and help you find or correct it.

8. Links to third party sites
Our service may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

9. Changes to this policy
We may update this privacy policy from time to time and so you should review this policy periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the top of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

10. Notice to you
If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

11. Contacting us
Questions, comments and requests regarding this privacy policy are welcome and should be addressed [email protected]