Date Last Updated: 13.September.2022
Huxly Inc. and its affiliated entities (“Huxly,” “we,” “our,” and “us”) are committed to protecting
individual privacy and maintaining trust with our business clients (“Clients”), and our Clients’ audiences
and end users (collectively, “End Users”).
platforms, and services (the “Huxly Platform”).
We provide the Huxly Platform to our Clients for use
via social media platforms. Our Clients use the Huxly
Platform to deliver interactive content over the messaging functions of various
social media websites and applications.
that Huxly typically has no direct relationship with
End Users. We simply process and store End Users’ information, including
Personal Information, on our Clients’ behalf and at our Client’s direction as
their service provider. Any use of
Personal Information is carried out pursuant to an agreement in place between Huxly and the applicable Client.
If you, as an End User, have any questions or
concerns about the data handling practices of our Clients using the Huxly Platform, please contact the Client (or Clients) with
whom you have interacted.
1. Information We Collect
2. How We Use Information
3. How We Disclose Information
5. Do Not Track
6. Information Regarding Children
7. Your Privacy Rights
8. Legal Disclaimers
10. Updates to This Policy
11. Contact Us
Information We Collect
On behalf of our Clients, we
collect information that identifies, describes, or is reasonably capable of
being associated with End Users (“Personal
Information”). Personal Information does not include publicly available
information from government records, deidentified information, or aggregated
information. We collect and use different types of Personal Information for
various reasons depending on how End Users interact with the Huxly Platform and our Clients. The following describes the
types of Personal Information we collect on behalf of our Clients.
Personal Information We Collect Directly From End Users
We may collect Personal Information directly
from End Users who interact with the Huxly Platform. The Personal Information we collect on
behalf of our Clients may include:
Contact Information. We collect information such as End Users’ first and last name.
Social Media Information. We collect social media
information related to an End Users’ social media username, profile
information, profile picture, gender, or other information available on the social media
Message Contents. If an End User sends messages to our Clients through social media via
the messaging function, we also collect message contents, including responses
to open ended or multiple-choice questions, and any other information End Users
may choose to provide.
Preferences. We also may collect information about End Users’
preferences, including communications preference and other preferences End
Users provide when interacting with our Clients.
Personal Information Collected Passively or
We may automatically collect the following
Personal Information from or about End Users who interact with our Clients:
Device Identifiers. When an End Users interacts with
our Clients, we may automatically collect information such as IP address,
unique device identifiers, operating system, and other information related to
the device used to interact with our Clients via the Huxly
Network and Activity Information. We may collect information related
to how End Users interact with our Clients in the Huxly
Platform, including interactions with advertisements, such as referring and exit web pages and
URLs, browsing history, and other similar information. As described below in
technologies, including cookies and similar tools, to collect this information.
To the extent permitted by applicable law, we
may combine this information with other information we collect, including End
Users’ Personal Information.
Information We Collect From Third Parties
When End Users interact with our Clients, we may
collect Personal Information about End Users through our service providers,
affiliates, and vendors who provide services on our behalf.
How We Use Information
We may use the Personal
Information we collect for the following purposes:
Operate Our Business. We use Personal Information to
allow End Users to use our services, interact with our Clients via the Huxly Platform, and to otherwise run our day-to-day
Data Analysis. We use Personal Information
collected from and about End Users to conduct data analysis and to provide
insights to our Clients on End Users.
To Communicate With
You. We may use Personal Information
to communicate with End Users about our services, and to respond to inquiries.
Evaluate and Improve Our Platform. We may use the Personal Information
we collect to evaluate and improve the Huxly
Platform, and to measure, improve, and understand the effectiveness of our
platform and its features. We may also use this information to develop new
Security Purposes. We may use Personal Information to
mitigate fraud and protect Huxly.
Legal Requirements. We may use Personal Information to
comply with lawful court orders, law enforcement requests, or other legal
Other Operational Purposes. We may use Personal Information for purposes not provided
for in this Policy, but if we do, we will notify the End User (and, if
necessary, obtain consent) before using the Personal Information in that way.
How We Disclose Information
We may disclose End Users’
Personal Information with the following parties:
Service Providers. We disclose information we
collect from End Users to service providers, vendors, contractors, or agents
who perform functions on our behalf. This includes entities that host the Huxly Platform, perform research and development, and assist us in performing
Client and Business Partners. We disclose information we
collect to our Clients and business partners for purposes of delivering interactive content.
Affiliates. We disclose the information we
collect to our affiliates or subsidiaries.
We also may disclose End User
Personal Information in the following circumstances:
At an End User’s Request. We may disclose information to
others when it is necessary to provide the services requested.
Business Transfers. If (i)
we or our affiliates are or may be acquired by, merged with, or invested in by
another company, or (ii) if any of our shares or assets are or may be
transferred to another company, whether as part of a bankruptcy or insolvency
proceeding or otherwise, we may transfer the information we have collected from
you to the other company. As part of the business transfer process, we may
share certain of Personal Information with lenders, auditors, and advisors,
including attorneys and consultants.
In Response to Legal Process. We disclose Personal Information
to comply with the law, a judicial proceeding, court order, or other legal
process, such as in response to a court order or a subpoena. If we receive such
a request we will take reasonable steps,
resources-permitting, to challenge such request and, if we are ultimately
unsuccessful in our challenge, we will strive to limit our disclosure to only
what is absolutely necessary.
To Protect Us and Others. We disclose Personal Information
when we believe it is appropriate to do so to investigate, prevent, or take
action regarding illegal activities, suspected fraud, situations involving
or this Policy, or as evidence in litigation in which we are involved.
With an End User’s Permission. We may disclose Personal
Information in ways not described above. If we do so, we will notify End Users,
and if necessary, obtain consent.
tracking technologies (“Cookies”) on
our website (huxly.co) to provide, customize, evaluate, and improve our
services. A Cookie is a small piece of text that is placed on your device’s
browser when you visit a website. These include our own first-party Cookies as
well as third-party Cookies of our service providers and partners. Some Cookies
are only stored temporarily and are destroyed each time you close your web
browser. We also use persistent Cookies, which do not delete when you close
your browser and may collect and store data for a set period of time after
leaving our platform.
Performance and Analytics. Cookies help us analyze how you
interact with our Clients via the Huxly Platform.
These Cookies enable us to monitor and improve our platform’s performance, our
services, and End User experiences.
to Manage Cookies
If you wish to prevent Cookies
from tracking your activity you can set your browser to block certain Cookies
or notify you when a Cookie is set. If you block Cookies, certain features and
services may not work. For more information on how you can customize your
browser’s Cookie setting, please visit the link to your web browser below:
We are not responsible for the
completeness, effectiveness, or accuracy of any third-party opt-out options or
Do Not Track
Some web browsers and mobile
operating systems offer a “Do Not Track” setting you can activate to signal
your preference not to have data about your online browsing activities
monitored and collected. Currently, the Huxly
Platform and our services do not recognize “Do-Not-Track” requests.
Information Regarding Children
We do not knowingly collect
Personal Information from End Users under the age of thirteen (13) without
parental consent. If we become aware that we have collected information from a
child under 13 years old without parental consent, we will delete such
information from our records. If you are a parent or legal guardian and believe
your child has given us information and you did not provide consent, please
contact using the information provided in the “Contact Us” section below.
Your Privacy Rights
Our Clients are responsible for
what they do with the Personal Information they collect about End Users using
the Huxly Platform. End Users may have certain rights
regarding their Personal Information. Please note these rights are generally
exercisable against Huxly’s Clients and not against Huxly because Huxly is acting as
a service provider to our Clients.
End Users who have questions or concerns about
the data handling practices of our Clients or who wish to exercise privacy
rights should contact the relevant Client directly. Where necessary, Huxly will assist our Clients with an exercise of a privacy
right by an End User.
Nothing in this Policy restricts
our ability to:
with federal, state, or local laws;
with a civil, criminal, or regulatory inquiry, investigation, subpoena, or
summons by federal, state, or local authorities;
with law enforcement agencies concerning conduct or activity that we reasonably
and in good faith believe may violate federal, state, or local law;
or defend legal claims;
security incidents and protect against fraudulent or illegal activity and
prosecute those responsible for such activity; or
Personal Information as part of a merger or acquisition, dissolution,
bankruptcy, or any other transaction in which a third party assumes control of
all or part of our business.
Platform may contain links to unaffiliated websites. Any access to and use of such linked websites is
not governed by this Policy, but instead is governed by the privacy policies of
those websites. We are not responsible for the information practices of such
Updates to This Policy
This Policy is current as of the
Effective Date set forth above. We may change this Policy from time to time, so
please be sure to check back periodically.
If you have questions about this
Policy, the privacy aspects of our platform, or would like to make a complaint,
please contact us at: