Hoyeeh Uk Privacy Notice
Last Updated: 15 December 2022
Hoyeeh is a service run by Cowries Money Limited, a member of the Cowries Money group of companies.
Your data is important. It’s important to us, and we understand that it’s important to you. Hoyeeh is committed to safeguarding your information in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information. If you have any questions, please don’t hesitate to contact us at privacy@Hoyeeh.co.uk.
WHAT INFORMATION WE MIGHT COLLECT ABOUT YOU
Data you give us: We collect information from you when you become a Hoyeeh subscriber, use our service or when you contact customer services. This will include your email address and password, billing address, payment card details and any other information you volunteer to us. We’ll only use this supplementary information to deal with your query or for the purposes explained to you at the time the information was collected. Please note that if you contact us to assist you, to help protect your privacy we may need to verify your identity before we can assist you.
Data we collect automatically: When you use the Hoyeeh service, we’ll collect technical information about your use and browsing of our website, our apps, our advertising, and information about the device you’re using to access the services. For example, we receive your IP address when your device talks to our servers so we can send content to the right device.
Information from other sources: We may also acquire information about you from third parties, for example from publicly available government databases, from specialist data providers (which may include demographic and interest based information about you), or from Hoyeeh partners who make our service available on their devices. We treat all information we acquire about you in accordance with this Privacy Notice.
From time to time we may also collect information about you by asking you to fill in a survey or questionnaire.
HOW WE USE THIS INFORMATION AND OUR LEGAL BASIS FOR PROCESSING
We aim to use your information in ways that are fair and reasonable. The list below sets out the ways in which we might use your information and the legal basis for that use:
Processing necessary to perform our contract with you:
Processing based on our or a third party’s legitimate interests:
If we want to use your data in any way not covered in the list above, we will only do so with your consent.
Aggregate and/or Anonymised Information: We may aggregate or anonymise certain information that we collect from you. Aggregate and de-identified information is designed so that we can’t identify you personally.
DIRECT MARKETING MESSAGES
We will only send you direct marketing about Hoyeeh products and services, unless you indicated during the registration process that you do not wish to receive such messages by sending us an email from the email address you use to register to email@example.com. In addition, you can unsubscribe from receiving such messages by clicking the unsubscribe link in any of our emails or in the account section of our website.
We may from time to time ask you if you are happy to receive marketing information from other Cowries Money group companies or from 3rd parties. If you opt-in to receive such information, we will share your email address with the relevant parties who may use it to contact you with marketing. Please note that such parties act as data controller in relation to use of your data and this Privacy Notice does not apply to such processing.
WHEN WE MAY SHARE YOUR INFORMATION WITH OTHERS
We won’t sell or rent your data to others. We may share your information outside Hoyeeh in the following circumstances:
To other companies in the Cowries Money group:
Hoyeeh has a legitimate interest in effectively managing and administering our service; promoting and marketing our service; improving our service; understanding more about your preferences; and understanding whether you have an Cowries Money Hub account, so that we and Cowries Money can analyse, administer and manage our services and enable you to have the best possible experience when you use our service alongside other Cowries Money services (e.g. the Cowries Money Hub or Cowries Money Hub+). We may share your information with Cowries Money for these purposes. For example, we may share information to understand which customers are on both services, and Cowries Money may recommend to you that the other series of a programme you enjoy on the Cowries Money Hub are available on Hoyeeh. Where Cowries Money acts as data controller for any data shared with them, Cowries Money will use your information in accordance with the Cowries Money Privacy Notice which is available at Cowries Money.com/privacy.
Our service providers: We use a number of third parties to perform business functions on our behalf, such as sending our newsletters, hosting our online services and providing our customer services. We only disclose the information necessary to enable these third parties to perform their services. Our suppliers are contracted to comply with our instructions and we require that they don’t use your personal information for their own business purposes.
Payment partners: We use specialist payment partners to process your payment card information. In processing your payments, they may also use the data for fraud detection and prevention. They’re obliged to remain certified as compliant with the Payment Card Industry (PCI) security standards.
Voucher code partners: We may share your information as necessary with any third parties where you have received a voucher code which is only available to a particular group of people (for example, if we provide a voucher code to employees of a particular organisation, we may share your information with that organisation to validate your entitlement to that voucher code).
Social media networks and other third parties: We (or a media agency acting on our behalf) may share your information with social media networks and other carefully selected third parties for the purpose of promoting our service to you, and other people like you, on their platforms. Where appropriate this is done by hashing or encrypting your information before it is sent to them, after which they can identify whether you are also a user of their platform. To opt-out from having your information used for this purpose please adjust your marketing preferences.
Sale, licence or transfer of all or part of our business, service or assets: If we decide to change or restructure our business or the service we provide we may need to pass your personal information to one of our group companies so we can continue to effectively deliver the Hoyeeh service to you and/or manage Hoyeeh following the change or new structure.
Also, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale or licensing of some or all of our group companies’ assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction may involve us:
(i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.
If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy notice (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.
SERVICE PROVIDERS BASED OUTSIDE THE UK
We use certain third party companies to perform some functions of the Hoyeeh service on our behalf or to provide services to us. These third parties are only allowed access to your information as needed to perform such functions or to provide such services. They’re not allowed to use it for any other purpose.
Some of these third party companies are located, or have servers that are located, outside the United Kingdom. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy notice.
However, please note that the data protection and other laws of such countries may not be as comprehensive as those in the United Kingdom. We’ll only transfer your personal information to a territory outside of the United Kingdom in line with UK data protection laws. The main transfers take place where:
If you want more information about international transfers we make, please contact us.
Any personal information you supply will be treated in accordance with applicable data protection laws including the UK General Data Protection Regulation (the “GDPR”) and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:
HOW LONG WE KEEP YOUR INFORMATION
We’ll keep your information for as long as you use our services and for a period of time after you have stopped using the services for analysis and administrative purposes. We may keep an anonymised form of your account for a longer period, but it won’t be possible to link this data back to you.
Our payment partners will keep certain payment information for as long as required by law; for example for VAT reporting, they may keep your payment card number and part of your address (as evidence of where our services were consumed).
PERSONS UNDER 18
You must be 18 years old or older to create an account with Hoyeeh.
If you’re the parent or guardian of a child who’s aged under 18, and you become aware that your child has provided us with information without your consent, please contact us at privacy@Hoyeeh.com. We’ll delete their information from our records within a reasonable time.
UPDATES TO THIS POLICY
This Privacy Notice may be updated from time to time to reflect changes in law or best practice, or changes in our business practices. Material changes will be clearly highlighted and we’ll take reasonable steps to notify you of any changes that impact on your privacy. The date of the most recent revision will appear at the top of this page. You should check this policy each time you provide information to us.
Hoyeeh as part of Cowries Money Limited is a company incorporated in England, United States and Cameroon. Our registered office is Hereford Walk, Manchester, United Kingdom, SK6 3HD.
COOKIES AND SIMILAR TECHNOLOGIES
Like most companies, we (and our service providers) use specialist web and app technologies. This notice provides general information about cookies and describes how these may be used on Hoyeeh services.
Why does Hoyeeh use these technologies?
Operating our services (strictly necessary cookies): We use strictly necessary cookies and other similar technologies to keep you signed in, to secure our services and your information and for other system administration purposes. Disabling these cookies will result in loss of functionality and may prevent you from being able to access the service. These technologies also allow us to understand how users interact with our service so we can make sure your Hoyeeh experience is as good as possible and to help us improve our service in the future. These cookies collect information about your use of our services, as well as technical information such as your IP address, time of visit, whether you are a return visit, any referring website and other information about your use of our service. These analytical services help us to know how many users we have, which parts of our sites are most popular, what browsers are used (so we can maximise compatibility) and the country or region where our users are located. This enables us to better understand who is using our site and to ensure we are reaching our target demographic, and to improve and tailor our services accordingly.
Performance Cookies: We use Google Tag Manager which records visits to our website and the source of those visits, and which allows us to manage our use of other types of cookies such as the Targeting Cookies described below
Targeting Cookies for Online Advertising: we may also use advertising companies or agencies to serve our online marketing to you elsewhere on the web. These companies use tracking technologies to collect information about your use of our services which they use to target our marketing messages to you, to make sure you don’t see advertising about Hoyeeh once you have subscribed, and to understand how you learned about Hoyeeh. They may also collect information about your online activities over time and across different websites and other online services so that they can better understand your interests to serve you with relevant adverts. Please note that if you do not give us consent to set these cookies, you may still see Hoyeeh advertising, but it will not be personalised to you.
Flashtalking: Hoyeeh uses the Flashtalking platform for ad delivery and campaign analysis, applying both cookie-based and cookie-less technologies to identify devices. Learn more about Flashtalking’s use of data and your choices in their Consumer Privacy statement.
Apps: Our apps collect the advertising identifier provided by your operating system (i.e. iOS or Android). You can learn how to opt-out of mobile app tracking by certain advertising networks through the privacy and/or advertising settings on your device.
Browser settings: Many web browsers automatically accept cookies (and LSO’s and HTML5 storage), but you can usually modify your browser’s setting to decline cookies if you prefer or delete them when you close your browser; you’ll find instructions for this on your browser’s help menu. If you choose to decline cookies, certain features of our services may not function properly or become inaccessible to you. In addition, you may also render some technologies unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt- out cookies that affect your online marketing preferences.
Privacy Preference Centre: You can manage your preferences and withdraw consent in relation to cookies in our Privacy Preference Centre. To access the Preference Centre clear your cookies and refresh our website.
If you have any questions or concerns about cookies used by Hoyeeh please contact us at firstname.lastname@example.org