Privacy Policy

Welcome, and thank you for your interest in Hotspotty ("Hotspotty", "we," or "us"), our web site at http://www.hotspotty.net (the "Site"), and all related web sites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications, such as email or phone (collectively, together with the Site, our "Service").

This Privacy Policy ("Policy") describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy.

This Policy is incorporated into, and is subject to, the Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Hotspotty Terms of Service.

1. Definitions

"Hotspotty" means Hotspotty Inc., a corporation incorporated under the laws of the State of Delaware, United States of America, with its registered office at 8 The Green, Ste R, Dover, DE 19901, United States of America. Hotspotty Inc. is the controller responsible for the Personal Data described in this Policy.

"Client" means a customer of Hotspotty.

"Client Data" means personal data, reports, payment data, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Public Area" means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.

"Restricted Area" means the area of the Site that can be accessed only by Users, and where access requires logging in.

"User" means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.

"Visitor" means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

2. Information Collection

We collect different types of information from or through the Service. The legal bases for Hotspotty's processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Hotspotty's Terms of Service and that the processing is carried out in Hotspotty's legitimate interests, which are further explained in the section "How We Use the Information We Collect" of this Policy. We may also process data upon your consent, asking for it as appropriate.

2.1 User-provided Information

You may provide us with Personal Data in various ways on the Service when you register for an Account. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests. Examples of Personal Data include name, email address, mailing address, mobile phone number, or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual.

When you use the Service as a Visitor without a registered Account the only information collected is "Automatically Collected" information via cookies and Google Analytics as described below.

2.2 Information Collected by Clients

A Client or User may store or upload into the Service Client Data. Hotspotty has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.

2.3 "Automatically Collected" Information

When a User or Visitor uses the Service, we may automatically record certain information from the User's or Visitor's device by using various types of technology, including cookies, "clear gifs" or "web beacons." This "automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User's interaction with Hotspotty messaging service. This information is gathered from all Users and Visitors.

2.4 Information Received from Third Parties

We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

3. How We Use the Information We Collect

We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

3.1 Operations

We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.

3.2 Improvements

We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionalities. Should this purpose require Hotspotty to process Client Data, then the data will only be used in anonymized or aggregated form.

3.3 Communications

We may use User's email address or other information – other than Client Data – to contact that User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under "Your Choices."

3.4 Cookies and Tracking Technologies

We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User's or Visitor's information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

3.5 Analytics

We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users' and Visitors' activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.

3.6 Payment Processing

Payments for paid Plans are processed on our behalf by Stripe, Inc. (354 Oyster Point Boulevard, South San Francisco, California 94080, USA), acting as our payment processor. When you purchase or renew a paid Plan, the personal data needed to take the payment is collected and processed by Stripe. This includes your payment card details, billing name and address, email address, country and IP address, and the transaction amount and currency.

Payment card numbers are entered directly into Stripe and are not received or stored by Hotspotty. We receive from Stripe only the information we need to administer your subscription and meet our accounting and tax obligations, such as the last four digits of the card, the card brand, the billing country, and the status, amount and date of each charge, refund or dispute.

The legal basis for this processing is the performance of our contract with you and, for the retention of transaction records, our legal obligations. Stripe is an independent controller in respect of some of this data, operates its own fraud prevention measures, and has its own privacy policy, which we encourage you to read: Stripe Privacy Policy. Both Hotspotty and Stripe are established in the United States, and this processing takes place there. Section 5 explains the safeguards that apply where this involves a transfer of Personal Data out of the European Economic Area, the United Kingdom or Switzerland.

4. Third Party Service Providers

We use the following third parties to provide the Service. Each processes personal data only as needed for the purpose shown, and each has its own privacy policy.

• Stripe, Inc. (United States): payment processing, subscription billing and fraud prevention, as described in section 3.6.
• Google LLC (United States): Google Analytics, for measuring traffic on the public areas of the Site, as described in section 3.5.

Where we engage a new provider that processes personal data on our behalf, we will update this list and, where the change is material, publish a new version of this Policy in accordance with section 6.

5. International Data Transfers

Hotspotty Inc. is established in the United States and the Service is operated from the United States. Where you access the Service from outside the United States, the Personal Data described in this Policy is transferred to, stored in and processed in the United States, and may also be processed there by the service providers listed in section 4.

If you are located in the European Economic Area, the United Kingdom or Switzerland, this means your Personal Data is transferred to a country outside the region in which you are located. We rely on the European Commission's Standard Contractual Clauses, together with the United Kingdom International Data Transfer Addendum where it applies, as the safeguard for these transfers, supported by technical and organizational measures appropriate to the data involved. You may request further information about the safeguards we rely on by emailing support@hotspotty.net.

6. Changes to this Policy

This Policy carries a version number and an effective date at the top of this page. Versions that have been superseded remain available at Policy versions. Where a change materially affects how we handle your personal data, we will give notice by email or by prominent notice within the Service before it takes effect.

7. Contact Information

If you have any questions about this Privacy Policy, please contact us at:

Hotspotty Inc.
8 The Green, Ste R
Dover, DE 19901
United States of America
Email: support@hotspotty.net