Privacy Policy


Last updated: February 11, 2024

This privacy policy describes how and why we collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you visit our appbill.pro website or any website of ours that links to this privacy policy, or engage with us in other related ways, including any sales, marketing, or events.
Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us.

TABLE OF CONTENTS

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW YOUR PERSONAL DATA IS COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

11. CHANGES TO THIS PRIVACY POLICY

12. DO NOT TRACK SIGNALS

13. INFORMATION ABOUT OUR USE OF SOCIAL MEDIA

14. COOKIES POLICY

15. CHILDREN'S INFORMATION

16. LOG FILES

17. LINKS TO OTHER WEBSITES

18. UPDATING YOUR INFORMATION

19. HOW TO CONTACT US

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your personal data, including any data you may provide through this appbill.pro website or any other websites we own or operate that link to this privacy policy (collectively, our "Websites") and/or related services such as any sales, marketing, or events (collectively referred to as "Services") when you sign up to our newsletter, purchase a product or service from us, take part in a competition or survey, or otherwise provide us with your personal data.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER
Our Website and Services are owned and operated by HarborHold. We are the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy policy).

CONTACT DETAILS
If you have any questions about this privacy policy and our privacy practices, please contact us using the following details:
Full name of legal entity: HarborHold
Email address: contact@villasurban.realty.info
Telephone number: +60 60 5678 9012
You have the right to make a complaint at any time to your local data protection supervisory authority about our collection and use of your personal data. We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority so please contact us in the first instance.

YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during your relationship with us.

THIRD-PARTY LINKS
Our appbill.pro Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU


Personal data, or personal information, means any information about an individual from which that person can be identified directly or indirectly. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website or Services.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Website and Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.



    IF YOU FAIL TO PROVIDE PERSONAL DATA
    Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

    3. HOW YOUR PERSONAL DATA IS COLLECTED


    We use different methods to collect data from and about you including:
  • Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Communications data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Apply for our services;
  • Subscribe to our service or newsletter;
  • Request marketing be sent to you;
  • Enter a competition, promotion or survey;
  • Give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Website or Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties: (a) analytics providers such as Google based outside the UK; (b) advertising networks inside OR outside the UK; and (c) search information providers inside OR outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

    4. HOW WE USE YOUR PERSONAL DATA

    • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
    • We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

    MARKETING
    We may process your personal data to contact you, primarily by email, but also through postal mail, phone to provide information regarding our services that you have previously purchased, or to provide information about other goods and services we offer that are similar or we feel you might find interesting.
    We strive to provide you with choices regarding how we contact you, if at all.
    You can opt-out from receiving marketing communications from us by using the opt-out mechanisms provided in our communications or by contacting us directly through the contact details provided in this policy.
    We may use third party tools and platforms to deliver our communications to you, like MailChimp, Facebook and Google Analytics. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our marketing communications. For more information, please see our Cookies Policy.

    OPTING OUT
    You can ask us to stop sending you marketing communications at any time.
    If you wish to amend any of your marketing preferences, you can click on the 'unsubscribe' link at the bottom of our emails OR contact us using the details provided in this policy.
    CHANGE OF PURPOSE
    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    5. DISCLOSURES OF YOUR PERSONAL DATA


    We may share your personal data with the parties set out below for the purposes set out in the table above:
  • Internal Third Parties: Our employees based in the UK who require the data to provide technical support, deal with enquiries or orders, administer our services etc. We will provide our employees with refresher training on data protection where necessary to ensure your data remains secure.
  • External Third Parties Service Providers: Such as MailChimp, Facebook and Google Analytics based in the United States who provide marketing automation, targeted advertising and web traffic analysing services. A full list of these third parties is available on request. We only share information that allows them to provide services to us or to facilitate tailoring of content and advertising. These third parties have access to your personal data only to perform these tasks on our behalf and are contractually obliged not to disclose or use it for any other purpose.
  • Specific third parties: for example PayPal or Stripe for payment processing; Shopify for ecommerce; Quickbooks for accounting; lawyers; HMRC for tax purposes etc. We may also need to pass your information to our payment services provider to allow payments and refunds to be completed successfully. We use third parties based in and outside the UK. A full list of these third parties is available on request. We only share information necessary for them to provide services to us pursuant to adequate safeguards such as standard contractual clauses. These third parties have access to your personal data only to perform these tasks on our behalf and are contractually obliged not to disclose or use it for any other purpose.
    • Please get in touch with us if you want further information on the specific safeguards used by us when transferring your personal data out of the UK.



    6. INTERNATIONAL TRANSFERS


    WHENEVER WE TRANSFER YOUR PERSONAL DATA OUT OF THE UK, WE ENSURE A SIMILAR DEGREE OF PROTECTION IS AFFORDED TO IT BY IMPLEMENTING APPROPRIATE SAFEGUARDS.
    Please contact us if you want further information on the specific safeguards used by us when transferring your personal data out of the UK.

    7. DATA SECURITY


    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who need to know the data to be able to process it for us and who are subject to a duty of confidentiality.
    We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or regulator of a breach where we are legally required to do so.

    8. DATA RETENTION


    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.
    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.



    9. YOUR LEGAL RIGHTS


    You have rights under data protection laws in relation to your personal data. You have the right to:
  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

    NO FEE USUALLY REQUIRED
    • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    WHAT WE MAY NEED FROM YOU
    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    TIME LIMIT TO RESPOND
    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    10. GLOSSARY


    LAWFUL BASIS
    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    THIRD PARTIES
    External Third Parties means:
  • Service providers such as MailChimp based in the United States who provide marketing automation services.
  • Social media platforms such as Facebook based in the United States to target advertisements.
  • Web analytics services such as Google Analytics based in the United States for traffic analysis.

    YOUR LEGAL RIGHTS
    • You have the right to:
    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    11. CHANGES TO THIS PRIVACY POLICY


    We reserve the right to update this privacy policy at any time, and any changes we make will be posted on this page. Prior versions of this privacy policy will be archived and made available for review. We will provide notice of any material changes to this privacy policy by posting prominent notice on the appbill.pro Website or notifying you via email.

    12. DO NOT TRACK SIGNALS


    Some web browsers incorporate "Do Not Track" (DNT) signals or settings that signal to websites that you do not wish to be tracked. Because there is no uniform way that browsers communicate DNT signals and because no definitive legal standard governs what websites can and cannot do with regard to DNT requests, our Website does not currently process or respond to DNT requests or signals. We await the result of work by the privacy community and industry to develop uniform standards for responding to and handling DNT signals.


    13. INFORMATION ABOUT OUR USE OF SOCIAL MEDIA


    We use social media platforms such as Facebook and Twitter to provide you with updates on our business, events, activities, promotions, etc. We do not collect any information via the use of these platforms. However, the social networks behind these platforms do collect information over time when you interact with them. You should check the privacy policies of each site before using them and ensure you understand their data practices.

    14. COOKIES POLICY


    Our appbill.pro Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse our Website, you are agreeing to our use of cookies as described in our Cookies Policy.

    15. CHILDREN'S INFORMATION


    The minimum age to use our Website without parental consent is 18 years old. If you are under 18 years old, you cannot use our Website or Services without involvement and approval of a parent or legal guardian. We do not knowingly collect personal information from, and do not market to, children under 18 years old. If we learn that we have collected personal data from a child under 18, we will promptly delete that personal data. If you are a parent or guardian and believe we may have information about your child, please contact us to request access to or deletion of information about your child.

    16. LOG FILES


    Like many website owners, we implement website analytic tools like Google Analytics which uses log files to analyze website performance. These log files contain aggregate information on IP addresses, browser types, referring domains etc. Log files do not contain personal information and are used solely to analyze website performance to provide better user experiences. The privacy policy of the service provider applies.

    17. LINKS TO OTHER WEBSITES


    Our appbill.pro Website contains links to websites owned by other third parties. Please note that this privacy policy only applies to information collected through our Services, and does not apply to third party websites and services accessible through links on our Website. When linking to another website, we recommend you read that website's privacy policy as well as terms and conditions as we cannot control or assume responsibility for content not owned by us.

    18. UPDATING YOUR INFORMATION


    If you believe that the information we hold about you is incomplete, incorrect or out of date, you can ask us to update the information by contacting us through the contact details provided in this policy. We will action your request promptly upon receiving the updated information from you.

    19. HOW TO CONTACT US


    If you have any questions about this Privacy Policy or our privacy practices, please contact us:
    E-Mail: contact@villasurban.realty.info

    Phone Number: +60 60 5678 9012

    WebSite: appbill.pro