Privacy Policy Summary
Hereʼs Hilokalʼs privacy Policy. Have a read through and understand how we respect your
privacy and your data. First, hereʼs the short version in bullet points:
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Data Collection: We only collect personal data necessary for providing our
services, such as your contact details, profile information, and activity data. We collect
audio recordings only when you request us to, and 2 minutes of audio when a user-report is
triggered.
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Usage and Storage: Your data is used to create your profile, enhance
community safety, and improve our services. We store your data securely and retain it only
as long as necessary.
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Third-Party Sharing: We share your data with third parties only with your
explicit consent or to comply with legal obligations. This includes services for analytics,
hosting, and payment processing.
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Your Rights: You have the right to access, correct, delete, and restrict
the processing of your data. You can also revoke your consent at any time and lodge
complaints with the relevant authorities.
Full Privacy Policy
Below you will find how Hilokal handles your personal data in our mobile app and website. Your
data protection is important to us.
Hilokal Co LTD.
CEO: JeongHo YUN admin@hilokal.com
Address: #407_c, 37, Seongsui-ro 22-gil, Seongdong-gu, Seoul
주소 : 서울시 성동구 성수이로 22길 37 407_c호
Data Protection Officer
Asong Choi
asong@hilokal.com
Address: #407_c, 37, Seongsui-ro 22-gil, Seongdong-gu, Seoul
주소 : 서울시 성동구 성수이로 22길 37 407_c호
1. Personal Data
Personal data includes any information that can identify an individual. The categories of
personal data we process are:
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Contact Details: This includes your email address, and location. (not
shared with other Hilokal members)
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Profile Information: This covers details such as your age, gender, and
city.
- Profile Images: Any personal images you upload to your profile.
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Message Content: This includes images, voice messages, corrections, and
topics shared within your messages.
- Communications with Hilokal: Any correspondence you have with us.
- Log Files: Information about your visits to our website and apps.
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Online Identifiers: This includes cookie IDs, IP addresses, and advertising
IDs.
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Activity Data: Records of your interactions with our apps and websites,
such as clicks, screens viewed, and pages visited.
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Audio recordings: Hilokal audio is temporarily recorded for purposes
described below, but is immediately deleted after 2 minutes unless:
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For user-reports review: if one or more reported user is a participant of a conversation
room, the last 2 minutes of audio in such conversation room is saved for user-report
review and community moderation to protect other users.
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When you request recording: The word-count feature records and stores your audio if you
request.
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When a Premium Host makes a recording Premium Hosts have the ability to record
conversation taking place in the rooms. All users are notified the audio room is being
recorded. You may only speak and have your voice recorded if you explicitly consent
while in the conversation room.
2. Purposes of Use
We collect personal data only to the extent and for the purposes you provide it to us, such as
when registering an account. We use and store your personal data as part of our services for
the following purposes:
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User Profile Creation: To create a public user profile for you on Hilokal.
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Service Communications: To send you relevant service information via email
or push notifications, such as updates on your membership status, missed calls/messages, and
new followers.
- Targeted Advertising: To display targeted ads in the app.
- Partner Matching: To help you find Hilokal partners nearby.
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Service Optimization: To understand how Hilokal is used and to optimize our
service.
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Curated Language Learning Community: To ensure a secure, member-only
environment for language learners. We prevent abuse and promptly ban offenders by verifying
profile picture authenticity and comparing hashed photos with known scam images.
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Community Safety: To maintain a safe, friendly, and accountable environment
in one-on-one chats, parties, clubs, and group chats by encouraging authentic communication.
- Correspondence: To communicate with you.
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Survey Participation: To facilitate your participation in our surveys.
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Contract Processing: To process any contracts with you (purchasing
subscriptions, in-app purchases)
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Advertising and Newsletters: To send advertising materials such as
newsletters.
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Quality Assurance and Statistics: To ensure quality and collect statistical
data.
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Member Profile Discovery: To create a profile that helps others find and
connect with you.
Only verified members can contact you, and we never display your email, exact location, or any
information you choose not to share. We do not share your personal data with third parties
unless you give explicit consent or we are legally obligated to do so, such as by a court
order. To provide functionality and for usage analysis and marketing purposes, we collect
relevant information.
3. Legal Basis
We process your data according to the following legal grounds:
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Consent: As per Art. 6(1)(a) of the General Data Protection Regulation
(GDPR), when you have given consent for cookies or advertising.
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Contract Fulfillment: Under Art. 6(1)(b) GDPR, to establish and execute the
contract, such as when you join our community.
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Compliance with Legal Obligations: According to Art. 6(1)(c) GDPR, to meet
legal requirements.
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Legitimate Interests: Based on Art. 6(1)(f) GDPR, for processing messages
you share with your Hilokal partners in one-on-one chats, conversation rooms, and group
chats, aligning with our legitimate interests. Furthermore, statistical data and online
identifiers are processed under our legitimate interests, in accordance with Art. 6(1)(f)
GDPR.
Legitimate Interests
When processing your data, we aim to achieve the following legitimate interests:
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Community Integrity and Credibility: To uphold and enhance the integrity
and credibility of our community.
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Misuse Prevention: To protect against misuse and fraudulent activities.
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Service Provision and Improvement: To deliver and enhance our services.
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Statistics and Analytics: To gather statistical data and analyze service
usage.
4. Sources of Data
Unless stated otherwise, we collect data directly from you, including from the devices you
use.
5. Data Retention Policy
We retain your data under specific conditions to ensure compliance and functionality:
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Consent-Based Retention: If you have given consent for specific processing,
we retain your data until you withdraw your consent (e.g., by deleting your account).
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Contractual Requirements: If data is needed to fulfill an agreement, we
retain it until the contractual relationship ends or legal retention periods expire.
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Legitimate Interest: If data is used based on legitimate interests, we
retain it until your overriding interests requiring deletion or anonymization.
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Account Deletion: When you delete your account, your personal information
will be permanently removed within 30 days, but we keep your associated email address and
Hilokal ID to process future deletion requests and respond to user inquiries. Additionally,
any messages you have sent to a Hilokal partner will remain; however, the sender will be
anonymized.
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Membership Applications: We store membership applications, including
personal information, from the tutors. This information will be deleted within 30 days of
account deletion.
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Rule Violation Consequences: To maintain a safe environment, we take
violations of Terms of Service or Community Guidelines seriously. We may retain anonymous
personal identifiers for up to 24 months to prevent access to the Hilokal service during
that period.
Children and individuals under the age of 16 are not permitted to use Hilokal. If you are a
parent and discover that your child is using Hilokal without your permission, please contact
us at admin@hilokal.com.
7. Cookies
Cookies and similar technologies are small text files or pieces of code that often contain a
unique identification code. When you visit a website or use a mobile application, your device
is asked for permission to save this file and access certain information. Information
collected through cookies may include the date and time of your visit and how you use the
website or app. We use cookies to:
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Remember Information: So that you don’t have to re-enter it during your
visit or on subsequent visits.
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Provide Personalized Content: To offer custom and personalized content and
information.
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Monitor Service Effectiveness: To assess and ensure the effectiveness of
our services.
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Aggregate Metrics: To gather and analyze data such as total visitors,
traffic, and demographic patterns.
- Diagnose Issues: To identify and fix technology problems.
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Streamline Access: To help you efficiently access your information after
signing in.
- Maintain Login: To keep you logged in during your session.
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Ensure Community Safety: To keep the Hilokal community safe for all
members.
8. Data Recipients
We use your personal information within our company and share it only with third-party
companies involved in fulfilling the contracts or providing relevant services. We forward the
following customer data to third parties:
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Service Analysis: To analyze how Hilokal is used and to optimize our
service and design, we share pseudonymous usage and personal data with Google Analytics,
Firebase Analytics, and UX Cam.
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Personalized Advertising: With your explicit consent, to make ads more
personal, we may share anonymized personal information, such as age, gender, and device
identifiers with Admob by Google, and Facebook Audience Network. Both iOS and Android
devices have resettable advertising identifiers that companies can use to target ads based
on the apps you use.
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Community Moderation: To enforce our community moderation policies, we
share personal data with Camino Moderation services to process user reports.
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Disabling Mobile Advertising Identifiers:
iOS Devices: Go to your iOS device settings and enable the “Limit ad trackingˮ option.
Android Devices: Go to your Android device settings and enable the “Opt out of ads
personalizationˮ option.
8.1 Registration and Authentication
By registering or authenticating, users allow Hilokal to identify them securely and give them
access to its services. Depending on what is described below, third parties may provide
registration and authentication services. In this case, Hilokal will be able to access some
data stored by these third-party services for registration or identification purposes, with
the userʼs explicit consent:
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Facebook Authentication (Meta, Inc.): Facebook Authentication is a
registration and authentication service provided by Facebook, Inc. and is connected to the
Facebook social network. The personal data collected includes various types of data as
specified in the privacy policy of the service. Place of processing: United States –
Privacy Policy.
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Firebase Authentication (Google Inc.): Firebase Authentication is a
registration and authentication service provided by Google Inc. To simplify the registration
and authentication process, Firebase Authentication can make use of third-party identity
providers and save the information on its platform. Personal data collected: email. Place of
processing: United States – Privacy Policy.
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Google OAuth (Google Inc.): Google OAuth is a registration and
authentication service provided by Google Inc. and is connected to the Google network. The
personal data collected includes various types of data as specified in the privacy policy of
the service. Place of processing: United States –
Privacy Policy.
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Kakao Authentication: Kakao Authentication is a registration and
authentication service provided by Kakao Corp. The personal data collected includes various
types of data as specified in the privacy policy of the service. Place of processing: South
Korea – Privacy Policy.
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Naver Authentication: Naver Authentication is a registration and
authentication service provided by Naver Corp. The personal data collected includes various
types of data as specified in the privacy policy of the service. Place of processing: South
Korea – Privacy Policy.
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Sign in with Apple (Apple Inc.): Sign in with Apple is a registration and
authentication service provided by Apple Inc. In cases where users are required to provide
their email address, Sign in with Apple may generate a private relay address on behalf of
users that automatically forwards messages to their verified personal email account, thereby
shielding their actual email address from the owner. Personal data processed: email address,
first name, last name, user ID. Place of processing: United States –
Privacy Policy.
8.2 Hosting and Backend Infrastructure
These services are used for hosting data and files that enable Hilokal to operate and be
distributed, as well as providing the infrastructure needed to run specific features or parts
of Hilokal. Some of these services work through geographically distributed servers, making it
difficult to determine the exact location where personal data is stored.
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Amazon Web Services (AWS) (Amazon Web Services, Inc.): AWS is a hosting and
backend service provided by Amazon.com Inc. A wide range of personal data, including sign-in
data, images, and message content, is stored on AWS infrastructure as Hilokalʼs main hosting
and infrastructure provider. Places of processing: Germany and the United States –
Privacy Policy.
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Google Cloud Platform (Google Inc.): Google Cloud Platform is a hosting and
backend service provided by Google Inc. Personal data collected includes various types of
data as specified in the privacy policy of the service. Place of processing: United States –
Privacy Policy.
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Vultr (The Constant Company, LLC): Vultr is hosting and backend service
provided by The Constant Company, LLC. All real-time audio communication is forwarded, but
not stored, by servers on the Vultr network. Place of processing: Singapore, India –
Privacy Policy.
8.3 Payment Handling
Payment handling services allow Hilokal to process transactions securely. For enhanced
security, Hilokal does not process or store credit card details, only using the necessary
information to complete transactions with the financial intermediaries involved. Some of these
services may also send you timed messages, such as emails with invoices or payment
notifications.
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Apple App Store Payments (Apple Inc.): Hilokal uses a payment service
provided by Apple Inc. for in-app purchases. Personal data required to complete purchases is
processed by Apple as described in their
privacy policy for the App Store. Personal data processed: payment information. Place of processing: United States –
Privacy Policy.
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Google Play Store Payments (Google Ireland Limited): Hilokal uses a payment
service provided by Google Ireland Limited for in-app purchases. Personal data required to
complete purchases is processed by Google as described in their
privacy policy for the Google Play Store.
Personal data processed: payment information. Place of processing: Ireland –
Privacy Policy.
8.4 Service Monitoring
These services allow Hilokal to monitor the usage and behavior of its components to improve
features, performance, operation, maintenance, and troubleshooting. The personal data
processed depends on the service’s characteristics and implementation.
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Crashlytics (Google Inc.): Crashlytics, provided by Google Inc., helps improve app stability
and reduce crashes. Personal data collected: geographic location, unique device identifiers
(e.g., Google Advertiser ID or IDFA), and various data as specified in the service’s privacy
policy. Place of processing: United States –
Privacy Policy.
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Sentry (Functional Software, Inc.): Sentry is a monitoring service that helps improve
application stability and performance. Personal data collected: device information, error
details, and various types of data as specified in the service’s privacy policy. Place of
processing: United States – Privacy Policy.
These services enable communication with users outside the app, such as via push notifications
and email. They may manage a database of email contacts, phone contacts, or other contact
information to communicate with users. These services may also collect data about when the
message was viewed and interacted with, such as clicking on links included in the message.
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Firebase Cloud Messaging (Google Inc.): Firebase Cloud Messaging, provided
by Google Inc., allows sending messages and notifications to users across platforms like
Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or
specific topics or user segments. Personal data collected: various types of data as
specified in the service’s privacy policy. Place of processing: United States –
Privacy Policy.
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AWS Pinpoint (Amazon Web Services, Inc.): AWS Pinpoint, provided by Amazon
Web Services, Inc., is a service that enables sending targeted push notifications and emails
to users. It also allows for tracking message delivery and user interactions. Personal data
collected: various types of data as specified in the service’s privacy policy. Place of
processing: United States – Privacy Policy.
8.6 Traffic and Usage Analytics
These services enable us to monitor and analyze web and mobile traffic, tracking how users
interact with Hilokal.
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Internal Analytics (Hilokal): We use an internal analytics system that does
not involve third parties. Personal data collected: cookies and usage data.
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Google Analytics (Google Inc.): This web analysis service tracks and
examines the use of Hilokal, prepares reports, and shares them with other Google services.
Google may also use the data to contextualize and personalize its ads. Personal data
collected: cookies and usage data. Place of processing: United States –
Privacy Policy –
Opt Out.
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Firebase Analytics (Google Inc.): This service tracks usage data and shares
information with other Firebase tools, such as Crash Reporting, Authentication, Remote
Config, or Notifications. Users can opt out of certain features through device settings.
Personal data collected: cookies, unique device identifiers for advertising (e.g., Google
Advertiser ID or IDFA), and usage data. Place of processing: United States –
Privacy Policy.
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Facebook Ads Conversion Tracking (Facebook, Inc.): This service connects
data from Facebook ads with actions performed on Hilokal. Personal data collected: cookies
and usage data. Place of processing: United States –
Privacy Policy.
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TestFlight (Apple Inc.): This analytics service provided by Apple tracks
app usage and performance. Personal data collected: cookies, email address, and usage data.
Place of processing: United States –
Privacy Policy.
For further details on how these services use your data, please refer to their respective
privacy policies.
8.7 Advertising
Ads help us fund Hilokal and keep most features free. We share your age, gender, location, and
device information with advertisers to make ads more relevant and increase our revenue. We
only share your data with your consent, which you can revoke at any time. Below are the
advertising services we use:
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AdMob (Google Inc.): AdMob displays ads based on cookies, unique device
identifiers (e.g., Google Advertiser ID or IDFA), and usage data. Place of processing:
United States – Privacy Policy – Opt Out.
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Facebook Audience Network (Facebook, Inc.): This service uses cookies and
device identifiers to show ads based on user preferences. Users can manage ad preferences in
the Facebook ad settings. Personal data collected: cookies, unique device identifiers, and
usage data. Place of processing: United States
Privacy Policy –
Opt Out.
For more details on these services and how to opt out, refer to their respective privacy
policies.
8.8 A/B Testing and Content Performance
These services allow Hilokal to track and analyze user responses to changes in web traffic or
behavior regarding changes to the structure, text, or any other component of Hilokal.
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Firebase Remote Config (Google Inc.): An A/B testing and configuration
service. Personal data collected: various types as specified in the privacy policy. Place of
processing: United States –Privacy Policy.
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Google Optimize (Google Inc.): A tool for A/B testing, website testing, and
personalization. Personal data collected: various types as specified in the privacy policy.
Place of processing: United States –
Privacy Policy.
9. Data Transfer to Third Countries
Data collected within the region of your residence, which may be European Economic Area (EEA),
is transferred to countries outside the EEA, including the United States, Singapore, India,
and South Korea. We ensure that appropriate safeguards are in place to protect your personal
data in accordance with GDPR.
These safeguards include:
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Adequacy Decisions: Transfers to countries that the European Commission has
deemed to provide an adequate level of data protection.
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Standard Contractual Clauses: Use of standard data protection clauses
approved by the European Commission.
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Other Legal Mechanisms: Use of other legally recognized mechanisms and
safeguards as required.
10. Your Rights
As a Hilokal user, you have the following rights regarding your personal data:
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Access and Information: Request details on whether and what personal data
is processed by us, and how it has been processed.
- Correction: Request amendments to your personal data.
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Deletion: Request deletion of your personal data, for example by using the
“Delete Accountˮ option in “My Page-Settings-Manage accountˮ. However, deletion may be
refused in accordance with GDPR and other applicable laws.
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Restriction: Request restrictions on the processing of your personal data
under certain conditions. When this right is exercised, the data may be stored but can only
be processed for limited purposes, and it cannot be used for other purposes without the your
consent.
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Object: Request objections to the processing of your personal data under
certain conditions. Revocation of Consent: Revoke your consent to data processing at any
time, with future effect.
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Data Portability: Receive your personal data in a common, structured, and
machine-readable format via the “Manage accountˮ ⇒ “Download personal dataˮ ⇒ “Submit
Request” button in “My Pageˮ. Your Data will be sent to you via Direct Message in Hilokal as
a ZIP file.
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Contact: For questions, comments, complaints, or requests related to data
protection. admin@hilokal.com
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Complaints: Lodge a complaint with the relevant supervisory authority if
you believe your personal data processing violates legal regulations.
11. Automated Decision-Making and Profiling
We may use automated decision-making processes, including profiling, to provide personalized
services or ads. This means decisions are made by algorithms without human intervention.
Profiling helps us analyze or predict your personal preferences, interests, behavior, and
other attributes. You have the right not to be subject to decisions based solely on automated
processing that significantly affect you. This right does not apply if the decision is
necessary for a contract, authorized by law, or based on your explicit consent.
12. Data Provision Requirements
Unless explicitly stated otherwise, providing data is not mandatory or required when it is
collected. However, please note that restriction or objection to the processing of your
personal data may result in restriction of certain services requiring the data.
Date of issue of this data privacy statement
2024-06-11