Privacy Policy

HowOrWhat: Privacy Policy

The privacy policies of HowOrWhat, Inc.’s online and mobile applications and websites (Service) explain how HowOrWhat collects, uses, discloses, shares, protects, and uses the information we collect about you, as well as your choices.

This Privacy Policy describes the practices we follow in collecting, using, storing, processing, and disclosing your information, including personal information, in conjunction with your use of our Services.

This Policy and these Terms of Use, except any capitalized terms, shall be interpreted according to the definitions present in the Terms of Use. If you disagree with anything in this Policy or these Terms of Use, you must not use or access the Services.

How We Use and Collect Information

Your information is collected in the following ways:

We collect the following information directly from you:

Please provide us with the following information:

  • When you create an account, or if you correspond with us, we collect information such as your username, real name, birth date, as well as your address, phone number, and email address. We also collect information when you sign up to receive our newsletters.
  • As well, we may keep any messages you send to or through the Service, and maybe they are kept in conjunction with User Content that you post on the Service.
  • You will be able to access the Service using your username if you choose, and your real name, if you choose to disclose it. Your username and/or real name cannot be removed from the Service once published.

The following third parties may provide us with information:

The information you provide may be received from third parties.

  • If you connect or log in through a third-party service, such as Facebook Connect, simply taking advantage of “following,” like,” adding the HowOrWhat application or linking your entire account to HowOrWhat, we may learn certain things about your use of its services.
  • Also included may be the user ID associated with your account (for example, Facebook UID), the access token to utilize that service or any information you have given the third-party permission to share with us, as well as information you have made publicly available.
  • By giving us access to your friends’ lists, we may use and store your friends’ user IDs, and your relationship with those friends, so we can make your experience more social and so we can notify you when your friends join HowOrWhat or when they unfollow HowOrWhat. Before linking or connecting a third-party account to the HowOrWhat Service, you should review the privacy settings of the third-party website and services and adjust them as necessary. You can unlink the account by adjusting the privacy settings of the third-party site or service.

Inviting a friend to use HowOrWhat:

  • Our invitation service allows you to invite third parties directly from the native contacts on your phone, without the need to import the people you’ve already added to the Service and without us keeping any information about them. Using the “Invite friends” feature of HowOrWhat, you agree that we are not storing your contact list. We are not responsible for the charges your phone incurs for sending messages. We do not have access to the communication since it is originating from your account.

Adding friends to the Service:

Depending on how you use HowOrWhat, it may develop a feature by which you can locate your friends that have HowOrWhat accounts by choosing from the contact list, social media sites, or by searching by username.

Choosing to find friends via your contacts list permits HowOrWhat to see if any individuals associated with the information you provide have installed HowOrWhat.

You can search for friends using information obtained from social media sites as part of our Service as long as they are allowed to do so. Choose whether to search by name or username and then type in a name or username in the search box to see if the name appears.

Neither howorwhat.com nor social media sites retain the information in your contacts list or on your friends, and we will not use this information to contact you.

Analytical information:

This analytics information is collected in aggregate form to not any individual user. This analytics information is communicated to us by your browser or mobile device, including the pages you visit on the Service.

Cookies information:

The cookie policy describes how we may send a small text file containing alphanumeric characters to your computer when you use the Service. The cookies allow us to identify your browser and speed up login and navigation through the website. We may track the pages you view, the links you click, and other activities you undertake while using the Service through cookies, and we or our business partners may also receive such information. You can visit our Cookie policy page for more.

  • You can remove persistent cookies by following your web browser’s instructions. Persistent cookies are added to your computer’s hard drive for future visits.
  • Cookies that last longer than a browser session prevails over temporary cookies. You can alter your browser settings to reject cookies or to indicate when a cookie is sent, but some features of the Service may not work properly if cookies are disabled.

Information about the logfile:

While you use the Service, our servers automatically store web request data, IP addresses, browser types, landing pages, pages viewed, and other information in log files.

Information about clear gifs/web beacons:

We may use clear gifs to track our users’ online activity. These include tracking what pages they visit on our site, what emails they open, and which links they click. This information allows us to enhance the quality of reporting and improve the Services.

Device identifiers:

Mobile devices (including but not limited to smartphones or tablets) that connect to the Service may access, collect, monitor, and store the unique identifiers of the devices (such as UUIDs). Device identifiers are data structures that uniquely identify your devices.

We may use a device identifier to give us information about how you browse the Service and use it. The device identifier may be published and stored on the device hardware, software, or operating system.

Some features of the Service may not work properly if your device identifiers are disabled or impaired. A device identifier may remain persistent on your device to enhance your navigation through the Service.

Geolocation information:

Location data may be accessed, collected, monitored, and/or stored remotely when using the Service by or through a mobile device. Location data may communicate to us information about your usage of the Service through viewing and interacting with it. When location data is disabled or impaired, some features of the Service may not function correctly. This is especially true for location-based services.

Communications in marketing and business:

Your email address is used by us to communicate directly with you via email. We may deliver newsletters, promotions, and special offers to you via email. Please follow the instructions in the body of each commercial and marketing communication we send you if you do not want to receive such emails. To opt-out, you can email us at [email protected], or you can follow the unsubscribe instructions in the messages we send you.

Before sending certain materials to you, we may request your permission before sending them to you. We use your information to communicate with you about the Service (e.g., account verification, reminders and confirmations of purchases, changes to features, and security notices) before sending them to you. If you are on HowOrWhat, you may be “found” based on the information you provide for finding friends (see above “HowTo Find”).

Information we collect about you used for certain services:

The information we collect, including cookies, log files, device identifiers, location data, and clear gifs, is used or may be used for the following purposes:

  • As we visit the site many times, it is necessary to remember certain information in order not to enter it again.
  • We also provide customized, personalized information and content.
  • We monitor and deliver our service to ensure it features how we intended;
  • Monitor metrics such as traffic volume, demographics, and visitor numbers.
  • Diagnostic or solution of technical problems;
  • If you sign in to your account, you will be able to access your information efficiently.
  • To display advertisements to you, we collect information from your browser or device.
  • Your mobile devices will automatically receive updates for the HowOrWhat app.

Information Sharing

The following list of entities may receive your Personal Information if you choose to use our Services:

  • The Service may provide Business Partners and Trusted Users access to your information to perform certain functions. Our Terms of Use explain how you may grant certain Users administrative rights to monitor and provide certain functions.
  • Our newsletter will be sent to you through Mailchimp. To learn more about how Mailchimp handles and safeguards your personal information, check out Mailchimp’s privacy policy.
  • The Services are provided by an assortment of third-party organizations and individuals (Service Providers), including web hosting companies, companies focused on analytics and other professionals who provide technical support.

The third-party Service Providers may access your personal information only for the limited purpose of operating, providing, and marketing our Services. They are restricted from using your information for any other purpose.

In some cases, we may require third-party service providers to protect the information you provide to us, including the personal information we collect as part of the service. We make reasonable efforts to ensure these third parties are required to do so.

Our Company’s legitimate interests in providing you with our services justify the legal basis on which we share information with our Service Providers. If we receive information from a Service Provider that is being improperly used or disclosed, we will take commercially reasonable steps to stop or correct it.

Service providers often play important roles in helping us operate and secure our services, so we need to engage these companies to provide them to you.

We have a legitimate interest in working with service providers to improve our services, for instance, to research how we can better serve our users. In these cases, service providers don’t strictly need to be part of our services, but they do help us make them better.

Information about third-party advertisements that we may use on the Service and information we may provide to them can be found below.

There is an opportunity for users to post User Content:

Users can post User Content that they voluntarily disclose to HowOrWhat. This content can be publicly viewed and cannot be removed other than at HowOrWhat’s sole discretion.

It is not required by Us to remove User Content from web pages since copies may remain viewable for various reasons, including on cached and archived pages of the Service, on other websites that republish Us, and if other Users copy or save that information.

Please do not submit User Content to HowOrWhat if you do not want it to be seen by the public. Once publicly presented, your username and real name will not be able to be changed.

Your IP address can be seen by:

The Service can identify your contribution if your IP address is published along with your User Content while you are not logged in. A few trusted users who have administrative rights on HowOrWhat can check IP addresses on behalf of HowOrWhat users to spot abusive behavior, as well as third parties, such as an advertiser, video provider, social network, or another third-party web service.

Who can see your Email address?:

If you provide an email address, your address will be shared with HowOrWhat and members of the HowOrWhat community. Additionally, if you reply to another member or participate in group activities, such as meetups, your email address will be shared when well.

Additionally, some email addresses, such as [email protected] forward to an address assigned to Trusted Users, who will reply to the email using your email address.

What happens if the control changes:

The company may also sell, divest, or transfer its assets, services, businesses, and your information (including your name, email address, and User Content) as part of the transaction. Similarly, we may also sell, assign or otherwise transfer your information as part of a corporate transaction, such as a merger, acquisition, bankruptcy, dissolution, reorganization, or liquidation.

The information we collect about you is shared in the following manner:

Among the common methods used to gather this information is the use of cookies, log files and device identifiers, location data, and clear gifs (such as anonymous use data, the number of clicks and referring URLs used, platforms, etc.). Our company may also aggregate or otherwise remove all personally identifiable information from data, which we share aggregated, anonymized data with third parties for the purposes described above in “How We Collect and Use Information.”

Ads on HowOrWhat:

The information you give us may also be shared with business partners to find out whether ads may be of interest to you based on your location, browser, cookie data, and other information relating to your use of the Service. Third-party ad servers or ad networks are allowed to serve ads on HowOrWhat. These vendors use technology to display the ads and affiliate links you see on the Service directly to your browser or mobile device, and when they do so, they will record your IP address.

The companies may also collect information using technologies like cookies, JavaScript, device identifiers, location data, and clear gifs (see above) to measure the effectiveness of our ads, personalize your experience on the Service, and tailor advertising content.

Google, for instance, uses DART cookies so it can deliver ads to you through the Service. Google and its partners can use the DART cookie to send you ads based on your previous visits to the Service and websites you may have visited in the past. If you delete your cookies from advertising networks, you can delete those from the Service as well. Advertising networks may send you tailored ads through other mechanisms. Using our Service and NAI-certified websites, you can opt-out of Google’s DART cookie and other cookies placed by ad networks with the Network Advertising Initiative certification. However, opting out of these cookies does not apply to networks without the NAI certification.

HowOrWhat or our advertising partners may determine the target audience for a specific ad (e.g., based on demographics or other interests). HowOrWhat serves the ad exclusively to the designated audience and would only provide anonymous data to the advertiser. You may be determined to be the target audience by responding to one of these advertisements. We may embed code from third parties to enhance your experience or to measure the effectiveness of the Service, for example:

  • Facebook
  • Twitter
  • Pinterest
  • Google
  • YouTube

These third parties may collect information about you, including IP addresses, cookies, in ways outside the control of HowOrWhat.

You may need to check the respective privacy policies of such third parties for more information and we have no control over their activities. Please contact these third parties directly for more information.

Keeping and Protecting Your Information

Processing and storage:

HowOrWhat or their subsidiaries, affiliates, or service providers may store and process the information you supply on the Service in the United States or any other country in which they maintain facilities.

The information HowOrWhat collects from you, including your personal details, may be transferred to affiliated entities or third parties across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you live outside the U.S. or in another region with laws that govern data collection and use different from those in the European Union, you should consider using a different browser.

Your consent to such transfers and the use and disclosure of the information as described in this Privacy Statement are given to HowOrWhat or its parent, subsidiaries, affiliates, and service providers located in the United States other countries.

Safeguarding your information:

HowOrWhat guarantees the integrity of all information collected through the Service and uses commercially reasonable safeguards to keep it secure.

You must keep your unique password confidential for your own protection, and only authorize people to access your email communications. To protect your privacy and security, we may verify your identity and ask you for a unique password before giving you access to your account.

You may also affect the information on the Service by changing the functionality of third-party services you add to the HowOrWhat Service, such as social networks; HowOrWhat will not be responsible for changes to the functionality of third-party services you add to HowOrWhat.

Compromise of information:

If the information under our control is compromised, we may take reasonable steps to investigate by applicable laws and regulations.

Your Information: Your Choices

The information about your account and the email communication preferences are under your control. You can update your details at any time and opt-out of promotional email communications by visiting your account’s profile settings.

The Service will remove you from all email communications as soon as possible. It will not continue to send you service-related information (such as account verification, purchase acknowledgment, billing confirmation, changes to service features, technical and security notices).

If you do not wish to be tracked or advertised to:

Occasionally, it may not be possible to delete or disable tracking mechanisms on mobile devices. Please consult your mobile device or browser’s technical instructions. If you disable cookies and/or other tracking tools, HowOrWhat and its business partners will no longer be able to track your browser’s activities when using the Services or for making targeted advertisements. However, doing so may prevent access to many of the features offered through the Service. You can contact us directly at [email protected] if you have any questions about opting out of the collection of cookies and other tracking/recording tools.

Information we keep about you:

For the avoidance of doubt, any information you choose to make public gets permanently stored at HowOrWhat. If your account is terminated, HowOrWhat retains your private profile information for backup, archival, or audit purposes.

Children’s Privacy

Children under the age of 13 are not permitted to register as Users or use parts of the Service. If We Learn That We Have Collected Personal Information Without Verified Consent from a Child Under 13 We Will Delete That Information As Soon As Possible. Please contact [email protected] if you are concerned that any information we have maybe about or come from a child under 13.

Children under the age of 16 living in the EU are not targeted by our Services and their content. HowOrWhat does not knowingly collect or solicit any information from children under the age of 16, or knowingly allows such children to register as Users. Please contact us at [email protected] if you believe we might have information about an EU resident under 16 without verification of parental consent. If your information is found to be data related to an EU resident under 16, we will have it deleted ASAP.

Additional Information and Links

It is not our responsibility to control the practices employed by websites or services that may be linked to or from the Service, including information or content contained in those websites or services. If you use a link to go to another website through the Service, our Privacy Policy does not apply to those websites or services.

In addition, you agree that we are not responsible or in control over any third-party websites or services to which our website has links or advertisements, including those you know about from our website.

This Privacy Policy does not apply to any information we collect other than through the Service. You do not need to follow this Privacy Policy if you are using third-party services (such as Facebook, Google groups, or an IRC chatroom) and allowing those services to access your User Content.

Right to Privacy in the EU

To the extent we process personal data of individuals within the European Union, we are legally entitled to do so on the following legal bases:

(a) For more information about our legitimate interests and how we pursue them, see below. Providing the Services, conducting commercial research, developing, maintaining, personalizing, ensuring the security of our databases, building our reputation, and protecting our assets, are some of our legitimate interests. We may use your information to resolve disputes, investigation, and respond to inquiries or complaints about the Services.

(b) The express consent of the individual concerned. If you give us your personal information and agree for us to use it;

(c) We comply with our contractual obligations with you as detailed in our terms and conditions of service whenever possible.

(d) In cases where it is necessary, by the legal obligations which we have.

According to EU law, users have the following rights:

(a) Their right to confirmation of whether their data has been processed, what purpose that processing serves, who has received their data, how long their data has been stored, and whether automated decision-making processes involve their data.

(b) The right to require us to rectify inaccuracies within a reasonable time frame;

(c) When we processed your information based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent makes the processing lawful before it was withdrawn;

(d) Your right to have your information erased. Under certain circumstances, you may request that your information be deleted when:

(I) About the purpose for which the information was collected, it is no longer required.

(ii) The other factors described in the sections of this policy describing the legal basis for processing your information do not apply if you withdraw your consent to its processing.

(iii) We may process personal data solely on basis of our legitimate interest described above (the other legal grounds don’t apply) if you object to the processing of your personal data and there is no overriding legitimate ground for us to do so.

Our policies require us to inform all third parties of our requests for erasure or rectification of your information; when data was disclosed to a third party, we will take all reasonable measures to meet your requests;

(e) If you provide us with your express consent, our processing of your data will be limited to protecting your rights or those of another individual or entity, or to avert danger to the public.

(f) Under certain conditions, you may be entitled to receive data that we process on your behalf or to fulfill a contractual obligation in a structured, commonly used format that is machine-readable.

(g) Objection to the processing of personal data in the following situations:

(I) Unless we have compelling legitimate grounds that override your privacy rights and interests when the processing of your information consists solely of the ‘legitimate interest’ basis, we may be legally required to stop processing it; or

(ii) Our processing of your information for direct marketing purposes will immediately cease.

(h) Any EU member state where you reside has the authority to handle complaints about data protection.

Several restrictions and exceptions apply, including where the data are used for statistical or scientific research purposes, and exercising these rights would hinder or hamper the achievement of such purposes.

The California Privacy Rights

Information about the personal information we collect and California residents’ rights under the Consumer Privacy Act is provided in this section. We collect and retain personal information in the public domain that is available to the public.

HowOrWhat collects different types of Personal Information when customers use the service. Depending on when a user accesses or uses the service in the last 12 months, we may collect the following types of Personal Information:

Names, postal addresses, email addresses, IP addresses, or other identifiers.

The information on our site is not collected by us and may have been provided only by you. We do not collect information about protected characteristics such as race, color, national origin, citizenship, marital status, medical conditions, physical disabilities, or sexual orientation.

A consumer’s interactions with websites, applications, or advertisements retrieved from the Internet or other similar network.

Geolocation data (such as IP addresses).

The “HowOrWhat Account” section details how we collect and use personal information such as demographic information, visual information (for instance your profile pictures), and personal interests. For more information please follow the link to the “HowOrWhat Account” section on our site. To stay informed about how your Personal Information is used, please send an e-mail to [email protected] If you cannot provide Personal Information, you may opt-out of receiving such information. This table shows how HowOrWhat disclosed Personal Information to third parties for business purposes.

The HowOrWhat Service may share certain Personal Information with third parties for advertising purposes by your right to opt-out of those sales. We may also sell certain Personal Information to third parties for delivering targeted advertisements. Please click here to opt-out of certain disclosures by third parties: Do Not Sell My Personal Information. Children under the age of 16 are not knowingly shared with third parties without parental consent.

Your Rights as a California Resident

Consumers in California can exercise the following rights under the California Consumer Privacy Act (CCPA) as of January 1, 2020:

  • You are entitled to know what categories of Personal Information we collect.
  • You have a right to know precisely what information we collect about you
  • Delete Personal Information at our discretion (once other exceptions are met)
  • Personal Information must be made available to you in the proper format for you to transfer it to third parties.
  • Personal Information about you may not be sold or rented, released, disclosed, disseminated, made available, or otherwise disclosed to another business or third party for money or in exchange for something of value.
  • Personal Information is protected by a lawyer who can sue if it is breached.

The ability to access certain information and transfer data

  • Our company will disclose to you any Personal Information it has collected about you during the past 12 months upon receipt of, and confirmation of, your written request.
  • Information about you that we may collect.
  • We collect Personal Information from a variety of sources.
  • This information is collected or sold for business and commercial purposes.
  • We share Personal Information with the following categories of third parties.
  • You can see which Personal Information we collected from you.
  • Your Identity and Personal Information would be disclosed on two separate lists if we “sold” your information or shared it for a business purpose.
  • Your Personal Information will be “sold” to specific categories of recipients, and we will identify each recipient’s “purchased” Personal Information categories.
  • The information categories that each recipient acquired from us if we disclosed your Personal Information for a business purpose.

Right to request deletion

Upon receipt of your request, we will delete your Personal Information from our records, unless an exception applies. Once we receive and confirm your request to delete your Personal Information, we will delete it from our records.

If we or our Provider(s) need to retain the information, we might deny your deletion request:

  • If we need to collect Personal Information to complete a transaction, provide you with good or services you requested, taking reasonable anticipatory steps as part of our ongoing business relationship, or otherwise fulfilling our contract with you;
  • An incident of security occurs when malicious, deceptive, fraudulent, or illegal activities are discovered, or when someone responsible is prosecuted.
  • Errors in the software are identified and repaired to ensure that the intended functionality is achieved.
  • To exercise one’s right to free speech, protect another consumer’s right to freedom of speech, or take advantage of another legal right;
  • This law (1546 et seq.) mandates that electronic communications be private.
  • Only allow internal use that is based on the relationship you have with us and reasonably aligned with consumer expectations.
  • To fulfill legal obligations; or
  • Other legal and internal uses that are compatible with your context that require the information (each an “Exception” in the “Alternatives” category).

Non-Discrimination

Our policy is not to discriminate against you for exercising any of your CCPA rights. Unless you have given written consent, we won’t:

We may withhold goods or services from you.

  • If you do not pay the price or rate listed for your goods or services, you will suffer penalties or receive discounts.
  • Ensure better products or services for you.
  • The price and quality of goods or services may be different or the price and rate may be different.
  • The CCPA does allow us to offer you certain financial incentives that may result in a greater range of prices, rates, or levels of service quality. While we do not currently offer any such financial incentives, we may do so in the future.

The right to obtain access, transfer, and deletion of data

If you wish to exercise your rights, please contact us as follows:

A request to access Personal Information can be made only by you, or by someone authorized by you, or on behalf of your minor child. If we are unable to verify your identity or the identity of the person making the request or confirm the information relates to you, we cannot respond to your request.

In a 12-month period, you may only request access or data portability twice. To do so, the request must comply with:

It is your responsibility to provide us with sufficient information to reasonably verify the subject’s identity or an authorized representative of that subject.

Details are needed for us to be able to properly understand, evaluate, and respond to your request.

Creating an account with us is not necessary to submit a request; we will only use the Personal Information provided in a request to verify the identity or right of the requestor.

Agents authorized by you

A representative authorized by you can request disclosure on your behalf, according to the CCPA.

Timeliness and Format

The response will be issued within forty-five (45) days after our receipt of your request. If additional time is required, we will let you know in writing within ten (10) days. We will deliver the response electronically or by mail, at your request. When you request data portability, we would provide your Personal Information in a format that allows it to be easily transferred from one company to another, if applicable. If we determine that a fee is warranted, we will explain our decision and provide you with an estimate of costs before we complete your request. We do not charge for responding to your request unless it is excessive, repetitive, or manifestly unfounded.

Privacy and the Use of Personal Information

You will find your information shared with third parties in the section titled “Sharing of Your Information.” In the sub-section titled “Ads on HowOrWhat,” you’ll learn about your personal information being sold. The HowOrWhat Service may use information such as your location, browser, cookies, and other data to deliver targeted advertisements. If you do not wish to have your information used for this purpose, please click here: Do Not Sell My Personal Information.

Application

In this Privacy Policy, we refer to personal data, meaning data that can be used to identify an individual. This does not apply to data that cannot be directly or indirectly linked to an individual (for example, anonymized information, or aggregated information that has not been used to derive personal information about you). If you provide personal data to us, we reserve the right to aggregate and remove anonymized data from such databases and then use this anonymized and aggregated data in any way we see fit, including publishing it and sharing it with third parties.

You can reach us using the following information

Contact us by sending an email to [email protected] with any questions regarding this Policy or the Service.

Help and General Questions

Advertising inquiries:

Snail Mail

HOWorWhat, Inc.
Al Qouz 1 Dubai
United Arab Emirates

Press Inquiries

Community Liaison

Changes to Our Privacy Policy

Our Privacy Policy may be updated periodically to reflect changes in our business and practices, so please make sure to review this page regularly. Whenever we update our Privacy Policy, we will alert you of the change and update the ‘last modified date.

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