LAST UPDATED: JULY 10, 2018

Hushed is founded on the principle of helping people keep their private communications private without compromise – as they should be. The purpose of this Privacy Policy is to outline AffinityClick Inc.’s commitment towards respecting your privacy and to comply with the applicable privacy laws and associated rules governing how or when any of your personal information is collected, used and disclosed while accessing our services. We know that you take your personal data and information very seriously; and so do we. We strongly encourage all of our users to familiarize themselves with our Privacy Policy to understand any and all circumstances where both non-identifiable or personally identifiable data may be collected or processed while using our services.

By visiting AffinityClick’s website, registering with or using any of AffinityClick’s services, you are accepting and agree to comply with this policy.

1. Introduction
AffinityClick Inc. (“AffinityClick”, “we”, “our”, and “us”) operates several products, services, websites and apps including, but not limited to AffinityClick.com, Hushed.com, and Hushed App. We refer to those products, services, websites and apps collectively as “Services” within this policy. It is AffinityClick’s policy to respect your privacy regarding any information that may be collected while operating our Services. The purpose of this privacy policy (“Privacy Policy”) is to codify our commitment to respecting your privacy and to comply with applicable privacy laws and associated rules governing how personal information is collected, used and disclosed. This Privacy Policy outlines the types of information we collect and receive, the circumstances in which we collect or receive it, and it explains the policies and procedures we have established for its storage, use and in certain circumstances sharing. We are committed to the confidentiality and security of your personal information and to allowing you to request access to, correction of, and deletion of, your personal information.

Your access to and use of the Services is subject to our Terms of Service (“TOS”). Any capitalized terms used but not defined in this Privacy Policy have the meanings provided in the TOS.

2. Consent
By using, registering to or otherwise accessing our Services, you agree to this Privacy Policy and give your explicit, informed consent to the collection, use and processing of your personal data in accordance with this Privacy Policy. If you do not agree to this Privacy Policy or the TOS, please do not visit, use, register to, or otherwise access any of our Services.

You may withdraw your consent at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal may restrict our ability to provide the Services. There are limited circumstances in which we may collect, use or disclose personal information without your consent. They are:

a) when the collection, use or disclosure of personal information is permitted or required by law;
b) in an emergency that threatens an individual’s life, health or personal security;
c) when the personal information is available from a public source;
d) when we require legal advice from a lawyer;
e) for the purposes of collecting debt;
f) to protect ourselves from fraud; or
g) to investigate an anticipated breach of an agreement or a contravention of law.

3. How We Collect Information
We collect information about you from a variety of sources when you access our Services, including:

a) directly from you (when you sign up for or use our Services);
b) from our business partners and service providers;
c) from third party sources; and
d) automatically from devices that you use to connect to our Services.

4. Types of Information We Collect
The amount and type of information that we collect about you depends on the nature of your interaction with our Services. We collect information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with us. We collect the following information based on different scenarios of usage while accessing our Services:

a) Registration/Profile Information
i. when signing up for your account, we collect your email address and password; passwords are hashed and encrypted before being transmitted to our servers; we do not see the clear text version of your password;
ii. when creating a profile on our ‘Hushed Messenger’ service, you are asked to provide us with an avatar name and profile picture which are stored until you delete your associated profile or your account.

b) Contact Information
i. authentication information (e.g. your account’s email address and encrypted password);
ii. communications with us (e.g. interaction with our sales or customer support teams);
iii. when buying phone numbers from certain countries, we may ask you to submit proof of identity and/or address verification information in order to comply with the requirements of local regulations in the territories from which the phone number(s) originate; we may share that information with our third party telecommunication providers in order to fulfill the transaction requirements and provide the phone number to your account; and
iv. we allow you to add other contacts and phone numbers to your app’s address book, this information is stored until you choose to delete the contact information or your account; we do not store or download contacts from your device’s address book.

c) Usage Information
i. like most website and app operators, we collect information about your interactions with the Services, such as which screens or pages you visit, what you click on, when you perform those actions, language preferences, and so on);
ii. message content contained within SMS/MMS segments as well as the source and destination numbers are stored until you delete your message history, associated phone number, or your account;
iii. CDR (Call Detail Records) are stored until you delete the call log, associated phone number, or your account (CDRs contains various attributes of the call, such as time, duration, completion status, source number, and destination number);
iv. voicemail recordings and voicemail greetings are stored until you delete voicemail recordings, voicemail greetings, the associated phone number, or your account; and
v. You are entirely and solely responsible for any information that you disclose or share with other users through our Services. We strongly recommend that you use extreme caution in sharing any personal information with other parties through our Services – AffinityClick is not responsible for any information that you disclose to other parties through our Services.

d) Billing Information
i. payment information is collected by our third party payment providers such as Apple, Google, Stripe or Coinbase, each of which may require you to provide your billing details and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). In most cases, we will have access to transaction reference numbers and/or your billing information pertaining to each payment.
e) Information from Third Parties and Integration Partners
i. we collect your information or data from third parties if you give permission to those third parties to share your information with us or where you have made that information publicly available online (e.g. if you enable service integrations with DropBox or Slack, they may send us your information which they have collected, all of which will be controlled by such third party); and
ii. other sources (to the extent permitted by applicable law we may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks).

f) Log Data
i. we collect log data each time a device accesses our servers, log data includes details about the nature of each access including originating IP addresses, access times, device type, operating system versions, internet service providers, pages you view before and after using the Services, links to third party applications, and hardware and software information.

g) Cookies
i. Our site uses “cookies” which enables us to remember you and understand and save your preferences, a cookie is a string of information that a website stores on your computer, and that your browser provides to the website each time you return. We use cookies to help us identify and track visitors to our sites, their usage of the website, and their website access preferences, to improve our Services. If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using our websites. If you do this, the drawback is that certain features of our websites may not function properly and this may also block cookies for any other website you visit; and
ii. Ads appearing on any of our websites may be delivered by advertising partners, who may also set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.

5. How We Use the Information We Collect
We use your information for the purposes identified in this Privacy Policy at the time of collection or for a purpose related thereto, include to develop and provide the Services. Specifically, we may use your information for the following purposes:

a) verifying identity and authenticating information;
b) registration;
c) payment processing;
d) to send email notifications and reminders related to the Services;
e) providing the Services and operating our business;
f) responding to customer requests and complaints;
g) sending newsletters or other marketing information;
h) establishing and maintaining relationships with our users;
i) optimizing experiences by performing analytics and conducting research;
j) conducting investigations, detecting fraud, abuse, security breaches and other harmful activity;
l) resolving disputes and enforcing agreements and policies; and
m) meeting and complying with legal and regulatory requirements.

6. Information We Share: Partners and Integrations
We may disclose personal information to fulfill the purposes identified in this Privacy Policy, and for purposes related thereto, and to provide the Services, including as follows:

a) within our organization;

b) to help us provide certain aspects of our Services, we use third party affiliates and trusted key partners with whom we enter into confidentiality and data processing terms to ensure that they comply with high levels of confidentiality and best practice in privacy and security standards. Each third party service provider has its own rules and privacy policies and we encourage you to review these rules and policies – in particular we engage third parties to:
i. facilitate payment processing;
ii. facilitate sending customer email surveys or marketing notifications;
iii. manage our sales and customer support services to you;
iv. deliver and help us track our marketing and advertising content;
v. help us provide core features of telecommunications services;
vi. help us track website conversions and success metrics;

c) certain information may be shared with third parties or published when you follow links to third party websites, we do not own or control these third parties and when you interact with them you may be providing information to them directly – such parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and we encourage you to review these rules and policies;

d) information that you choose to share publicly or with others may be indexed through third party search engines – we do not control the practices of third party search engines so you need to be careful about the information you make public;

e) at your request or with your consent;

f) as required by applicable laws and related rules and regulations;

g) in connection with a merger, acquisition or other corporate transaction;

h) We disclose personally-identifying information only to those of our employees, contractors and affiliated organizations that (i) need to know such information in order to process it on our behalf or to provide the Services, and (ii) have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using our Services, you consent to the transfer of such information for the purposes described in this Privacy Policy. We will not rent or sell personally-identifying information to anyone; and

i) If you are a registered user of our Services and have supplied your email address, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with our Services and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.

j) We may collect statistics about the behavior of visitors to our websites. We may display this information, in aggregated form, publicly or provide it to others. However, we will not disclose personally-identifying information other than as described in this Privacy Policy.

7. Retention of and Access to Personal Information
We retain personal information that we collect for 15 days or as long as is necessary to fulfill identified legal or business purposes.

You may request access to your personal information or request to know how we use it or to whom it has been disclosed, subject to limited exceptions prescribed by law. Requests should be made in writing via e-mail to support@hushed.com. We will respond to requests within 30 days or provide notice if we require longer. Fees may be charged to access information, but you will be notified of such in advance so you can choose whether or not to proceed.

8. Security of Personal Information
We are committed to the security of your personal information and we take steps to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal and other risks. We store personal information in a secure location, accessible by designated staff and we only use it for the purposes for which you provide it (as set out in this Privacy Policy).

We use appropriate security measures when we destroy personal information.

We routinely review and update our security policies and controls to ensure ongoing personal information security, though the Internet is not a 100% secure environment so we cannot guarantee the complete security and protection of the transmission and storage of your information.

9. Accuracy of Personal Information
We make reasonable efforts to ensure your personal information is accurate and complete. You may make a request to update, correct, or delete your personal information at any time by submitting a request in writing to support@hushed.com. It is your responsibility to provide updates to your personal information and to maintain its accuracy.

10. Safety of Minors
We encourage parents and guardians to be aware of their children’s online activities. We do not knowingly collect the personal information of Minors (persons under the age of 16 or under a higher age if permitted by the laws of their residence). If you are a parent or guardian and you are aware that your Minor has provided us with personal information, please contact us at support@hushed.com. If it comes to our attention that we have collected personal information from a Minor without verification of parental consent, we may delete this information without notice.

11. Questions and Complaints
You may direct complaints, concerns or questions regarding our compliance with applicable privacy laws and/or this policy to support@hushed.com. If you remain unable to resolve the concern after speaking with a representative of AffinityClick Inc., you may also write to the Information and Privacy Commissioner of Ontario.

12. Changes to the Terms
Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors and users to frequently check this page for any changes to the Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.