The Principles are part of the Homepastries Terms of Service and apply to the Principles. Capitalized terms used but not defined in the Principles have the meaning given to them in the Homepastries Terms of Service
Customer means Homepastries customer, i.e. business user who uses the Services as a work tool.
Personal data is any information about an identified or identifiable natural person.
Public Area means the area of the Website accessible to both Users and Visitors without the need to login.
2. Information we collect on the Service:
We collect different types of information from or through the Service. For Homepastries, the legal basis for the processing of personal data is, in particular, that the processing is necessary for the provision of the Service in accordance with the Homepastries Terms of Service and is for the legitimate interests of Homepastries, further explained in the “How We Use Information We Collect” policy. We may also process the data with your consent, which we ask if appropriate.
2.1 Information Provided by the Customer In processing the Customer’s personal data in the course of providing the Service to the Customer, the Customer is a controller and an authorized processor of Homepastries. Examples of personal information include name, email address, postal address, billing address, mobile phone number, password and credit card or other billing information. Personal information also includes other information, such as geographic area or preferences, when such information is related to information that identifies a particular individual. You may provide us with Personal Data in a variety of ways on the Service. For example, when registering for an Account, using the Service, posting Customer Data, communicating with other users of the Service through communication or messaging features, or sending customer service related requests. When you use the Service and the Registrar, certain Service Solutions may collect data about your exact location or device movement, or both, if you give us permission to do so in your device setup. These specific Homepastries Service solutions do not track the Customer’s location in real time, but the location at the time the start or stop button is pressed when using the Registrar.
2.2 Information Collected by Customers. Customer may store or upload Customer Data on the Service. Homepastries has no direct relationship with individuals whose Personal Data is hosted on the Web as part of Customer Data. Each Customer is responsible for ensuring that Customer has a valid legal basis for the processing of Personal Data of its customers, employees or third parties through the Services. Each Customer is responsible for informing its customers, employees and third parties of the purpose for which Customer collects Personal Data and how such Personal Data is processed as part of Customer Data on or through the Service. If required by applicable law, each Customer is responsible for obtaining valid consents from its customers, employees or third parties to process their Personal Data through the Service prior to the start of processing of Personal Data.
2.3 “Automatically collected” information. When a Visitor uses the Service, we may automatically store certain information from the Visitor’s device using various technologies, including cookies, screen recordings, clear gifs, or web bugs. This “automatically collected” information may include the IP address or other device addresses or IDs, the type of web browser and / or device, the web pages or pages, pages, or other content visited or accessed by the Visitor immediately before or after use of the Service , and the dates and times when you access, access or use the Service. We may use these technologies to collect information about a Visitor’s interaction in emails, such as whether a Visitor opens, clicks, or forwards a message. Information is collected from all Visitors and Homepastries is the controller of such information.
2.5 Information from Other Sources We may obtain information, including Personal Data, from third parties and from sources other than the Service, such as our partners, advertisers, rating agencies and the Integrated Services. When we combine or associate information from other sources with the Personal Data we collect through the Service, we treat the Combined Information as Personal Data in accordance with the Principles.
3. How we use the information we collect
We use the information we collect in a variety of ways in the provision of the Services and in the course of our business, including:
3.1 Keeping up with the job
We use the information – other than Customer Data – to maintain, upgrade and provide all solutions to the Service, to provide the services and information you request, to respond to your comments and questions, and to provide support to users of the Service. We will only process Customer Data in accordance with the instructions given by the respective Customer.
We use the information to understand and analyze our Visitors usage trends and preferences, to improve the Service, and to develop new products, services, solutions and features. If Homepastries is required to process Customer Data for this purpose, the data will only be used in anonymous or aggregated form.
We may use the Visitor’s e-mail address or other information to contact that Visitor for (i) administrative purposes, such as customer service, to deal with intellectual property infringement, offers and events related to the products and services we provide or with third parties we work with. You may opt-out of receiving any promotional material as described in the “Your selections” section.
3.4 Cookies and other tracking technologies
We use automatically collected information and other information collected through the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering Visitor Information, so that the Visitor does not have to re-enter it during or after a visit; (ii) provide personalized advertising, content and information; (iii) monitor and analyze the effectiveness of the Service and third party marketing activities; (iv) monitor aggregate usage of the page, such as the total number of visitors and pages viewed, and (v) monitor your listing, submission and status in any advertising or other activity on the Service. More information about cookies can be found at http://www.allaboutcookies.org.
We apply measures to protect the technical information collected when you use Google Analytics. The data collected is used only on a need basis to resolve technical issues, manage the Website, and identify visitor preferences, but in this case, the data is in an unrecognizable form. We do not use this information to identify Guests.
4. To whom we disclose information
4.1 Publicly Available Information
Any information that you voluntarily choose to include in the Public Area of the Service, such as the Public Profile Page, will be made available to any Visitor who has access to this Content.
4.2 Service Providers
We work with third party service providers to provide us with website, application development, web hosting, maintenance and other services. These third parties may have access to or process Personal Data or Customer Data in the course of providing our services to us. The information we provide to these service providers is limited to what is reasonably necessary for them to perform their functions, and the agreements with them oblige them to keep that information confidential.
4.3 Non-personally Identifiable Information
We may make certain automatically collected, aggregated, or otherwise non-personally identifiable information available to third parties for a variety of purposes, including (i) various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist those persons in understanding the interests, habits, and practices of our Customers regarding certain programs, content, services and / or features available through the Service.
4.4 Law enforcement, legal process and compliance
We may disclose Personal Data or other information when required by law or in good faith to comply with applicable law, in response to a court order, court summons or other governmental order, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe is appropriate or necessary in good faith to (i) take precautionary measures against us, (ii) protect ourselves or others from fraudulent, abusive, or unlawful use or action, (iii) investigate and defend any third party claims or claims, (iv) protect the security or integrity of the Service and any means or equipment used to make the Service available, or (v) protect your property or other benefits, enforce your contracts or protect the rights of others , property, or security.
4.5 Change of ownership
5. Your Choices
5.1 Access, Repair, Deletion
We respect your right to privacy and give you reasonable access to the Personal Data you may have provided to us in the course of your use of the Services. If you wish to access or modify any other Personal Data that we process as a controller for you, or to request that we delete or disclose any information about you that we have received from the Integrated Service, you may contact us at “How to Contact Us” section. At your request, we will delete or block all references to you in our database.
You may refuse to share certain Personal Data with us, in which case we may not be able to provide you with some solutions and features of the Service.
You may at any time object to the processing of your Personal Data on a legitimate basis, unless otherwise permitted by applicable law. If you believe your privacy rights under applicable data protection laws have been violated, please contact the Homepastries Data Protection Officer at email@example.com. You also have the right to complain to the competent data protection authority.
Homepastries has no direct relationship with Customer’s customers, employees, project owners, or third parties whose Personal Data may be processed by Customer. An individual who wishes to access or corrects, modifies, deletes inaccurate data or withdraws consent for further communication should submit a request to the Client or the User with whom they communicate directly. If Customer requests Homepastries to remove data, we will respond to that request within thirty (30) days. We will only delete, modify or block access to Personal Data that we retain unless we receive a written request from the Client, who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of this data for archiving purposes or to protect our rights in litigation. Any request regarding Customer Data should be addressed as described in the “How to Contact Us” section and should contain sufficient information to enable Homepastries to identify the Customer or its customer or third party and information to be deleted or modified.
5.2 Navigation information
You may opt-out of collecting navigation information about your visit to the Website through Google Analytics using the Google Analytics Opt-out Solution.
6. Third party services
The Service may include solutions or links to websites and services provided by third parties. Any information you provide on third-party websites or services is provided directly to the operators of those services and is subject to the privacy and security policies of those operators, if any, even if you access them through the Service. We are not responsible for the content or privacy and security practices of any third party websites or services that are linked to or accessed through the Service. We recommend that you familiarize yourself with the privacy and security policies of third parties before providing them with information.
7. International Data Transmissions, Privacy Shield and Terms and Conditions
Homepastries holds all European Customer Data only in EU data centers. Homepastries may transfer your Personal Data to countries other than your country of residence. If Homepastries transfers Personal Data originating from the European Union or Switzerland to other countries where data protection legislation does not provide an adequate level of protection, we will apply the following security measures:
- EU-US Privacy Shield and Switzerland-US Privacy Shield. To comply with European Union and Swiss data protection laws, Homepastries will only disclose your information to partners who are certified by the EU-US Privacy Shield and the Switzerland-US Privacy Shield Framework. These frameworks were created to enable companies to meet data protection requirements when transmitting personal data from the European Union and Switzerland to the United States. You can read more about the Privacy Shield program at https://www.privacyshield.gov
- Standard terms for the European Union. Homepastries uses the Standard Contractual Clauses of the European Union to meet the adequacy and security requirements of Customers operating in the European Union and international transfers of other Customer Data to third parties who process your data in countries that do not apply the same data protection standards and hence an adequate level of protection guaranteed by local law.
In accordance with the Privacy Shield Principles, Homepastries undertakes to resolve complaints about the collection and use of your personal information by us. Individuals in the EU who have inquiries or complaints about our Privacy Shield policy should first contact the homepastries data protection officer at firstname.lastname@example.org. In addition, Homepastries has committed to cooperate with the EU DPAs on pending Privacy Shield complaints regarding the transfer of personnel data from the EU in the context of an employment relationship.
8. Interest-Based Advertising
Interest-based advertising is the collection of data from various sources and across different platforms to predict a person’s preferences or interests, and to send ads to that person or their computer, smartphone or tablet based on their perceived preference or interest derived from that person’s profile or similar profile or data collected about people with interests.
We work with various third parties to try to understand the profiles of individuals most likely to be interested in Homepastries products or services so that we can send them commercial emails or display their ads on other entities’ websites and mobile apps.
These third parties include, but are not limited to: (a) ad networks that collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners who measure the effectiveness of certain advertising channels and ads; and (3) business partners who collect information when a person views or interacts with one of their ads.
In collaboration with these third parties, we collect information about our clients, prospective clients, and other individuals as they use or interact with these platforms over time and through various platforms. Individuals may submit information directly to our Websites or platforms operated by third parties, or through communications with us, our ads, or emails from us or third parties. We may use special tools commonly used for this purpose, such as cookies, web bugs, pixels, tags, mobile ad IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information collected by us or by third parties enables us to know what purchases a person has made, what ads or content a person sees, which ads or links a person clicks on, and other actions that person takes on our Websites or in response to our emails or visits or personal platforms.
The information we collect, as described above, is used by us or third parties we work with to understand the various activities and behaviors of our clients, visitors to the Website and others. We do, or these third parties do, for a variety of reasons including: recognizing new or past visitors to our Website; Provide more personalized content provide more useful and relevant ads – for example, if we know which ads are being shown to you, we may try not to show you the same ads repeatedly; devices, sales channels, third-party websites and Websites to identify or send personalized or targeted ads and other customized content that are more focused on the individual’s expected interest in products or services similar to ours.
Our interest-based ads may be displayed to you in emails or on third party platforms. We may serve these ads on our products and services or send commercial announcements directly or through these third parties.
Visitors may refuse to receive interest-based advertising from ad networks that may be sent to them on our platform and other websites by visiting http://www.aboutads.info/consumers and http://www.networkadvertising.org. These solutions remove the Visitor from many, but not all, of the interest-based advertising activities we or third parties undertake.
9. Principles of non-monitoring
Some web browsers have added “non-tracking” solutions. Most of these solutions, when turned on, send a signal or preference to the web page or web-based service the user visits, stating that the visitor does not want to be monitored. As there is currently no common understanding of how to interpret non-tracking signals, we are not responding to the non-tracking signal at this time. We will continue to work with the web industry to define a common understanding of how to handle non-tracking signals.
However, you may opt out of receiving interest-based ads from ad networks that may be displayed on our platform and other websites by visiting the following websites. If you would like to opt out of this behavioral advertising, please visit http://www.aboutads.info/consumers and http://www.networkadvertising.org.
These features remove you from many, but not all, of the interest-based advertising activities we or third parties do. The choices you make may depend on your web browser or device. If you delete cookies or use a different browser or other computer or device, you may need to update your refusal options. Other third party Web sites offer visitors the ability to opt out of receiving interest-based advertising on your Web site, which you must verify through your Web site settings. For example, to prevent Google from using your online behavior for advertising purposes, visit the Google Ad Settings page.
10. Third Party Cookies
The information collected by these third parties is used to predict your interests or preferences, so that they can place ads or promotional material on this Website and other websites anywhere on the Internet that are tailored to your obvious interests.
Business partners and ad networks that provide Internet-based advertising on the Services will have limited access to the limited information about your profile and device needed to provide you with ads tailored to your obvious interests. It is possible that they may reuse this little information on other websites or other services.
We do not share information with these third parties that would allow you to be immediately identified (such as an email address), but these third parties may have access to information about your device (such as an IP or MAC address). We have no access or control over the technologies these third parties may use to collect information about your interests, and the data practices of these third parties are not subject to this Privacy Notice. Except as discussed in the document, we have no control over these third parties.
10.1 The website uses the following types of cookies:
- strictly necessary cookies – These cookies are necessary for you to navigate around the site and use its solutions, such as access to secure areas of the site. Without these cookies you will not be able to provide the services you have requested. These cookies do not collect information that the visitor identifies.
- Performance cookies – These cookies collect information about how visitors use the site, such as which pages visitors most frequently visit and whether they receive error messages on the pages. These cookies do not collect information that the visitor identifies. All information collected by these cookies is aggregated and therefore anonymous. It is used only to improve the operation of the website.
- functionality cookies – These cookies allow the website to remember the choices you make (such as the language or region you live in) and to provide improved and more personalized solutions. For example, a website may offer you local weather or traffic updates by storing your current location in a cookie. These cookies can also be used to remember the text size, font style, and other choices you make about the parts of the web page that you change. They can also be used to provide the services you want, such as watching a video or commenting on a blog. The information that these cookies collect can be made anonymous and they cannot track your browsing on other websites.
- Behavioral Advertising Cookies – These cookies are used to serve ads that are more relevant to you and your interests. They are also used to limit the number of times you see your ad and help you measure the effectiveness of your advertising campaigns. These cookies are usually placed by the ad network with the permission of the webmaster. They remember that you have visited the site and that information is shared with other organizations, such as advertisers. Often, targeting cookies or advertising cookies are linked to the functionality of a website provided by another organization.
11. The privacy of minors and children
It is very important to protect the privacy of young children. Our Service is not intended for children under the age of 18 and we do not knowingly collect Personal Data from children under the age of 18 without parental consent. If you are under 18, please do not use the Service at any time or in any way. If we become aware that the Service has collected Personal Data from persons under the age of 18 and without the consent of the supervised parent, we will take appropriate measures to delete that information. If you are a parent or guardian and become aware that your child under the age of 18 has received a Service Account, you can notify us at email@example.com and request that we delete that child’s Personal Data from our systems.
12. Data security
We adhere to generally accepted standards to protect the information provided to us, both at the time of transmission and upon receipt. We maintain appropriate administrative, technical and physical security measures to protect Personal Data against accidental or unlawful loss, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful processing of Personal Data in our possession. This includes, but is not limited to, firewalls, password protection, and other access and authentication controls. We use SSL technology to encrypt data when transmitting it over the public Internet, and we also apply application layer security solutions to further anonymize Personal Data.
However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee or warrant the security of the information you transmit or store to us on the Service, at your own risk. We also cannot guarantee that this information will not be accessed, disclosed, altered or destroyed through violations of our physical, technical or managerial security measures. If you believe your Personal Information has been compromised, please contact us as described in the “How to Contact Us” section.
Once we become aware of a breach of security, we will notify you and the authorities of the breach in the manner required by law.
13. Data Retention
We will retain Personal Data collected from the User only as long as we need it for the purpose for which we originally collected it, unless otherwise required by law. We retain and use the information as necessary to perform our legal obligations, resolve disputes and perform contracts:
- the contents of closed accounts will be deleted within 3 months from the date of closure;
- backups are kept for 3 months;
- invoice information is retained for 7 years from the time it is submitted to Homepastries in accordance with Estonian accounting and tax laws;
- Information on legal proceedings between the Customer and Homepastries will be retained for 10 years from the time it is filed with Homepastries, in accordance with the general statute of limitations for civil claims set out in the General Part of the Estonian Civil Code.
While we may allow you to change our privacy settings to restrict access to certain Personal Data, please be aware that no security measure is perfect or impenetrable. We are not responsible for any circumvention of the privacy or security measures of the Service. In addition, even after the information posted on the Service has been removed, the cache and archiving services may have stored that information and other users or third parties may have made a copy or stored information available on the Service. We cannot and do not guarantee that the information you post or transmit on the Service will not be viewed by unauthorized persons.
15. Transmission of data
The service is hosted in Estonia or the US. EU customer databases are located at the Homepastries Data Center in Tallinn, Estonia. Irrespective of the fact that the Database is located in the EU, if you choose to use the Service in the European Union or other regions of the world where data collection and use laws may differ from US law, please note that you may transfer Customer Data and Personal Data outside these areas To the United States for storage and processing by our service providers listed in the Homepastries Terms of Service. We comply with the requirements of the GDPR, providing adequate protection when transmitting personal data from Europe to the US. In addition, we may transfer your data to the United States, the EEA, other countries or regions that the European Commission determines to provide an adequate level of data protection with respect to the storage and processing of data, the execution of your requests and the management of the Service.
16. Controller and processor
Homepastries does not own, control or control the use of the Customer Data stored or processed by the Customer through the Service. Only the Customer has the right to access, obtain and control the use of this Customer Data. In most cases, Homepastries is not aware of what Customer Data is actually stored or made available by the Customer on the Service and does not have direct access to such Customer Data unless Customer has given its consent or is required to provide the Services to Customer.
The Client is responsible, in accordance with the Regulation, for any Client Data containing Personal Data, which means that this Party controls the manner in which the Personal Data is collected and used and the purposes and means of processing such Personal Data.
Homepastries is not responsible for the content of the Personal Data contained in Customer Data or any other information stored on its servers (or subcontractor servers) at Customer’s discretion, and Homepastries is not responsible for the manner in which Customer collects, discloses, disseminates or otherwise processes such information.
17. Modification and updating of the Principles
Please visit this page regularly to be aware of any changes to the Policy that we may update from time to time. If we change the Principles, we will make them available through the Service, and will refer to the date of the latest version and comply with applicable laws. Your continued use of the Service after the revised Terms come into force means that you have read, understood and agreed to the current version of the Terms.
18. How to contact us
Please contact us if you have any questions or comments regarding the Principles, your Personal Data, our use and disclosure practices or your consent options by sending an email to firstname.lastname@example.org. If you have any concerns or complaints regarding the Principles or your Personal Data, you may contact the Homepastries Data Protection Officer at the same email address: email@example.com.