Privacy Policy

You - Privacy & HyPa
HyPa & The Coniferous Multitrade, (“HyPa“, “we“, “our“, or “us“) are committed to protecting your privacy & data security. This Policy sets out how we gather, store, process, share, transfer & use data that identifies or is associated with you (“personal information“) & information regarding our use of cookies & similar technologies. HyPa provides web-based software that allow customers to: create a web-pages, accept payments & get bookings for their tours & activities through a booking engine, create vouchers for customers, get on-page marketing services via our websites (our “Websites“) located at hypa.in (the “Services“). This Privacy Policy applies to our Website & the Services associated with it. Before accessing our Websites or using the Services, kindly ensure that you have read & understood our collection, storage, use & disclosure of your personal information as described in this Privacy Policy. HyPa is the controller of the data regarding the personal information we hold about you.

1. INFORMATION WE COLLECT ABOUT YOU & HOW WE USE IT

We process personal information about individuals that are our customers &, where our customer is a business or similar entity, individuals that are our customer’s employees, agents & similar other representatives. These individuals about whom we collect personal information are referred to as “you“ throughout this document.
We gather personal information about you when you voluntarily submit information directly to us when you access our Websites or use the Services. This can include information you provide when you register for an account, fill in a form, correspond with us via the Websites, phone, chat, email or otherwise, subscribe to our mailing lists, newsletters or any other forms of marketing communications, respond to surveys or use some other feature of the Services as available from time to time.
If you choose not to provide personal information, we may not be able to provide the Services to you or respond to your other requests, in the best of our capacity.
Annexure 1 sets out the categories of personal information we collect about you & how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information & information as to how we determine applicable retention periods.
We also automatically gather personal information about you indirectly regarding your access & use of the Services & information about the device you use to access the Services.
Annexure 2 sets out the categories of personal information we collect about you automatically & how we use that information. It also lists the legal basis which we rely on to process the information, the categories of recipients of the personal information & information as to how we determine retention periods.
We may combine the personal information we collect about you & the information we collect automatically. This allows us to provide you with a personalized and simplified experience regardless of how you interact with us.
We may anonymise & aggregate any of the personal information we collect, including information about individuals that are your subscribers, website visitors &/or customers (so that it does not directly identify you or them). We may use anonymised information for reasons that include testing our IT systems, research, data analysis, improving our Services & researching & developing new products & features. We may also share such anonymised information with others.
CUSTOMER DATA WE MAY PROCESS THROUGH THE PROVISION OF OUR SERVICE
1. Please note that, during the provision of our Services, we may also process information about individuals that are subscribers, website visitors &/or customers of our customers (which we call “Customer Data“).
2. The relevant customer will have its own privacy policy which will apply to Customer Data & any questions should be directed to that customer.

2. MARKETING & ADVERTISING

From time to time only with your consent, we may contact you with relevant information about our Services. Most messages we send will be via email. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.
If you do not want to receive such messages from us, you can always opt out by clicking on the unsubscribe link at the bottom of all our emails. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Services, or technical or security notices.

3. STORING & TRANSFERRING YOUR PERSONAL INFORMATION

Security. We implement appropriate technical & organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. All electronic transaction entered into via our Website will be protected by SSL encryption technology. Where you register for an account on the Services, you are responsible for maintaining your account’s security as more specifically explained in our Terms of Service.
International Transfers of your Personal Information. The personal information we collect may be transferred to & stored in countries outside of the jurisdiction you are in where we & our third party service providers have operations. If you are located in the European Union (“EU“), your personal information will be processed outside of the EU, including in the United States; these international transfers of your personal information are necessary for the performance of our agreement with you in order to provide the Services.

4. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

This section applies if you are located in the EU - In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Right of access & portability. The right to obtain access to & to receive your personal information.
Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, & to object to the processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

5. COOKIES & SIMILAR TECHNOLOGIES

When you use our Service, read our emails, or otherwise engage with us through a computer or mobile device, we & our third party service providers, automatically collect information about how you access & use the Service & information about the device you use to access the Service. We use this information to enhance & personalize your user experience, to monitor & improve our websites & services, & for other internal purposes.
Annexure 2 sets out the categories of personal information we collect about you automatically & how we use that information.
We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, & similar technology (collectively, “tracking technologies”). We may combine this information with other personal information we collect directly from you.
Our Websites use cookies to distinguish you from other users of our Websites. Cookies are pieces of code that allow for personalization of our Websites by saving your information such as user ID & other preferences. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes.
We use the following types of cookies:
1. Strictly necessary cookies. These are cookies that are required for the essential operation of our Websites such as to authenticate users & prevent fraudulent use.
2. Analytical/performance cookies. They allow us to recognise & count the number of visitors & to see how visitors move around our Websites when they are using it. This helps us to improve the way our Websites work, for example, by ensuring that users are finding what they are looking for easily.
3. Functionality cookies. These are used to recognise you when you return to our Websites. This enables us to personalize our content for you, greet you by name & remember your preferences (for example, your choice of language or region).
4. Targeting cookies. These cookies record your visit to our Websites, the pages you have visited & the links you have followed. We will use this information to make our Websites & the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic & usage trends for the Service & to underst& more about the demographics of our users. You can learn more about Google’s practices at https://policies.google.com/privacy/partner s, & view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout .
We may also work with third party partners to employ technologies, including the application of statistical modelling tools, which permit us to recognize & contact you across multiple devices.
Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
The cookies we use are designed to help you get the most from our Websites but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Websites. These settings will typically be found in the “options“ or “preferences“ menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help“ option in your browser for more details.
Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari web & iOS
Deleting cookies does not delete non-cookie technologies such as Local Storage Objects (LSOs) such as Flash objects & HTML5. You can learn more about Flash objects - including how to manage privacy & storage settings for Flash cookies – on Adobe’s website or by clicking here . Various browsers may offer their own management tools for removing HTML5 LSOs.

6. THIRD PARTY DATA COLLECTION & INTEREST BASED ADVERTISING

We participate in interest-based advertising & use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies & other third party services to collect information about your use of our websites & mobile apps over time so that they may play or display ads on our Service, on other websites, apps or services you may use, & on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies, which recognize the device you are using & collect information, including click stream information, browser type, time & date you visited the site & other information. We may share a common account identifier (such as an email address or user ID) with our third party advertising partners to help identify you across devices.
We & our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics & market research.
To learn about interest-based advertising & how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choice s, the DAA’s resources at www.aboutads.info/choices &/or Your Online Choices at www.youronlinechoices.com/uk.Y ou may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (&roid). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoice s & downloading the mobile AppChoices app.
Please note that opting-out of receiving interest-based advertising through the NAI’s & DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Furthermore, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
LINKS TO THIRD PARTY SITES
Our Websites may, from time to time, contain links to & from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies & 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.
OUR POLICY TOWARDS CHILDREN
The Services are intended to be used by adults & we do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information, please contact us using the details below so that we can take steps to remove such information & terminate any account your child has created with us.
CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time & so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the “last modified“ date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
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 our Websites. 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.
CONTACTING US
Regardless of your location, any questions, comments & requests regarding this Privacy Policy are welcome & should be addressed to the Data Protection Officer at privacy@HyPa.in as appropriate depending on how you are using our Services.
This Privacy Policy was last modified on 24 January 2021.

Annexure 1 – Personal Information We Collect of your use of the Services

CATEGORIES OF PERSONAL INFORMATION
1. CONTACT INFORMATION & BASIC PERSONAL DETAILS
  Such as your full name, phone number, postal address, e-mail address, zip code.
  1. How we use it
    We use this information to:
    1. communicate with you, including sending statements & invoices, communications, news, alerts & marketing communications;
    2. deal with enquiries & complaints made by or about you relating to the Services;
  2. Legal basis for the processing
    The processing is necessary for:
    1. the performance of a contract & to take steps prior to entering into a contract;
    2. our legitimate interests, namely administering the Services, for marketing purposes & communicating with users; & to comply with certain legal obligations.
    3. to comply with certain legal obligations.
2. WEBSITE, BUSINESS & MARKETING INFORMATION
  Such as company website, IP address, current email list size, e-commerce software in use, email marketing software, product usage information, demographic data, data about customer’s 3rd party services, other business information (Facebook ad spend, status of business, industry, business goals).
  1. How we use it
    We use this information to:
    1. operate, maintain & provide to you the features & functionality of the Services;
    2. determine relevant advertising / marketing activities.
  2. Legal basis for the processing
    The processing is necessary for:
    1. the performance of a contract & to take steps prior to entering into a contract; &
    2. our legitimate interests, namely administering the Services & for marketing purposes.
3. PAYMENT INFORMATION
  Details such as your credit card information, account information, billing address & related information.
  1. How we use it
    We use this information to facilitate payment for use of the Services & to detect & prevent fraud.
  2. Legal basis for the processing
    The processing is necessary for the performance of our contract with you & our legitimate interests, namely the detection & prevention of fraud.
4. CORRESPONDENCE & COMMENTS
  When you contact us directly, e.g. by email, phone, mail, when you post on message boards, blogs or complete an online form or provide quality survey input, we will record your comments & opinions.
  1. How we use it
    To address your questions, issues & concerns & improve the Services, to determine the products & services that may be of interest to you & to send you news, alerts & marketing communications in accordance with your marketing preferences.
  2. Legal basis for the processing
    The processing is necessary for our legitimate interests, namely communicating with users & for marketing purposes.
5. ALL PERSONAL INFORMATION SET OUT ABOVE
  1. How we use it
    We will use all the personal information we collect to prevent & detect fraud, to operate, maintain & provide to you the features & functionality of the Services, to communicate with you, to monitor & improve the Services, our Website & business, & to help us develop new products & services.
  2. Legal basis for the processing
    The processing is necessary for our legitimate interest, namely to administer & improve the Services, our Websites, our business & develop new services.
CATEGORIES OF RECIPIENTS
As required in accordance with how we use it, we will share your personal information with the following:
1. SERVICE PROVIDERS & ADVISORS
  Third party vendors & other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax & accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Your personal information is never transferred to any third-party for the purposes of remarketing to you.
2. PURCHASERS & THIRD PARTIES IN CONNECTION WITH A BUSINESS TRANSACTION
  Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
3. LAW ENFORCEMENT, REGULATORS & OTHER PARTIES FOR LEGAL REASONS
  Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law & the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Services or Websites; &/or (c) exercise or protect the rights, property, or personal safety of HyPa, our customers or others.
RETENTION PERIOD
For no longer than necessary for the purposes set out & in accordance with our legal obligations & legitimate business interests.

Annexure 2 – Personal Information Collected Automatically

CATEGORIES OF PERSONAL INFORMATION
1. INFORMATION ABOUT HOW YOU ACCESS & USE THE SERVICES
  For example, the website from which you came & the website to which you are going when you leave our Websites, how frequently you access the Services, the time you access the Services & how long you use them for, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, & other actions you take on the Services.
  1. How we use it
    We use this information to:
    1. present the Services to you on your device;
    2. determine news, alerts & other products & services that may be of interest to you for marketing purposes; &
    3. monitor & improve the Services & our business, & to help us develop new products & services.
2. INFORMATION ABOUT YOUR DEVICE
  We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers & applications connected to the Services through the device, information about the server upon which the Services operate, your Internet service provider or mobile network, your IP address.
  1. How we use it
    We use this information to:
    1. enable the Services to be presented to you on your device;
    2. operate, maintain & provide to you the features & functionality of the Services;
    3. monitor & improve the Services & business, & to help us develop new products & services.
  2. Legal basis for the processing
    The processing is necessary for our legitimate interests, namely: to tailor the Services to the user & to improve the Services generally; to monitor & resolve issues; for marketing purposes; to communicate with users; to contact users; & for the detection & prevention of fraud.
CATEGORIES OF RECIPIENTS
As required in accordance with how we use it, we will share your personal information with the following:
1. SERVICE PROVIDERS & ADVISORS
  Third party vendors & other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax & accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Your personal information is never transferred to any third-party for the purposes of remarketing to you.
2. PURCHASERS & THIRD PARTIES IN CONNECTION WITH A BUSINESS TRANSACTION
  Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
3. LAW ENFORCEMENT, REGULATORS & OTHER PARTIES FOR LEGAL REASONS
  Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law & the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Services or Websites; &/or (c) exercise or protect the rights, property, or personal safety of HyPa, our customers or others.
RETENTION PERIOD
For no longer than necessary for the purposes set out & in accordance with our legal obligations & legitimate business interests.