Privacy Policy

HesTopics provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information received from users of  HesTopics ’s website, located at the domain  HesTopics .com (the “ HesTopics  Website”).

Please note that this Privacy Policy only applies to the  HesTopics  Website.

Information Collection and Use

It is not necessary to provide  HesTopics  with your personally identifiable information to use the  HesTopics  Website, and  HesTopics  does not collect personally identifiable information in connection with the operation of the  HesTopics  Website. If you contact  HesTopics  by email through the  HesTopics  Website,  HesTopics  may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to  HesTopics  in your message, to respond to you.  HesTopics  treats this information as it would treat any other unsolicited business correspondence, and has no obligation to keep this information confidential, nor to take any security measures to protect this information.

When you visit the  HesTopics  Website,  HesTopics ’s servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting. For most users accessing the Internet from an Internet service provider, the IP address will be different every time you log on.  HesTopics  uses Log Data to monitor use of the  HesTopics  Website and the services we offer via the  HesTopics  Website and for the  HesTopics  Website’s technical administration.

Cookies

Like many websites,  HesTopics  also uses “cookie” technology to collect additional website usage data and to improve the  HesTopics  Website and the services offered via the Web Site. A cookie is a small data file that  HesTopics ’s servers transfer to your computer’s hard disk.  HesTopics  does not use cookies to collect personally identifiable information. However, IP addresses are collected by the use of cookies.

 HesTopics  mainly uses “session cookies”, which enable certain features of the  HesTopics  Website and services offered via the  HesTopics  Website, to better understand how you interact with the Web Site and services we offer via the  HesTopics  Website, to monitor aggregate usage by our users and web traffic routing on the  HesTopics  Website, and to improve the  HesTopics  Website and services offered via the  HesTopics  Website. Session cookies should be deleted from your computer when you disconnect from or leave the  HesTopics  Website.

 HesTopics  also uses a persistent cookie that stays on your computer after you leave the  HesTopics  Website, for the sole purpose of ensuring that you receive a variety of  HesTopics  content (also called “frequency-capping”).

Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

Information Sharing and Disclosure

 HesTopics  cooperates with government and law enforcement officials or private parties, to enforce and comply with the law.  HesTopics  may disclose any information about you to government or law enforcement officials or private parties as  HesTopics , in its sole discretion, believes necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of  HesTopics  or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

If any or all of the assets of  HesTopics  are acquired by, or merged with another entity,  HesTopics  will share with this entity some or all of the information collected through the  HesTopics  Website.

Security

Because  HesTopics  does not collect any personally identifiable information from the  HesTopics  Website,  HesTopics  does not take any specific security measures to protect the information we do collect.

Links to Other Sites

The  HesTopics  Website may contain links to other web sites (“Linked Sites”) operated by  HesTopics  or third parties. Linked Sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. This Privacy Policy addresses only the use and disclosure of information that  HesTopics  collects through the  HesTopics  Website. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them.  HesTopics  does not exercise control over third party Linked Sites. Your use of any Linked Site operated by  HesTopics  is subject to the terms and conditions provided by  HesTopics  for such Linked Site.  HesTopics  encourages you to read the privacy policies or statements of the other websites you visit.

Our Policy Towards Children

The  HesTopics  Website is not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided  HesTopics  with personally identifiable information without their consent, he or she should contact  HesTopics  at [email protected] HesTopics .com. If  HesTopics  becomes aware that a child under 13 has provided  HesTopics  with personally identifiable information,  HesTopics  will remove such information from our files.

Changes to this Privacy Policy

 HesTopics  reserves the right to change this policy at any time without prior notice. Any changes to this policy will be posted here. You are advised to consult this Privacy Policy regularly for any changes. If you have any questions or comments about this Privacy Policy, please contact us at [email protected] HesTopics .com.


 HesTopics  Widget Data Protection Summary

This  HesTopics  Widget Data Protection Summary (this “Summary”) will help to explain the practices regarding the collection, use and disclosure of your personal data / personal information by HesTopics in connection with the  HesTopics  widget appearing on third party websites. This Summary uses the term to “personal data” and “personal information” interchangeably, and in both cases, refers to the broad definitions of data concerning natural persons under both European and California privacy law.

The Purpose Of the  HesTopics  Widget and Legitimate Interest for this Processing

 HesTopics  and the publishers (“Publisher”) of one or more websites you visit (“Publisher Website”) have a commercial arrangement for  HesTopics  to provide the Publisher with javascript code that displays the  HesTopics  widget (“ HesTopics  Widget”) displaying content in which you may be interested. In order for  HesTopics  to do so, it must collect and process a limited amount of personal data and place a cookie on your browsing device.

Data Collected by the  HesTopics  Widget

The  HesTopics  Widget collects only the following data:

• the IP address of the device which displayed the  HesTopics  Widget

• the user agent (what kind of device and browser) which displayed the  HesTopics  Widget

• the identity of the Publisher Website on which the  HesTopics  Widget was displayed

• the content links you clicked on (if any), which is recorded in a cookie stored on a browser device along with other cookies containing an identifier for the Publisher Website on which you viewed the  HesTopics  Widget, and an identifier for the precise version of the  HesTopics  Widget you were viewing

California consumers may refer to the table at the end of this  HesTopics  Widget Data Summary to see this data identified by the categories of personal information required by the California Consumer Privacy Act of 2018 (the “CCPA”).

The  HesTopics  Widget Cookie

• The “ HesTopics  Widget Cookies” are small data files that  HesTopics ’s servers transfer to your computer’s hard disk when you view the  HesTopics  Unit. The  HesTopics  Widget Cookies are named “recent_crc”, “recent_clicks”, and “seen_crc”. As noted above, the  HesTopics  Widget Cookies contain only the content links you clicked on (if any), an identifier for the Publisher Website on which you viewed the  HesTopics  Widget, and an identifier for the precise version of the  HesTopics  Widget you were viewing, for the sole purpose of ensuring that you receive a variety of  HesTopics  content (also called “frequency-capping”) and offer you  HesTopics  content we think is related to that Publisher Website and the content links you click.

• It is possible to opt out of cookies via your browser’s cookie settings. Most browsers allow you to opt out of all cookies, or just “third party cookies”. Either will prevent the  HesTopics  Widget from placing a cookie on your browsing device.

• You may also opt-out by visiting our opt-out page here. Please note that after choosing to opt-out, if you use a different computer or a different browser, or if you delete or block browser cookies, you may need to repeat the opt-out steps.

What  HesTopics  Does with that Data

•  HesTopics  keeps logs of IP addresses, user agent information, and Publisher Website identity (but not the cookie information, which we only read into temporary memory when we display the  HesTopics  Widget and other  HesTopics  content to you) for 30 days in their raw form. We aggregate the data into categories and counts necessary for the business relationship with the relevant Publisher (to count, sort and report impressions and to make payment), and then we delete the logs. The aggregated data does not contain any data which is identifiable to any natural person (for example, IP addresses). While we have the logs in their raw form, we may also use them for performance and security auditing.  HesTopics  will also retain personal data as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

•  HesTopics  uses the information stored in the  HesTopics  Widget Cookies to avoid displaying content to you that you already clicked on from the specific Publisher Website identified in the cookie.  HesTopics  does not store this data, and you can delete the cookie at any time.  HesTopics  does not use cookies or other mechanisms to track user behavior across multiple Publisher Websites.

California consumers may refer to the table at the end of this  HesTopics  Widget Data Summary to see these uses categorized into business purposes as required by the “CCPA.

Exceptions For Extreme Circumstance

Your personal data may be used when necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or if otherwise required by law to do so (such as a subpoena).

Transfer of Data Outside of Europe And Outside of the United States

Your personal data will be processed by  HesTopics  in the United States and possibly other countries outside of Europe.  HesTopics  abides by the principles of the EU – U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks.

Who Else Will Receive The Data

 HesTopics  will share your personal data with third party service providers that work with us to provide our services such as providers to host  HesTopics ’s infrastructure solution. These third-party service providers have access to your personal data only for the purpose of performing services on our behalf.  HesTopics  may share aggregated, non-identifying information with other third parties, including other users, to enhance the effectiveness of our services and for industry research and analysis, benchmarking, and other similar purposes. For example,  HesTopics  may share aggregated, non-identifying statistics with other website publishers as part of  HesTopics ’s sales and marketing efforts and to allow publisher to optimize their use of the  HesTopics  Unit. Finally,  HesTopics  may also transfer your personal data if its business assets are ever sold to or purchased by another company. (The data records are part of  HesTopics ’s business.)

What Rights Do I Have?

European and other Non-US Individuals

Under the applicable laws of various countries, you may have certain rights, such as under EU law, the right to access to, rectification or erasure of, and/or restriction of processing or objection to processing of your personal data.  HesTopics ’s contact information is below. However, please note that given the limited information  HesTopics  collects,  HesTopics  will almost certainly not be able to verify your identity from its records.

If you are a resident in the European Union, you have right to at no cost to lodge a complaint with EU data protection authorities. This right also exists in other countries. If you have questions please contact us or the data protection authority in your country.


California Consumers

Except for personal information we have because you or a business you work for or own has a direct business relationship with us, you as a California consumer have the following rights under the CCPA.

• You have the right to request that we disclose to you the categories of personal information we have collected about you, the categories of sources from which we collected that personal information, the business purposes for which we use that information, and the specific pieces of personal information we have about you.
• You have the right to request that we disclose to you the categories of personal information we have collected about you, the categories of personal information we have sold about you, and for each category of your personal information we have sold, the categories of third parties to which we sold that personal information.
• You have the right to request the categories of your personal information we have disclosed for a business purpose.
• You have the right to request that we delete any of your personal information that we have collected from you.

All California consumers have the following rights under the CCPA:

• We do not disclose your information to third parties in exchange for consideration (“sell”, “sale”, “selling”, “sold” under the CCPA). However, we are required to inform you that you have the right to opt-out of the sale of your personal information.
• You have the right not to be discriminated against because you have exercised any of your rights under the CCPA.
• You have the right to designate an authorized agent to make requests to us to exercise any of your rights under the CCPA.

To make any of the requests exercising your rights as a California consumer, you may contact us using the methods below.

Please note that we have to be able to verify your identity in order to comply with any of your requests to exercise your rights, and given the limited information  HesTopics  collects, there is no reasonable method by which  HesTopics  can verify your identity from its records. Only you and your internet service provider know your IP address and which websites you have visited at any given time. We have no ability to obtain this information, so we have no ability to correlate the personal information we have to any individual or household.

How To Contact  HesTopics

 HesTopics  can be reached at:
[email protected]

Scope of Coverage

This Data Protection Summary only covers data collected by  HesTopics  through the  HesTopics  Widget. It does not cover data collected by  HesTopics  from any other source. It does not cover the data practices of any Publisher or Publisher Website

Supplemental Table for California Consumers

Personal Information and CCPA CategoryBusiness PurposesSource CategoriesRecipient Categories
• IP Address

CCPA Category: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

• delivering content
• limiting the number of times you see content
• reporting on and recording traffic from  HesTopics  Widget
• preventing malicious or invalid activity
• Directly from your browser• Cloud storage service provider
• The Publisher on whose website you viewed the  HesTopics  Widget
• Legal counsel if necessary
• the user agent (what kind of device and browser) which displayed the  HesTopics  Widget

• the identity of the Publisher Website on which the  HesTopics  Widget was displayed

• For each Publisher Website, the content links you clicked on (if any), and an identifier for the precise version of the  HesTopics  Widget you were viewing

CCPA Category: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement

• delivering content
• limiting the number of times you see content
• reporting on and recording traffic from  HesTopics  Widget
• preventing malicious or invalid activity
• Directly from your browser• Cloud storage service provider
• The Publisher on whose website you viewed the  HesTopics  Widget
• Legal counsel if necessary

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