Seven Hats Information Technology Solutions (“Seven Hats Information Technology Solutions”, “Company” “we” or “us”) respects the privacy of the visitors and/or users of its primary website at: https://www.sevenhatssolutions.com (including its subdomains), mobile “App(s)” and any other websites operated by us (collectively, the “Site”) (“User” or “you”) and is committed to protecting its Users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site.

We strongly urge you read this Policy and make sure you fully understand our practices in relation to personal data, before you access or use any of our Site. If you do not agree with this Policy, please do not use the Site or any App that we published on Apple App Store or Google Play Store. By accessing and using the Site, you agree to this Policy. If you have any questions, please contact us at: support@sevenhatssolutions.com.

Capitalized terms which are not defined in this Privacy Policy, shall have the meanings given to them in our Terms of Use at: https://www.sevenhatssolutions.com/terms-of-use/ (“TOU”).

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1. Which information may be collected?

We may process two types of data and information about our users:
 

a. Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom Non-personal Information has been collected. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available while such User is entering into and/or using the Site our Apps. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information (e.g. the activity of the User on the Site, User’s ‘click-stream’ or searches on the Site, type and version of browser, etc.).
 

b. Personally identifiable information (“Personal Information”). This is information from which an individual can be identified.

In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User: Personal Information may be collected from the details the Users provide in our websites or App, which may include the User’s e-mail address, full name, company, phone number, CV file, and any text and or information or documentation the User wishes to submit.
 

1. If you engage with us through social media (eg Facebook, Linkedin, Instagram, Twitter or Youtube), we may collect Personal Information you voluntarily provide, such as messages you post on our social media pages. If you upload content, including your Personal Information, to a social network and then tag our Site, your submission will be subject to that social network’s terms of use and privacy notice, even where you post on an official Seven Hats Information Technology Solutions page on the social network. We do not have control over these terms of use and privacy policies and have not reviewed their adequacy. You should therefore review these before submitting any Personal Information.
   
   If you are an app publisher and have included Personal Information in your app store listing or your site/s e.g. your name, e-mail address, we may also process this Personal Information for the purposes described below.

2. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
    

2. How is Information being processed

• through your entry and use of the Site or App. In other words, when you are using the Site  or App, we are aware of it and may process, gather, collect and/or store the information relating to such usage, either independently or through the help of third party service providers.
   

• when you decide to provide us with your information voluntarily.For example, we collect Personal Information which you voluntarily provide when you fill in a Contact Form on the Site or App, submit a content to us, provide us with your information on the careers page or transmit communication to any of our e-mail addresses available on the Site. We may gather, collect and store the Personal Information either independently or through the help of our authorized Third Parties.
   

• For content publishers we may also collect limited Personal Information which you post on your app store listing, either directly from your listing or from third parties which collect and aggregate this information, or on your site/s.
   

3. What are the Purposes of the Processing of Information?

Non-personal Information is processed for:

• Statistical and research purposes,

• Customization and improvement of our Site and services, and

• Safeguarding the Site and App.
   

Personal Information is processed to:

• Reply to the User’s questions, requests and/or concerns sent by the Users via or in connection with the Site and/or its services.

• Contact Users for the purpose of providing them with technical assistance and support

• Contact Users who are interested in applying for jobs at Seven Hats Information Technology Solutions.

• Contact Users for the purpose of providing updates on any programs or promotions they are taking a part in, and/or on future programs or promotions.

• Safeguard our Site and Users.

• Provide the Site and Services to you.

• We may use such Personal Information for the above purposes via any applicable communication channel, including e-mail, SMS, etc.

For content publishers we use the limited Personal Information referred to above to contact you for business purposes.
 

4. Sharing Information with Third Parties

We may share Personal Information in the following cases:
 

(a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
(b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations;
(c) to detect, prevent, or otherwise address fraud, security or technical issues;
(d) to respond to User’s support requests;
(e) to respond to claims that any content available on the Site or App violates the rights of third-parties;
(f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment;
(g) to protect the rights, property, or personal safety of the Company, its Users, or the general public;
(h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets;
(i) with third party service providers (including our affiliates) who we engage in connection with our provision of the Site and Services, and who are required to protect your Personal Information and only use it on our instructions;
(j) to store or process your Personal Information through our affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction. We require our affiliated entities to agree to process your Personal Information in compliance with this Policy;
(k) pursuant to your explicit approval prior to the disclosure; or
(l) to cooperate with third parties for the purpose of enhancing the User’s experience. For avoidance of doubt, we may transfer and disclose Non-personal Information to third parties at our own discretion.

Please see section 13 for more information on international transfers of Personal Information.
 

5. Deletion, Modification and Retention of Personal Information

If for any reason you wish to delete or modify your Personal Information please send us an e-mail with adequate detail of your request to: support@sevenhatssolutions.com and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations and to resolve disputes or to enforce our Terms, all as permitted under any applicable privacy laws.
 

Aggregated and/or anonymous information derived from your use of the Site may remain on our servers indefinitely.

Users in the EEA can refer to section 15 below.

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6. Minors

The Site or App is not intended for Users who are children. Therefore, the Company does not intend and does not knowingly collect Personal Information from children and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Site. If we learn that we collected Personal Information from children we will delete that information as quickly as possible. Please contact us at support@sevenhatssolutions.com if you have reasons to suspect that the Company has collected Personal Information from children and we will delete that information as quickly as possible.
 

7. Security

We take reasonable measures to maintain the security and integrity of our Site, App and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
 

8. Links to Third Party Websites

Certain links provided on our Site permit our Users to leave the Site and enter third party sites or services (including but not limited to Facebook’s “Share” and “Like” buttons available in our Site, Instagram, Twitter and Google+). The Company is not responsible or liable for such linked sites and services’ privacy practices and/or any other practices. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. Those linked sites and services are provided solely as a convenience to you. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use of those sites. It is always advisable to read such documents carefully before using those sites and services, so that you understand what kind of information they are collecting.
 

9. Cookies and Other Tracking Technologies.

When you access or use the Site or App, we or our Third Parties may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies“), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized Third Parties may use both session cookies (which expire once you close the Site) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase Cookies from your computer’s hard drive, block acceptance of Cookies, or receive a warning before a cookie is stored. However, if you disable or erase Cookies, your online experience may be limited. Cookies usually store only Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc.
 

All of the Cookies are managed by third parties who have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.
 

We use the following Cookies on our Site:

Google Analytics: These are performance cookies which allow us to assess how you and other web users use our Site. This information is essential in helping us to continuously improve our Site’s functionality. These Cookies will be preserved for a maximum period of 2 years and the information generated by them about your use of our Site (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States. For information on how these cookies collect and process data please see www.google.com/policies/privacy/partners/ and for information on how to opt-out of tracking technologies from Google Analytics, please visit https://tools.google.com/dlpage/gaoptout?hl=None
 

Wpfront plugin: These are functional Cookies which are used to display notifications on our Site.

Internet browsers allow you to change your Cookie settings, for instance to block certain kinds of Cookies or files. You can therefore block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies, you may not be able to access all or parts of the Site or the Site may not work as well as you will have blocked functionality Cookies. For further information about deleting or blocking Cookies, please visit: http://www.allaboutcookies.org/manage-cookies.

10. Direct Marketing

Where permitted by applicable law, we may use your email address to keep you informed about our Apps, products and services (including competitions we may hold) and to send you other marketing material which may be of interest.  If applicable law requires your consent for us to use your email address for direct marketing, we will only send you marketing where you have provided such consent.   In all cases, you may withdraw your consent by sending a written notice to Seven Hats Information Technology Solutions by email to the following address: support@sevenhatssolutions.com or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.

11. Philippine Data Privacy

Republic Act No. 10173, otherwise known as the Data Privacy Act is a law that seeks to protect all forms of information, be it private, personal, or sensitive. It is meant to cover both natural and juridical persons involved in the processing of personal information. Seven Hats Information Technology Solutions will abide by this law.

12. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as making transfers subject to contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. If you are an individual based in the EEA, you can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
 

13. Changes to the Privacy Policy

The terms of this Privacy Policy govern use of the Site and any information collected via the Site. The Company may change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site. Such substantial changes will take effect five (5) days after such notice was provided on our Site. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.
 

14. Legal Bases For processing Personal Information

We will only collect, use or share your Personal Information for the purposes set out in this Privacy Policy where we are satisfied that:

1. Our use of your Personal Information is necessary for communicating with you, for answering to your request, for managing your job application or for giving you access to the Site;

2. Our use of your Personal Information is necessary to support legitimate interests that we have as a business to provide our Site or App, services and interactive applications for mobile devices to our customers, provided it is conducted, at all times, in a way that is proportionate, and that respects your privacy rights;

3. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have. For example, to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law; or

4. You have provided your consent to us using your Personal Information for that purpose.
    

Where the basis of processing is your consent, you have the right to withdraw your consent at any time.
 

15. Additional Information for individuals in the EEA

Seven Hats Information Technology Solutions currently has no representative in EEA. We will consider our support for EEA data privacy when we have enough users in EEA.

16. Got any question?

If you have any question (or comment) concerning this Privacy Policy, you are most welcome to send us an email to the following address: support@sevenhatssolutions.com.

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