Last Updated: 18 June 2020

Hooshmand.Net (“we”, “us”, or “our”), trading under Scimitar Holdings (www.scimitarholdings.com) is committed to protecting your privacy.

This Privacy Policy (“Policy”) describes how we collect, use, and disclose data. This Policy applies to your use of our products, services, and Website located at www.hooshmand.net on all platforms (collectively, “Services”).

We operate under a Hong Kong company subject to the laws of Hong Kong. Hong Kong may not offer a level of privacy protection as great as that offered in other jurisdictions.

Since our servers are located globally in the cloud, your data may be transferred to, stored, or processed in servers world-wide. By using our Services, you understand and consent to the collection, storage, processing, and transfer of your data to our facilities in Hong Kong or elsewhere in the cloud and those third parties we share your data with as described in this Policy and our Terms of Service Agreement.

1. DEFINITIONS

a. Customer: a person or entity that is registered with Hooshmand.Net to use the Services (this is probably you)

b. Distribution List: a list of Subscribers and all data related to those Subscribers.

c. Personal Data: any information relating to an identified or identifiable natural person.

d. Subscriber: any person or entity on your Distribution List.

e. You: you, or a person who has used our services, distribution list, or our website.

2. INFORMATION WE COLLECT ABOUT YOU

We collecte two kinds of information about you: (a) Personal Data; and (b) Non-Personal Data.

None of it is for evil or dark purposes. It's either to market to you, or because we're showing ads on our website, and those use your personal info via cookies.

a. Personal Data. Personal Data is any information relating to a person. Personal Data we may collect includes:

i. Identification and Contact Data: name, date of birth, gender, address, title, contact details, username, or other demographic information;

ii. Financial Information: credit card details, account details, payment information;

iii. Employment Details: employer, job, title, geographic location, area of responsibility;

iv. IT Information: IP address, cookie data; and

v. Personal Interests or Preferences: purchase history, social media profile information.

You can decline to provide Personal Data to the Services. We don't even need it for most things.

b. Non-Personal Data. Non-Personal Data is any information not relating to an identified or identifiable natural person.

Non-Personal Data we may collect includes:

i. Browser and Device Data: IP address, device type, unique user device number, device manufacturer and model, type of browser or operating system, dates and times of use, screen resolution, plug- ins, add-ons, location, and the version of the Services you are using. Your browser usually sends us this stuff.

ii. Cookies and Tracking Technologies: time spent on the web page, pages visited, and email campaign performance.

iii. Aggregate Information: data about how you use the Services combined with data about how others use the Services in order to help us better optimise our services.

3. HOW WE USE YOUR INFORMATION

a. Personal Data. We may use your Personal Data to:

i. Provide the Services (mostly operate the web page)

ii. Resolve disputes, calculate and collect fees, and troubleshoot problems;

iii. Verify your identity and the information you provide;

iv. Encourage a safe online experience and enforce our policies;

v. Customise your experience and analyze usage of, improve and measure interest in, and inform you about the Services (e.g. by displaying popular posts more prominently)

vi. Provide you with information that may affect your use of the Services;

vii. Communicate marketing and promotional offers;

viii. Provide customer service, including receipts;

ix. Develop new products; and

x. Perform certain other business activities we haven't thought of yet.

b. Non-Personal Data. We may use your Non-Personal Data for any purpose, including, but not limited to:

i. Measuring traffic patterns;

ii. Understanding demographics, customer interest, and other trends among users;

iii. Providing, improving, and modifying the website/products; and

iv. For promotional and marketing purposes.

4. HOW WE MAY DISCLOSE YOUR INFORMATION

a. Personal Data. We may disclose, and you consent to our disclosing of, your Personal Data to:

i. Service Providers and others who help with our business operations and assist in the delivery of our products and services.

These may include services related to application development, site hosting, maintenance, data analysis, infrastructure provision, IT services, customer service, email delivery services, payment processing, marketing, analytics, and enforcement of our Terms of Service Agreement and other agreements;

ii. Third parties in the event of a reorganization, merger, sale, debt financing of assets, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including in connection with any insolvency, bankruptcy, receivership, or similar proceeding);

iii. A subsidiary, affiliate, or business partner;

iv. Other users of the site to identify you to anyone to whom you send messages or make comments through the Services;

v. Persons or entities with whom you consent to have your Personal Data shared;

vi. Third parties in order to prevent damage to our property (tangible and intangible), for safety reasons, or to collect amounts owed to us;

vii. Merchants and payment processors; and

viii. Third parties as we believe necessary or appropriate, in any manner permitted under applicable law, including laws outside your country of residence to: comply with legal process; respond to requests from public and government authorities, including public and government authorities outside your country of residence; enforce our Terms of Service Agreement and other agreements; protect our operations; protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit the damages that we may sustain.  

We will never sell, rent, or lease your Personal Data to a third party.

b. Non-Personal Data. We may disclose Non-Personal Data for any purpose. Remember, Non-Personal Data cannot be used to identify you or another person.

5. ADVERTISING

a. Opting out of Receiving Electronic Communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link or by notifying us at [email protected]

We may still send you important messages regarding administrative matters, updates, disputes, and customer service issues that are required to provide you with the Services.

b. Cookies and Other Tracking Technologies. We and our partners may use cookies and other tracking technologies such as pixels. We use these to analyse our website and app performance. You can opt out with your browser or use an ad blocker.

Our third-party partners may use cookies or other tracking technologies to provide you advertising on other sites based upon your browsing activities and interests.

If you want to opt-out of interest-based advertising, please visit

http://preferences-mgr.truste.com/, or if located in the European Union, visit http://www.youronlinechoices.eu.

c. Web Beacons. When we send emails to Customers, we may use web beacons to track who opened the emails and clicked links to measure campaign performance and improve features for Customers.

We also use web beacons in the emails we deliver for Customers to create reports about campaign performance and determine what actions Subscribers took.

Mediavine Programmatic Advertising

The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.

The Website may collect IP addresses and location information to serve personalized ads and pass it to Mediavine. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp. You may also visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

Mediavine partners with the following data processors:

  1. Pubmatic. You may find Pubmatic’s privacy policy through this link. The data collected on the Website may be transferred to Pubmatic and its demand partners for interest-based advertising. Statistical information and other non-cookie technologies (such as eTags and web or browser cache) may be used by third parties on this Website. Browser settings that block cookies may have no effect on these technologies, but you may clear your cache to delete such trackers. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.
  2. Criteo. You may find Criteo’s privacy policy through this link. The data collected on the Website may be transferred to Criteo and its demand partners for interest-based advertising. Criteo may collect, access, and use non-identifying data to improve the Criteo Technology and other Criteo products, programs, and/or services. This non-identifying data may include on-site user behavior and user/page content data, URLs, statistics, or internal search queries. The non-identifying data are collected through the ad call and stored with a Criteo cookie for a maximum period of 13 months.
  3. Pulsepoint. You may find Pulsepoint’s privacy policy through this link.
  4. LiveRamp. You may find LiveRamp’s privacy policy through this link. When you use the Website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with LiveRamp Inc, and its group companies (‘LiveRamp’). LiveRamp may use a cookie on your browser and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email, in-app, etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of LiveRamp’s targeted advertising, please go here: https://liveramp.com/opt_out/
  5. RhythmOne. You may view RhythmOne’s privacy policy through this link. RhythmOne uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) to provide its services. RhythmOne may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the following webpage: http://www.networkadvertising.org/managing/opt_out.asp.
  6. District M. You may find District M’s privacy policy through this link.
  7. YieldMo. You may find YieldMo’s privacy policy through this link. If you want to opt out of receiving interest based ads from Yieldmo or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link.
  8. The Rubicon Project. You may find Rubicon’s privacy policy through this link. If you want to opt out of receiving interest based ads from Rubicon or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page.
  9. Amazon Publisher Services. You may find Amazon Publisher Services’ privacy policy through this link.
  10. AppNexus. You may find the AppNexus privacy policy through this link.
  11. OpenX. You may find OpenX’s privacy policy through this link.
  12. Verizon Media formerly known as Oath. You may find Verizon Media’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  13. TripleLift. You may find TripleLift’s privacy policy through this link. To opt out of receiving interest-based advertising (including retargeting) from TripleLift’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to www.triplelift.com/consumer-opt-out.
  14. Index Exchange. You may find Index Exchange’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  15. Sovrn. You may find Sovrn’s privacy policy through this link.
  16. GumGum. You may find GumGum’s privacy policy through this link. GumGum may (i) use place and use cookies on end users’ browsers or use web beacons to collect information about end users who visit such Publisher Websites and (ii) link such collected end user information to other end user information provided by third parties in order to deliver targeted Advertisements to such end users.
  17. Digital Remedy. You may find Digital Remedy’s privacy policy through this link.
  18. MediaGrid. You may find MediaGrid’s privacy policy through this link. MediaGrid may collect and store information about end-user interactions with this website through cookies, advertising IDS, pixels and server-to-server connections. MediaGrid was receive the following information: the page an End-User has requested and the referring/exit pages; Timestamp information (i.e., the date and time the End-User has visited the page); IP address; mobile device identifier; device model; device operating system; browser type; carrier; gender; age; geolocation (including GPS coordinates); clickstream data; cookie information; first-party identifiers'; and hashed email addresses; demographic and inferred interest information; and post-conversion data (from both online and offline behaviour). Some of this data is gathered from this website and others is gathered from advertisers. MediaGrid uses this data to provide its services. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising or review their privacy policy for more information.
  19. RevContent - You may find RevContent’s privacy policy through this link. RevContent may collect information about your browser or device, including browser type, IP Address, device type, user agent string, and operating system. RevContent also collects information about the websites you visit through their services, such as date and time of access and specific pages accessed and the content and ads you click on. You may opt-out of any personalization track by opting-out of RevContent’s data collection.
  20. Centro, Inc. - You may find Centro’s privacy policy through this link. You may find opt-out information for Centro’s services through the privacy policy link.
  21. 33Across, Inc. - You may find 33Across’s privacy policy through this link. To opt-out of personalized advertising, please visit https://optout.networkadvertising.org/?c=1.
  22. Conversant. LLC - You may find Conversant’s privacy policy through this link. Conversant uses information that does not directly identify you, such as information about your browser type, time and date of visit, your browsing or transaction activity, the subject of advertisements clicked or scrolled over, and a unique identifier (such as a cookie string, or a unique advertising identifier provided by your mobile device) during your visits to this and other websites and apps in order to provide advertisements about goods and services likely to be of greater interest to you. Conversant may use technologies such as cookies and other tracking technologies to collect this information. To learn more about interest-based advertising, or to opt-out, you can visit www.youronlinechoices.eu or https://www.networkadvertising.org/.

6. DATA COLLECTED BY OUR CUSTOMERS

a. Our Relationship with Subscribers. Customers may import into the Services Personal Data they have collected from their Subscribers or other individuals. We have no direct relationship with Customers’ Subscribers or any individuals other than our Customers. Customers are responsible for making sure they have the necessary permissions for us to collect, store, and process Personal Data about Subscribers or other individuals.

A Subscriber should unsubscribe directly from a Customer’s newsletter or contact the Customer directly to change, update, or delete the Subscriber’s data. If a Subscriber contacts us, we will refer you to that Customer and support them in responding to your request if necessary.

b. Use and Transfer of Data. Consistent with this Privacy Policy, we may transfer Customer or Subscriber Personal Data to entities that help us promote, provide, or support our Services or the services of our Customers (“Service Providers”). All Service Providers agree to protect Personal Data in accordance with this Privacy Policy. We will never sell, rent, or lease Customers’ Distribution Lists.

7. PUBLIC DATA AND THIRD-PARTY SITES

a. Public Data. We may provide areas on the Services where you can publicly post information. This information may be read, collected, and used by anyone. We do not control or endorse the information posted by third-party users, are not liable for your or third-party posts to the Services, and specifically disclaim any liability resulting from such posts.

b. Third-Party Sites. Upon your consent, the Services may access third- party information through application interfaces. We may also provide links to third-party sites. When you click on links to third-party sites, you may leave the Services.

This Policy does not cover any collection, use, or disclosure by third parties through any applications, websites, products, or services that we do NOT control or own, or any third-party features or services made available through our services. By using our services, you expressly relieve us from any and all liability arising from your use of any third-party website.

The inclusion of a link or accessibility of third-party sites does not imply endorsement of such third-party site by us. All trademarks, trade names, and logos of third parties featured on the Services belong to their respective owners.

Each merchant and third-party payment processor collects and shares your information according to its own privacy policy and terms of service.

We are not responsible for the actions of third-party processors or merchants, including how such entities treat your information. You are responsible for knowing and understanding their policies and terms.

8. DATA RETENTION

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

9. USERS UNDER 13 YEARS OF AGE

Our Services are not directed to and we do not knowingly collect Personal Data from children under the age of 13. If we become aware that a child under the age of 13 has provided us with Personal Data, we will take steps to remove such data. If you become aware that your child has provided us with Personal Data without your consent, please contact us at [email protected] By using the Services, you are representing to us that you are not under the age of 13.

10. PRIVACY RIGHTS NOTICE TO CALIFORNIA RESIDENTS

The State of California enacted the Shine the Light law (California Civil Code Section 1798.83) that permits users who are California residents to request certain information regarding the disclosure of certain “personal information” during the past year for marketing purposes. To make such a request, please email us at [email protected]

11. DATA SECURITY

We employ commercially reasonable security measures to protect your information; however, no system is impenetrable. If you create an account on the Services, you are responsible for protecting the security of your account, its content, and all activities that occur under the account or in connection with the Services. You must immediately notify us of any unauthorized uses of your account or any other breaches of security by emailing us at [email protected]

12. EU-U.S. AND SWISS-U.S. PRIVACY SHIELD

We aim to comply with the EU-U.S. Privacy Shield Framework and the Swiss- U.S. Privacy Shield Framework (collectively, “Privacy Shield”), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union (“EU”), European Economic Area (“EEA”), and Switzerland to the United States.

We are committed to subjecting all Personal Data received from the EU/EEA and Switzerland to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, visit https://www.privacyshield.gov, and to view our certification, visit https://www.privacyshield.gov/list.

a. Accountability for Onward Transfer

When we use Service Providers to process Personal Data received in reliance on Privacy Shield, we’re responsible if that Service Provider processes the information in violation of the Privacy Shield Principles (unless we can prove that we’re not responsible for the Service Provider’s action that violated the Privacy Shield Principles).

In certain situations, we may need to disclose Personal Data in response to lawful requests by public authorities, including to meet national security and law enforcement requirements, or otherwise comply with the law or a court order.

b. Security

We use reasonable and appropriate physical, electronic, and administrative safeguards to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and risks involved in processing that information.

c. Data Integrity and Purpose Limitation

We only collect Personal Data that is relevant for providing the Services. We process Personal Data in a way that is compatible with providing the Services or as otherwise authorized by you. We take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We adhere to the Privacy Shield Principles for as long as we retain Personal Data.

d. Access to Personal Data

If you would like to review, correct, delete, or update personal data that you have previously disclosed to us, please email us at [email protected] We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive, or as otherwise permitted by the Privacy Shield Principles.

We will assist our Customers in responding to EU/EEA and Swiss individuals exercising their rights under the Privacy Shield Principles.

If you are a Subscriber of one of our Customers, please contact the Customer directly with your request to access or limit the use or disclosure of your Personal Data. If you contact us, we will refer you to that Customer and support them in responding to your access request if necessary.

We need to retain certain information about you for legal and internal business reasons. We will retain your Personal Data for as long as necessary to provide you with the Services and as needed to comply with our legal obligations and enforce our agreements.

e. Recourse, Enforcement, and Dispute Resolution

If EU/EEA or Swiss individuals have questions or complaints about our compliance with the Privacy Shield Principles, please email us as [email protected]

f. Notice and Choice

i. The types of Personal Data we collect are described in Section 2 of this Privacy Policy.

ii. The purposes for which we collect and use Personal Data are described in Sections 3 and 4 of this Privacy Policy.

iii. The choices we offer individuals for limiting the use and disclosure of Personal Data are described in Section 5 of this Privacy Policy.

13. DO NOT TRACK DISCLOSURE

Currently, there is no industry standard or requirement for recognizing Do Not Track browser signals, so we don't respond to them.

14. CHANGES TO THIS PRIVACY POLICY

We might change this Privacy Policy at any time. The most recent version of the Privacy Policy is indicated by the “Last Updated” date at the top of the Privacy Policy. All changes are effective immediately upon posting. Please review this Privacy Policy frequently to stay updated on changes that may affect you. Your continued use of the Services signifies your continuing consent to be bound by this Privacy Policy.

15. CONTACT INFORMATION

If you have any questions about this Privacy Policy, please email us at [email protected]