Privacy Notice

Effective date: 06/01/2017

(“Company”, “we”, “our”, or “us”) operates the site and subsites located at and mobile applications (collectively “Site”) and provides the content (including email and electronic communications) and services (collectively “Services”) offered on or through the Site. “Platform” means the “Site” and/ or “Service”.

This Privacy Notice explains how we collect, use, share and protect information about visitors or registered users on, from or through the Platform and the choices that visitors and registered users have about the collection and use of certain information about them.

Scope

This Privacy Notice applies solely to information that we collect from visitors and registered users through the Platform or through electronic communications that we receive at the address indicated in section “How to Contact Us”.

A “visitor” is an individual who visits the Platform, without having registered. We do not know the identity of the individual.  A “registered user” is an individual who has registered with the Platform, and whose identity can be determined directly or indirectly from the information provided. For the purpose of this Privacy Notice “you” means a visitor or a registered user; and a “visitor” includes a “registered user”.

This Privacy Notice does not apply to the websites of third parties to which the Platform may link. We do not endorse, and are not responsible for the content of such websites, their policies or practices, or any product or service that they may offer. Any activity you perform on such third-party websites will be subject to the privacy policies and other terms and conditions expressed therein. We recommend that you review third-party terms before providing any personal information to them.

Consent

By using the Platform, you agree to the terms of this Privacy Notice. Please ensure that you read this Privacy Notice carefully.

We may modify this Privacy Notice from time to time. We will notify you of material changes to this Privacy Notice by posting the amended terms in accordance with applicable laws. If you do not agree with the proposed changes, you should discontinue your use of the Platform before the new Privacy Notice takes effect. If you continue using our Platform after the new terms take effect, you will be bound by the modified Privacy Notice.

Children

The Service is a general audience service. Our content is neither directed towards minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we become aware that a minor or a child under the age of 13 has provided us with personal information without parental consent, that information will be deleted. Parents who have questions about personal information that may have been submitted by a child under the age of 13 should email us at the address provided in the “How to Contact Us” section.

By using the Platform, you represent that you are at least 13 years old.

How we Collect Information

We (and our service providers) collect information in a variety of ways, such as through the methods identified below:

  • From the visitor’s browser, such as the screen resolution, operating system name and version, device manufacturer and model, language, or browser type and version.
  • Through a visitor’s activities offline, for example when a visitor responds to a newsletter or interacts with us by telephone.
  • Through the visitor’s activities online, such as when a visitor responds to an email, fills out an online form or responds to a survey.
  • Through social media.
  • Through cookies and other technologies that help us track and analyze how visitors interact with our Platform.
  • By receiving additional information from third parties.

Information We Collect

We collect information from visitors when they interact with the Platform. This includes, for example, the following:

Information we Collect Automatically

When a visitor uses, or interacts with our Platform the visitor’s browser automatically provides, and we automatically collect and store, certain information about the visitor’s device (computer, tablet, smart phone) and the visitor’s activities. This includes, for example:

  • Preferences and settings: time zone, language, and character size, among others;
  • Identifiers: IP address; mobile device advertising identifier, Media Access Control (MAC) address, among others;
  • Technical information: type of device, operating system name and version, device manufacturer, model, browser information (type, version), screen resolution, installed and uninstalled applications running in the background, among others;
  • Connection: Internet service provider or mobile carrier’s name, country, connection speed and connection type, Bluetooth settings, among others;
  • Information about use of the Platform: date stamp, URL of the last webpage visited before visiting our Platform, and URL of the first page visited after leaving our Platform, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, comments made, search history, type of service requested, purchases made, among others;
  • Information collected through cookies, pixel tags, and other technologies; and
  • General geographic location.

Communications and Interaction

When a visitor registers to have access to the Platform (thereby becoming a “registered user”), when we send a communication to a visitor, or when the visitor accesses, responds to, or declines to open a communication from us, completes a form to communicate with us, or contacts us, we collect and store certain information about the visitor, the visitor’s device (computer, tablet, smart phone) and the visitor’s activities, such as:

  • The visitor’s name, login ID or pseudonym and contact information (if provided);
  • Information that the visitor provides or comments that the visitor makes;
  • The nature of the communication;
  • The purpose of the interaction, and the action we took in response to the visitor’s inquiry or request;
  • Whether the visitor opened our communication or ignored it;
  • Any action the visitor takes upon receipt of such communication.

Social Media

Our Platform includes social media features that may be managed by us or by third parties. These features may collect a visitor’s IP address and which pages the visitor is visiting, and may set a cookie to enable the feature to function properly. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services.

We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

Information we Obtain from Third Parties

We may obtain information from third parties, such as third parties with whom we do business, such as strategic business partners, service providers, public databases, or social media services to which our Platform might be linked.

We may work with third party analytics services to help us understand how the Platform is being used, such as tracking the frequency and duration of use of the Platform. We use analytics services from providers who use cookies and similar technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting the Platform, and your system information and geographic information. The information generated by these cookies and other technologies is transmitted to and stored by the applicable analytics services.

Use of Information

In addition to some of the specific uses of information that are described in this Privacy Notice, we may use the information that we have collected or received to:

  • Send administrative information to the visitor;
  • Remember the visitor’s preference, such as language, font size, when using our Platform;
  • Remember the visitor’s interests;
  • Administer our Platform, diagnose technical problems, and otherwise manage our business;
  • Facilitate the visitor’s use of the Platform;
  • Allow the visitor to navigate or browse through our Platform quickly and efficiently;
  • Personalize the visitor’s experience by presenting content that is tailored to that specific visitor based on what we know about that visitor;
  • Keep records of contact information and correspondence;
  • Send marketing information;
  • Communicate with the visitor about our activities;
  • Send invitations to events that may be of interest to the visitor;
  • Facilitate social sharing functionality, such as sharing content, through social media networks;
  • Allow the visitor to share content with a friend through the Platform; by using this feature, you guarantee that you have the right to use and provide us the names and email addresses you submit.
  • Improve, test, and monitor the effectiveness of the Platform;
  • Develop features for the Platform that may be of interest to our visitors;
  • Optimize our marketing efforts, for example by compiling statistics regarding the use of the Platform, identifying usage trends, or measuring the effectiveness of our promotional campaigns;
  • Perform data analysis, audits, security and fraud monitoring and prevention;
  • Enhance, improve, or modify our Platform; identify usage trends;
  • Help diagnose technical problems, and detect spam behavior, denial of service attacks or  other cyber-threats.

Sharing of Information with Third Parties

Some of the technologies used on our Platform are managed by third parties. The practices of some of these third parties are subject to the third parties’ privacy policies over which we may have no control. We encourage visitors to read their privacy policies. Third parties who may have access to information may include:

Employees; Service Providers

We share information with our employees, suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with advertising, hosting, data analytics, information technology and infrastructure, email delivery, auditing, and other related activities.

Affiliates

We may share some or all of our visitors’ or registered users’ information with our corporate affiliates, joint venture partners, or other companies under common control with us. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out of this sharing by emailing us at the address provided in the “how to contact us” section.

Partners and Sponsors

Some of our content is offered or promoted in conjunction with a partner or sponsor. We may share visitor information with such parties in order to serve such content to the most appropriate audience.

Third Party Marketing Partners.

If you opt-in to receive marketing communications from third parties, we may, from time to time, share the information you provide to us with selected third party marketing partners that we believe offer products or services that may be of interest to you.  If you would like us to stop providing your information to our third-party marketing partners, you may opt-out by contacting us at the address provided in the “how to contact us” section.

Social Media

The Platform may include links to third party websites and social media services where a visitor is able to post comments, reviews or other information. Please note that any information that is posted or disclosed through these social media services may be available to us, or to other visitors of that service or the public. We recommend caution when using these features.

Legal Requests and Preventing Harm

To the extent permitted by law, we will disclose a visitor or registered user’s information to government authorities or third parties if: (i) required to do so by law, or in response to a subpoena, search warrant, court order or similar request from a judicial entity having jurisdiction; (ii) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (iii) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Change of Control

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of the Service to third parties.  Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Aggregated, Anonymized, or Statistical Information

We generate and use aggregated, anonymized, or statistical information about the use of our Platform. We may provide this information to third parties such as advisers or consultants for research, analytical or strategic purposes. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

AD CHOICES

Cookies and other Tracking Technologies

We use cookies, beacons, pixels, tags, statistical IDs, flash cookies, and similar tracking technologies to collect information about the activities of our visitors and registered user over time and across different Sites, such as the pages a visitor views, the links on which a visitor clicks, how frequently a visitor accesses the Platform, and other visitor attributes and behaviors.  We also collect log file information from a visitor’s browser such as web request, IP address, browser type, referring / exit pages and URLs, and landing pages.  We may use statistical modeling tools to attempt to recognize visitors across multiple devices.

We may retain the services of third party service providers who may link personal information about a visitor – such as name or email address – to other information they may have – for example, past purchases. This information may allow us to identify assumed interests or preferences of that visitor, so that we can provide a visitor with more useful and relevant offers or services.

We use cookies and tracking technologies to, among other things:

  • Display information more effectively;
  • Gather statistical information about the use of the Platform, to understand how our Platform is used, and improve design and functionality;
  • Store, on a visitor’s device, information about that visitor’s preferences and settings;
  • Recognize a visitor when the visitor moves from page to page, or returns to use the Platform;
  • Collect information such as browser type, time spent on the Platform, pages visited, and traffic data;
  • Track responses to our marketing and advertising campaigns; and
  • For security purposes.

We also use these technologies to understand the activities and interests of our visitors, including to:

  • Measure traffic and usage of our Platform;
  • Monitor the effectiveness of our Platform;
  • Better understand the interests of visitors;
  • Recognize new or past visitors to our Sites;
  • Present more personalized content and advertisements;
  • Optimize a visitor’s shopping experience;
  • Identify visitors across devices, and third party websites; and
  • Identify improvements or enhancements to our Platform that might be of interest to our visitors

HOW TO BLOCK COOKIES

You can control some of our use of cookies. How you do so depends on the type of cookie. You may be able to configure certain browsers to delete or disable browser cookies. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the “options” or “preferences” menu of a browser. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies and http://www.allaboutcookies.org/browsers/index.html for information on commonly used browsers.

To control flash cookies, you can visit:  http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Platform. Choices you make about cookies are also browser and device specific. Further, while disabling a cookie may prevent the collection of information in the future, it does not prevent the use of information collected before the cookie was disabled. If you block or delete cookies, not all of the tracking described in this notice will stop.

Analytics

Information collected by Google Analytics is transmitted to, and stored by, Google in accordance with its privacy practices.  To see an overview of privacy at Google and how this applies to Google Analytics, please click here: https://support.google.com/analytics/answer/6004245.

To opt out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout.

Interest-Based Advertising

We may – or may have third parties, on our behalf – display to a visitor interest-based advertising and other custom content regarding our capabilities, products or services that may be of interest to visitors. These advertisements may be served to a visitor on or through our Platform, or on third-party websites. They may be based on interactions that a visitor has had with us or our Platform, on other activities and behaviors that the visitor demonstrates online, assumed interests attributed to that visitor, browsing history, and other information gathered about that visitor over time across multiple sites.

To collect this information, our service providers may place or recognize a unique cookie on the user’s browser and use other techniques, such as pixel tags. If you are using one of our mobile applications, our ad network partners may use and store your mobile device ID or Advertising ID to show ads that they consider relevant to you.

Do Not Track

Some browsers give individuals the ability to choose not to be tracked while browsing on the Internet. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law. However, please note the capabilities below.

How to Opt-out of Interest-Based Advertising

You may opt-out of receiving interest-based advertising as explained below. The opt-out may be provided through specific tracking opt-out cookies. Please note that if you get a new computer, install a new browser, or erase or alter your browser’s cookie file (including upgrading certain browsers), this may also clear any opt-out cookie.

To opt out of receiving interest-based advertising from advertising networks that may be delivered on a website, visit the following websites, and follow the instructions:

http://optout.aboutads.info/#/ and http://www.aboutads.info/choices

In addition, some third-party businesses may provide a mechanism to opt-out of their technology.  For more information about the opt-out process, you may visit the Network Advertising Initiative, you may want to visit:

http://optout.networkadvertising.org/#/ and  http://www.networkadvertising.org/managing/opt_out.asp.

Mobile device visitors may also download the AppChoices app at:

www.aboutads.info/appchoices to opt out from interested based advertising served in mobile apps.

The features above will allow a visitor to opt out of many –but not all – of the interest-based advertising activities in which we or third parties engage.

Data Retention

You can request that we stop using your information to provide you services by contacting us at the address provided in the “How to Contact Us” section.

Information Security

We take reasonable measures to protect any personal information we may hold in order to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. In some areas of our Platforms, we may use Secure Socket Layer (“SSL”) or Transport Layer Security (“TLS”) encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the information under our control.

We cannot guarantee, however, that all information will remain secure. The Internet by its nature is a public forum. We encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your login ID and password from third party access, and for selecting passwords that are secure.

Consent to Transfer of Information

If you are located outside the United States, please be aware that information we collect about you will be transferred for processing to the United States or other countries or jurisdictions that may not have the same data protection laws as your jurisdiction.

By registering for, and using the Platform, you consent to the transfer and storage of your personal information to the U.S. or to any other country in which we or our service providers maintain facilities.

Marketing Choices

Company material is provided at no cost to all visitors.  In order to finance some of the operations of the Platform, we have opted to make it available to advertisements by third parties. We may use aggregated and non-identifying information to deliver tailored advertisements targeted to a specific audience. Based upon the aggregated information we have collected about visitors, we display the advertisement to the intended audience based on these general criteria. Some advertisement methodology may be directed to a specific individual, and may be based on the specific apparent interest of the visitor of a specific device.

Electronic Communications

If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe link” provided in such communications. Please also note that if you do opt out of receiving emails from us, we may still send you important administrative messages (such as updates about your account or service changes), and you cannot opt out from receiving these messages. Please note that even though you may opt-out of receiving marketing-related Communications from us, we may still send you important administrative messages.

We may need to retain certain information for record keeping purposes and/or to complete any transaction that you began before requesting a change or deletion. In addition, it is likely that residual information might remain within our databases, back-ups or other records and might not be removed.

Shine the Light

Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any users of the Platform who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of customer information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year.  If applicable, the notice will identify the categories of information that we shared, and the names and addresses of the third parties and affiliates with which we shared your information.

If you are a California resident and would like to request a copy of this notice, please submit a written request by email to the address provided in the “how to contact us” section. In your request, please specify that you want a “California Privacy Rights Notice.”  Please allow at least thirty (30) days for a response.

Right of Erasure

In addition, if you are a California resident under the age of 18 and are a registered user, you may request that we remove content or information that you posted on our Platform or stored on our servers by submitting a request by email to the address provided in the “how to contact us” section. In your request, you must clearly identify the content or information you wish to have removed and provide sufficient information to allow us to locate the content or information to be removed.  However, please note that we are not required to erase or otherwise eliminate content or information if: (a) other state or federal laws require us or a third party to maintain the content or information; (b) the content or information was posted, stored, or republished by another user; (c) the content or information is anonymized so that the minor cannot be individually identified; (d) the minor does not follow the instructions posted in this Privacy Notice on how to request removal of such content or information; and (e) the minor has received compensation or other consideration for providing the content.  Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

How to Contact Us

If you have any questions about this Privacy Notice, please contact us:

By email at: legal@hakkasangroup.com

By postal mail at:
Hakkasan Holdings, LLC
Legal Department
​​6385 S. Rainbow Blvd., Suite 800
Las Vegas, NV 89118