Privacy Notice

Last Modified: March 12th, 2024

Introduction

Aylo Social Ltd (hereinafter "we", "us", or "our") operates the website www.nextdoorhobby.com (hereinafter "NextDoorHobby") and is the controller of the information collected or provided via NextDoorHobby.

Please read this Privacy Notice carefully, as your access to and use of NextDoorHobby signifies that you have read, understand, and agree to all terms within this Privacy Notice. We respect your privacy and are committed to protecting your Personal Information.

If you have any questions about our privacy practices, please see the section "Contact Information" below for information on how to contact us.

1.       Scope

For the purposes of this Privacy Notice, "process", "processed", or "processing" means any operation or set of operations performed on personal data or on sets of Personal Information or data (excluding disclosure thereof) as defined hereinafter, by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of personal data or of sets of personal data or Personal Information as defined hereinafter may be found in the "Disclosure of Your Personal Information" section below.

This Privacy Notice applies to information we collect:

It does not apply to information collected by:

2.       The Data We Process About You

For greater certainty, the term "Personal Information" means any information or data regarding a user which can lead to identify such user, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person or user. It does not include data that has been anonymized or pseudonymized.

We may, depending on whether if you are an unregistered or a registered user on NextDoorHobby, process, collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

·         Identifiers and Biometric Information: When accessing NextDoorHobby in some States or countries, when creating an account and subscribing to NextDoorHobby as case may be, we will process the identifiers you submit to us. Where we are legally required to do so to grant you access to the content on NextDoorHobby, we will collect biometric information, which you will provide, to verify the authenticity of the identifiers you provided us to verify your identity, as further explained in the section "Biometric Information" below.

3.       Biometric Information

In some states or countries where the law requires, we may employ third-party service providers to verify your identity, age, and to verify the authenticity of the identification documents you provide us using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features which are detected from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is shared by our service providers with us. Your biometric information will be collected and processed to:

 

You will be asked to provide your consent to biometric information processing which you may withdraw at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.

Please note that this section entitled "Biometric Information" only applies to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to NextDoorHobby in some states or countries only. We will store your biometric information according to the section "Retention of Personal Information" below.

 

4.       How is Your Personal Information Collected

We use different methods to collect data from and about you including through:

 

5.       User Contributions

When you use NextDoorHobby, we provide functionalities where you can add or remove a model or content from and to your favourite list. To request removal of your Personal Information from NextDoorHobby, please visit the section ‘Manage Your Personal Data’ below or send an e-mail at privacy@nextdoorhobby.com to help you initiate the process. In some cases, we may not be able to remove your Personal Information, in which case we will inform you accordingly.

6.       Cookies and Automatic Data Collection Technologies

As you navigate through and interact with NextDoorHobby, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include use of cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

We currently use the following types of cookies, which are set by NextDoorHobby:

Analytics, Functionality, Targeting and Advertising cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of NextDoorHobby. However, if you decline to accept these cookies, some functionality on NextDoorHobby may be disabled and may interrupt your access to certain parts of NextDoorHobby.

Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.

Do Not Track: Our systems do not recognize browser "Do Not Track" signals.

Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use NextDoorHobby, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, NextDoorHobby uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with NextDoorHobby on different devices (cross-device activity). Google Signals applies to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

7.       Third-party use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements on NextDoorHobby are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party features on NextDoorHobby or directed to such third-party website. Unless expressly stated otherwise, NextDoorHobby does not provide any Personal Information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access NextDoorHobby to provide targeted content. You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

8.       Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us.

·         The Cookie Banner can be utilized to customize your cookie preferences, if available. The Cookie Banner will record when you have consented to our cookies. For logged in users, we will ask for consent every 6 months or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookie and privacy policies. For non-logged in users, your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the Functionality, Analytics, and Advertising cookies set by using NextDoorHobby. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from NextDoorHobby.

·         You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of NextDoorHobby.

9.       How We Use Your Personal Information

We will only use your Personal Information when the applicable local law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

 

10.   Purposes for Which We Use Your Personal Information

In general, we use information that we collect about you or that you provide to us, including Personal Information, for following purposes:

 

11.   Disclosure of Your Personal Information

We disclose your Personal Information to and for the following purposes:

·         To comply with the law or protect our rights or the rights of third parties: We access, preserve and share your Personal Information with regulators, law enforcement, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms & conditions, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of NextDoorHobby or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

·         Transaction Information: Transaction information, including Personal Information that you have provided to us will only be shared with our third-party processors to initiate and complete any orders placed on or through your account. All credit card transactions and such are processed with industry-standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions, and policies of a third party. All such information provided to a third party is subject to their terms and conditions.

·         Aggregated data: We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.

For more information on recipients of Personal Information, please contact us by using the information in the Section Contact Information below.

12.   Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your Personal Information only where:

·         You provide your consent to do so for a specific purpose: for example, when you allow us to show you personalized features or to send you e-mail marketing;

·         Biometric information is also processed based on your consent. You may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal;

·         It is necessary to perform our contractual obligations as per our Terms and Conditions for example, to create your account and subscribe you to NextDoorHobby;

·         It is necessary to comply with our legal obligations: for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation;

·         It satisfies a legitimate interest which is not overridden by your data protection interests: for example, to keep NextDoorHobby safe and secure from fraud and illegal activities;

·         It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud, and

·         It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area ("EEA"), Switzerland or the United Kingdom ("UK"), the legal bases on which we rely may differ from those listed above.

 

 

13.   Transfers of Your Personal Information to Other Countries

We share the information we collect globally, both across our corporate group and data centres, and externally with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Use and this Notice or so that we can fix, analyse and improve our products.

When we transfer Personal Information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where available, we rely on decisions of the European Commission, known as "adequacy decisions", recognizing that certain countries offer a level of protection of your Personal Information that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section "Contact Information" below on how to contact us.

14.   Retention of Personal Information

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless we have a legal obligation or a preservation or court order which would legally oblige us to retain your Personal Information for a specific period, where we no longer need to process and retain your Personal Information in accordance with this Privacy Notice, we will delete your Personal Information from our systems.

Where permissible, we will also delete your Personal Information upon your request. Information on how to make a deletion request can be found under "Your Rights Related to Your Personal Information".

For more information on our data retention periods, please contact us by using the information in the section "Contact Information" below.

 

15.   How We Protect the Security of Your Personal Information

We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.

You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on NextDoorHobby.

16.   Your Rights Related to Your Personal Information

Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:

If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of NextDoorHobby, some of our services or NextDoorHobby platform as case may be.

You can exercise your Rights of Access or Deletion by following the dedicated links in the section "Manage Your Personal Data" below. You can also send an e-mail at support@nextdoorhobby.com to help you with the process. Please note that we have one month to respond to your request.

Prior to processing an access or deletion request, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address).

17.   California Rights and Choices

The California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their Personal Information, as this term is also defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, such Consumers have the right to:

If the CCPA is applicable to you and you would like to exercise the rights described above, please use the links at the bottom of this page or email us at privacy@nextdoorhobby.com with the subject line "CCPA Request." In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you to verify that you have access to your account and/or verify the email account used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

We disclose certain categories of California residents’ Personal Information for our business purposes, as described in the section above titled "Disclosure of Your Personal Information".

18.   Resident’s Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange your Personal Information with anyone for money.

19.   Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:

1.       The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest

2.       The document(s) you are serving is correctly issued by a valid court of law or equivalent legal or administrative authority to Aylo Social Ltd;

3.       The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540

We reserve the right to refuse online service through our Legal Service Process Platform, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

20.   No Rights of Third Parties

This Privacy Notice does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of NextDoorHobby.

21.   Our Policy Towards Minors

NextDoorHobby prohibits minors from accessing or using its platform in any way. NextDoorHobby is forbidden to persons under the age of eighteen (18) years old or the applicable age of majority in the jurisdiction from which NextDoorHobby is accessed. We do not knowingly collect Personal Information from minors. If you become aware that a minor has provided us with Personal Information in any way, inadvertently, fraudulently or erroneously attempted to provide us such information with the intent to access NextDoorHobby, please contact us at privacy@nextdoorhobby.com to remove such information immediately.

22.   Changes to Our Privacy Notice

We may modify or revise our Privacy Notice from time to time. Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the "Last Modified" date mentioned in the header of this Privacy Notice.

23.   Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@nextdoorhobby.com.

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

Our Data Protection Officer can be contacted at the following email address: dpo@nextdoorhobby.com

24.    Manage Your Personal Data

With respect to applicable Data Protection Laws in their jurisdiction, registered users may request a copy of their personal data or request the deletion of their personal data via the links below. Please note that the below website is governed by the present Privacy Notice.

REQUEST A COPY OF MY PERSONAL DATA

DELETE MY PERSONAL DATA[KP1] 

Note: AdBlocker add-ons interfere with the Manage My Data system. Please disable them.

 




AYLO BILLING US CORP, 610 BRAZOS STREET - SUITE 500, AUSTIN, TEXAS 78701
AYLO BILLING LIMITED, 195-197 OLD NICOSIA-LIMASSOL ROAD, DALI INDUSTRIAL ZONE 2540, BLOCK 1, CYPRUS