Hushkeys Privacy Policy

Last revised: 25th May 2018

This Privacy Policy (“Policy“) describes the manner in which we collect, use and disclose your personal information when you use our Hushkeys platform and services (“Services”) through our website www.hushkeys.com and our online and mobile device apps (together, our “App”). We take the privacy of our App users (“you“) very seriously. We ask that you read this Policy carefully as it contains important information about how we will process your personal data. We may change this Policy from time to time. You should check this Policy regularly to ensure you are aware of the most recent version that will apply each time you access the App. In this Policy, the term “post” includes any action you make to create, upload, post, publish, transmit, send, receive, store or reproduce content or communications to our App, whether publicaly or privately.

1. About us

Hushkeys is owned, developed and operated by Netiqet Labs Ltd (“we“), a company registered in England and Wales. Our company registration number is 09545220 and our registered office is at 20-22 Wenlock Road, London, England, N1 7GU. We are the “data controller” for the purposes of data protection law (i.e. we are responsible for, and control the processing of, your personal information).

2. Information we collect

We collect:

  • (a). information that you give to us;
  • (b). information on how you use our Services and what you do on our App; and
  • (c). information from outside our Services.

(a) Information that you provide to us

When you use our App and Services, we collect information that you choose to give us. When you register with us and set up a Hushkeys account, you will provide us with personal information such as the username you choose, a password and your contact details (such as your email address). You may provide with us additional information that will be public and available to other users, which helps personalise your profile and make it easier for other users to find you. This includes information such as your name, a profile picture and other information that may help to identify you. We will also collect information based around your searches for friends. On registration, for example, you may choose to find friends through the contacts list on your device, another social media platform and/or, manually, through a search of users on Hushkeys. The information we collect from the acts of searching and the results of searches help us provide a better connected service to you.

(b) Information on how you use our Services and what you do on our App

When you use our Services, we collect information on your activities. Examples of the types of information we capture are listed below:

  • How you use Hushkeys: for example, we collect information on which keys you use, which people you interact with most, who you search for and what you look at most in Discover.
  • How you interact with other users on Hushkeys: for example, who you message, when you message, who you interact with most, what you do within your messages and posts (for example, how you use a key). We will also capture information about how other users interact with you. So, for example, if they share content with you, share a key with you, message you or tag you.
  • Device information: We collect information about the device you are using to access our Services, for example information about (i) attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; (ii) device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals; and (iii) connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
  • Who is in your contacts: As a social media platform, Hushkeys is all about bringing friends together to enjoy the experience of using our Services. With your permission, we may access your device’s contacts to access information about your friends so we can connect them with you on our App.
  • Your cameras and images in your library: you can use text or images to send a message or a post on our App. To send an image from your library or to take a new photo we will need to have access to your device’s camera and library. We will process this information for your use within our App.
  • Where you are when you use Hushkeys: Some of our functionality, like adding a location to a key, requires you to share information with us. That location may be where you are or elsewhere. We may collect the information about the use of that location and any interaction with the key attached to it.

We also collect content and information that other people provide when they use Hushkeys, including information about you, such as when they share a photo or video of you or key information, send a message to you or upload, sync or import your contact information. This information could reveal special category information, for example about your gender or religion Please bear in mind that when you comment on another person’s post that person decides the audience who can see your comment. If their audience is public, your comment will also be public. In some cases, people you share and communicate with may download or re-share this content with others on and off our service.

We may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms. We may share such information with law enforcement agencies to help prevent unlawful activity.

We collect information about the people and groups you are connected to and how you interact with them, such as the people you communicate with the most or the groups you like to share with. We also collect contact information you provide if you upload, sync or import this information (such as an address book) from a device.

We also collect data on how you use Hushkeys through regular and systematic monitoring of your behaviour which may include the following:

  • Your IP address
  • The device you use
  • The date and time you visited a particular page and length of time you remained there
  • Date of your last visit
  • Your lens interactions
  • All key data (including the number of keys created, keys used, key requests, key granted/not granted)
  • Your social behaviour whilst within Hushkeys including your posts, reposts, worth it
  • Your sharing activity with Facebook, Twitter and other branded partners we allow you share with
  • Tracking data generated by cookies which track which site you visit immediately after leaving the Hushkeys’ environment. All use of cookies will accord with our Cookie Policy

(c) Information from outside our services

With your consent, we may access information about you from other sources. For example, you may give us consent to access your contacts from a third party’s platform so we can find out if any of your friends or followers on that platform are using Hushkeys. We may also use information from other sources to crosscheck any information you provide to us, for example to verify your identity

3. Meta data

When you create a piece of content, there is often information created with it that tells us where, when and how the piece of content was created. You can add information to this by associating tags with it (for example, you can add a tag to our keys). We will capture and use such information attached to your posts.

4. Sensitive personal data

We may obtain sensitive personal data about you if you post it to the App or otherwise provide it to us. By posting to the App or providing us with such information you signify your consent to our processing it for the purposes listed in this Policy. “Sensitive personal data” means personal data relating to race or ethnicity, political opinions, religious beliefs, trade union membership status, physical or mental health, sexual life, or the commission, alleged commission or conviction of criminal offences.

5. How we will use the information about you

We use personal data collected for the purposes of:

  • providing and improving our services;
  • verifying identities and registering your user account;
  • administration;
  • personalising our service to you;
  • compiling research data;
  • notifying you of any changes to the App or to our services that may affect you;
  • marketing—see the section on Marketing below;
  • security;
  • preventing and detection fraud and other illegal activities; and
  • complying with our legal obligations.

6. Sharing your information

We may share your information in the types of ways set out below with:

  • (a) other Hushkeys users; and
  • (b) third parties.
  • (c) publicaly available information

(a) Sharing with other Hushkeys users and the public

We are a social media platform that enables users to interact with each other. To do so, we will share information about you with other users. For example:

  • your username, name and information about you;
  • who you engage with, who you follow on Hushkeys and other information that will enable other users to understand how they are connected to you, if you have any users in common and whether they would like to follow or interact with you on Hushkeys;
  • we share content you have posted with other Hushkeys users who you have decided to share that content with. You have the choice of giving users outside of your followers’ permission to access your content. This all depends on how you use the key system;
  • there are Hushkeys features you may use that will generate information which we will share with other users. For example, your interaction statistics with games and challenges, keys that you have created and that you have not hidden, and information about who has used your keys.

It is important to remember that when you post content on our App, it means that you are allowing everyone who has (or may in the future have) access to that post to access and use that content and to associate it with you (e.g. your name and profile picture). Depending on the permissions, keys and challenges you have set, this could be (for example) a selected group of friends that you have chosen, users who successfully complete a challenge or any member of the public using our Services. It is important to note that using the “Hushkeys Key” gives everyone using our App, including people who do not have a Hushkeys account, access to your content. You should be mindful of how you share content whilst using our conceal functionality and how you manage the sharing of the keys. Our Hushkeys Key is available to everyone, so any content sent that is attached to this key will be publicly available, including people who do not have a Hushkeys account. If you want to post content about others on our App (including without limitation their image or name) then, before posting, you must have their consent to do this. Other App users may use the App to share content about you with the audience they choose. For example, a friend may share a photo of you, mention you at a location in a post, or share information about you that you shared with them. If you have concerns with someone’s post, please let us know by contacting us. Information you share on our App can be copied (for example, screen grabbed) and used outside of our App. We cannot control that, so make sure you only post content you are comfortable sharing with the public.

(b) Sharing with third parties

To deliver relevant content and information to you whilst using Hushkeys and/or for Hushkeys’ commercial activities, we may share information relating to you with:

  • our agents, contractors, partners, brands and other organisations that we work with such as advertising companies;
  • other social media companies (for example when integrating contacts);
  • law enforcement agencies to help prevent unlawful activity; and
  • if we become involved in a sale of all or some portion of our business to another company, we may disclose your information to that company for purposes related to that transaction.

No data transferred will enable any third parties to personally identify you unless we have sought your specific additional consent to do so. The information will be captured and grouped in a way so as to give non-specific, non-personalised detail about our users. We will not include your content in any advert without your specific consent.

Personal data that we transfer to a third party may be processed in accordance with the policies of that third party but we will undertake due diligence to assure ourselves that the third party’s privacy policies offer the same protection for your data that we offer but it is your responsibility once no longer within the Hushkeys’ environment to check and consent to to the privacy policies of sites visited.

(c) Publicaly available information

By default, the following information linked to your user account will be publicaly available online, including to people who do not have a Hushkeys account:

  • User image (profile image)
  • User profile name
  • User name
  • User’s content (the above attached to a single post)

7. Children’s privacy

Our App and our Services are not intended for anyone under 13. For this reason, we do not knowingly collect information from anyone under 13. However, if we discover that we have unknowingly collected personal information of a child under 13 without parental consent, we will delete this information as quickly as possible. We trust users to declare their age truthfully. If you are aware of someone under 13 using our Services then please contact us.

8. Closing your Hushkeys account

You are free to close your account at any time. Please note this action is irreversible and we cannot restore your account after its closure. When your account is closed your posts and your account profile will no longer be visible to other users. Following closure of your account we may retain such information for a commercially reasonable time for backup, archival, and/or audit purposes. You should keep in mind that information others have shared about you is not part of your account and will not be removed from our App when your account is closed.

9. Closing accounts of deceased users

We recognise how difficult it is to request and action the closure of an account in the event of a user’s death. In the event of a death of a Hushkeys user, please contact us.

10. Consent

By submitting your personal information you consent to the use of that information as set out in this Policy. You may withdraw your consent to receiving direct marketing communications from us at any time (see the section called Marketing below). You may withdraw your consent to our processing your personal information for providing the Services to you at any time by deleting your Hushkeys account (see the section called Deleting your Hushkeys account above), although please note that we may still continue to process some of your personal information to the extent that it is required for us to comply with applicable laws and regulations.

11. Marketing

We may wish to provide you with information about our App or Services that we think may be of interest to you. If you prefer not to receive any direct marketing communications from us you can opt out at any time by sending your request to unsubscribe. You can also opt out of receiving our marketing emails at any time by clicking the unsubscribe link displayed in any of those emails and following the subsequent directions.

12. How we protect your information

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. For example:

  • access to your account is controlled by a unique password that you have created;
  • we store your personal data on secure servers; and
  • payment details are encrypted using SSL technology.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal data transferred from you or to you via the internet.

13. Overseas transfers

We may transfer your personal data to a jurisdiction outside the European Economic Area if in our discretion such transfer is necessary or desirable for our purposes as described in this Policy. Certain of those jurisdictions may not have data protection laws equivalent to those in the UK. By submitting your information you consent to these transfers.

14. Monitoring

We may monitor and record communications with you (such as telephone conversations and emails) for the purposes of compliance and improving our services.

15. Cookies

The App uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.

16. How to contact us

We welcome your feedback and questions. If you would like to contact us, please contact us.