Privacy Policy


We have made revisions to this Privacy Policy, effective May 25th, 2018. You can see the new version at the bottom of this page. By continuing to use our services after May 25th, you agree to the new Privacy Policy.


Effective Date: April 26, 2018

Handy Technologies, Inc., and its affiliates and subsidiaries ("Handy" or "we", "us", or the "Company") take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the Handy Platform. Personal Information is information that relates to you as an individually identifiable person, such as your name, e-mail address, and mobile number.

This Privacy Policy explains:

  • What information we collect
  • How we use that information
  • How we may share that information
  • How we protect your information
  • Your choices regarding your Personal Information
  • How to contact us with questions about this Privacy Policy

This Privacy Policy applies only to information that we collect on the websites Handy.com, site.mopp.com, and site.iamexec.com (collectively, the "Site") and through the Handy mobile applications, including the mobile application for service requesters and the mobile application for service professionals (the "App") (collectively the "Handy Platform").

I. INFORMATION WE COLLECT

a) Personal Information You Give Us

We collect information that you voluntarily share with us through the Handy Platform.

If you are using the Handy Platform to request professional services, or contact Handy or its third-party service providers, you may give us:

  • Contact information, such as your name, physical address, telephone number, and email address
  • Information about your home, such as the number of bedrooms, the types of appliances and zip code or postal code where your home is located
  • Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts
  • Ratings and reviews of the service professionals you engage through the Handy Platform

If you participate on the Handy Platform as a service professional, or contact Handy or its third-party service providers, you may give us:

  • Contact information, such as your name, email address, mailing address, and phone number
  • Log-in information, including your Handy Platform username and password
  • Application information, if requesting consideration to participate as a service professional through the Handy Platform, such as your experience, skills, eligibility to work, and availability
  • Social Security number, if you are a service professional who wishes to participate on the Handy Platform in the United States and you are selected for a background check

If you apply on the Handy Platform for employment with Handy, you may give us:

  • Contact information, including your name, email address, telephone number, and mailing address
  • Resume and LinkedIn profile

More about payment card information:

Although users can submit credit card or other payment card information to pay for a service through the Handy Platform, Handy does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, Stripe, through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. Stripe then communicates to Handy whether your payment has cleared, but does not provide payment card information to Handy. Stripe's privacy policy is available here.

Surveys

You may, at your choice, complete surveys on the Handy Platform about, for example, your level of satisfaction with the Handy Platform, your engagement with the Handy Platform, and your awareness of Handy Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your Handy account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.

b) Information We Collect Through Technology

We collect information through technology to enhance our ability to serve you. When you access and use the Handy Platform, or contact Handy or its third-party service providers, Handy and, in some cases, our third-party service providers collect information about you or how you interact with the Handy Platform. We describe below a few of the methods we use to collect information through technology.

When you visit the Handy Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the Handy Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.

We may also collect a unique identifier for your computer, mobile device, or other device used to access the Handy Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the Handy Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name.

Do We Use Cookies?

Yes. For more information about cookies, please visit our Cookies Policy.

Web Beacons

We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the Handy Platform by informing us what content is effective, monitoring how users navigate the Handy Platform, counting users of the Handy Platform, and counting how many e-mails sent by us were actually opened.

Your 'Do Not Track' Browser Setting

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.

We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the Handy Platform.

c) Information Collected by Mobile Applications

When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to:

  • The type of Internet browsers you use with the App.
  • Your preferred country site.
  • Your mobile operating system.
  • Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device

We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively "App Usage Information").

We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.

Location Tracking

If you are a service professional using Handy's mobile application for service professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Service Professional Agreement available on the service professional portal.

We only collect location information about service professionals who have been accepted to participate on the Handy Platform and not about service requesters or about service professionals applying to participate in the Handy Platform.

d) Information You Provide About A Third Party

If you choose to use our referral service to tell a friend about the Handy Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Handy Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.

If you are using the Handy Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the Handy Platform.

e) Information Third Parties Provide About You

Conversion Tracking: We may supplement the information we collect about you through the Handy Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about Handy you clicked. This is often called "conversion tracking."

Background Checks: In addition, when third parties such as Hirease, Onfido or Checkr.com conduct background checks on service professionals, those third parties share the results of the background check with Handy.

Recording Phone Calls: Selected third-parties, including those who may assist in providing customer service support, may monitor and/or record the contents of phone calls made through or in relation to the Handy Platform, after notice to you and with your consent.

Social Networking Sites: If you login to the Handy Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the Handy Platform.

Ratings and Reviews: If you are using the Handy Platform as a service professional, we may receive information about you in the form of ratings and reviews from requesters who engaged your professional services through the Handy Platform.

Message Interception: If you call or text (SMS) message a service professional or service requester using the telephone number provided by Handy, Handy uses Twilio to mask your telephone number. During this process, Handy and Twilio receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.

If you send a message to a service professional or service requester in the App, Handy uses Layer to process the communications. During this process, Handy and Layer receive in real time and store message data, including the date, time, and content of the messages.

If you are using the Handy Platform as a service professional, we may receive information about you in the form of ratings and reviews from Requesters who engaged your professional services through the Handy Platform.

We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.

f) Information You Provide to a Third Party

The Handy Platform includes links from the Handy Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites.

For example, service professionals may be directed to a Third Party Site, such as Checkr.com, Onfido.com, SterlingTalentSolutions.com, or Hirease.com, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.

Some Third-Party Sites link to Handy and share information with Handy. For example, in some cases, you can book services through the Handy Platform with one of our booking partners (“Booking Partner”), such as Amazon, Facebook, Walmart and Wayfair. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the Booking Partner. The Booking Partner might then share the necessary booking information with us. Amazon's privacy policy is available here , Facebook’s privacy policy is available here , Walmart’s privacy policy is available here , and Wayfair’s privacy policy is available here.

Handy does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site's privacy policy.

We recommend that you read the Third-Party Site's privacy policy if you choose to enter any Third-Party Site or click on a plug-in.

II. HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the Handy Platform. Some examples include:

  • Scheduling, rescheduling, and cancelling services
  • Rating and reviewing service professionals
  • Providing public profiles of service professionals
  • Addressing service complaints
  • Communicating with you by email, telephone, or text message, in accordance with your wishes
  • Managing payments for services
  • Considering whether to engage service professionals on the Handy Platform
  • Evaluating job applications to work at Handy
  • Improving customer service
  • Sending you marketing and promotional emails, on behalf of Handy or selected third parties, unless you have told us you do not want to receive such emails
  • Troubleshooting technical problems on the Handy Platform
  • Responding to questions and feedback
  • Conducting research and analysis
  • Running online or mobile sweepstakes, contents, or other promotions
  • Marketing and advertising Handy products and services and those of selected third parties
  • Continuously evaluating and improving the online and mobile user experience
  • Preventing, discovering and investigating violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and investigating fraud, chargebacks or other matters
  • Contacting you with regard to your use of the Handy Platform and, in our discretion, changes to the Handy Platform and/or the Handy Platform policies
  • Compliance with the law or to protect the rights, property, or safety of Handy, our users, or others, including to maintain network and information security, for fraud prevention, and to report suspected criminal acts

By using the Handy platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by Handy, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages, sent by or on behalf of Handy, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the Handy Platform or Services, updates concerning new and existing features on the Handy Platform, communications concerning promotions run by us, and news concerning Handy and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the Handy Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from Handy at any time. You may opt-out of receiving all text (SMS) messages from Handy (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however you acknowledge that opting out of receiving all texts may impact your use of the Handy Platform or the Services. You also acknowledge that Handy or its third party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.

You agree to Handy’s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by Handy. During this process, Handy and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to Handy’s use and disclosure of this call data for its legitimate business purposes.

The information described in this section may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.

Data Retention

We delete the back-ups of the databases containing your Personal Information after 13 months.

III. HOW WE SHARE THE INFORMATION WE COLLECT

We do not sell, rent, or trade your Personal Information to third parties other than as disclosed in this Privacy Policy at the time you provide your information. The following are some of the ways we share your information:

a) Service Professional Profiles and Ratings and Reviews by Requesters

The Handy Platform may display profiles of the service professionals who participate on the Handy Platform. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by their customers. The service professional’s profile may be visible to all users of the Handy Platform and on Booking Partners’ websites.

If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile on the Handy Platform and on Booking Partners’ websites. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

b) Third Parties Providing Services on Our Behalf

Third party companies and individuals provide or facilitate certain aspects of the services offered through the Handy Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.

The following are some examples of how we share your information with third-party service providers.

  • Data Analytics. We retain third-party service providers to help us perform data analytics regarding your interactions with the Handy Platform. For example, Google Analytics (privacy policy here) and Bounce Exchange (privacy policy here) may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site. For example, Branch Metrics and Mixpanel collect and provide reports to us showing how you interact with the Handy Platform using information, such as your IP address, browser ID and Device Identifier. Branch Metric's privacy policy is available here and Mixpanel's privacy policy is available here.
  • In some cases, these third-party service providers, such as Epsilon, may in turn share your Personal Information, such as your name and email address, with other third parties for their marketing-related purposes.
  • Platform Features. Service providers help us to provide functions available through the Handy Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. Urban Airship's privacy policy is available here. We share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. Twilio's privacy policy is available here. We share your telephone number, call data, device id and other Handy account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App. Layer's privacy policy is available here.
  • Payment Processing. We use Stripe, a third-party service provider, to process any billing information, including credit card information you submit. Stripe’s privacy policy is here.
  • User Reviews Aggregation. We use third-party service providers, such as Bazaarvoice, to aggregate user reviews and publish them on third party websites. Bazaaervoice’s privacy policy is here.
  • Email Delivery. We use third-party service providers, such as Customer.io and Sendgrid, to deliver email to our users. Customer.io’s privacy policy is here and Sendgrid’s privacy policy is here.
  • Background Check Service Providers. When service professionals applying to participate on the Handy Platform in the United States provide their Social Security numbers for a background check, the Social Security number is transmitted using TLS encryption to the background check service provider. Handy also securely provides U.S. service professional's Social Security numbers to the check processor.
  • Digital Vault Services. If you participate in Handy Vault, Handy uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the Handy platform. As part of this service, Handy will provide KeyCafe your name and your physical keys. If you provide services to a customer who participates in Handy Vault, Handy uses KeyCafe, a third-party service provider, to provide digital access to the customer's keys. As part of this service, Handy will provide KeyCafe your mobile phone number.
  • Customer Support. We use third-party service providers to assist with providing customer support for questions you may have about your account and use of the Handy Platform. We may disclose your Personal Information to such service providers to assist with responding to your questions.
  • Legal Advice. We may disclose your Personal Information to an attorney in the process of obtaining legal advice.

c) Third Parties Providing Information on Available Services or Marketing Offers

By using the Handy Platform, you may be contacted, either by Handy or directly by selected third parties, with opportunities to receive information on available services or marketing offers. If you agree to share your Personal Information to receive this information or marketing offers, your Personal Information may be disclosed to such third parties. All the information you disclose to the third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to sharing your Personal Information with them. If you later decide that you no longer want to receive communication from such a third party, you will need to contact that third party directly.

d) Booking Partners

We share your Personal Information with Booking Partners. For example, Amazon, Facebook, Wayfair and Walmart customers can book services through the Handy Platform from the Amazon, Facebook, Wayfair and Walmart sites and apps. Upon request, we provide our Booking Partner with information about the services you booked or provided, as applicable, through the Handy Platform.

e) Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Handy Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.

f) Social Network Site Authentication

If you choose to log-in to the Handy Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.

g) Administrative and Legal Reasons

Required Disclosures:

We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections:

We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Handy, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.

h) Corporate Transactions

We reserve the right to disclose and transfer your information, including your Personal Information:

  • To a subsequent owner, co-owner, or operator of the Handy Platform or successor database.
  • In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect any information from anyone under 13 years of age. The Handy Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Handy Platform.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE/YOUR CALIFORNIA PRIVACY RIGHTS

California residents who use the Handy Platform may request that we provide certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes. You can make such a request by e-mail to privacy@handy.com or by mail to: PO Box #1122, New York, NY 10159

IV. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT

The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.

For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.

It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.

V. YOUR CHOICES REGARDING THE INFORMATION WE COLLECT

You may contact privacy@handy.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the Handy Platform.

In addition, you may cancel or modify the email communications you have chosen to receive from the Handy Platform by following the instructions contained in emails from us.

VI. HAVE QUESTIONS?

If you have any questions about this Privacy Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email:
privacy@handy.com

Mailing Address:
Handy Technologies, Inc.
PO Box #1122
New York, NY 10159

PRIVACY POLICY UPDATES

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.


Effective Date: May 25, 2018

Handy Technologies, Inc., and its affiliates and subsidiaries ("Handy" or "we", "us", or the "Company") take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the Handy Platform. Personal Information is information that relates to you as an individually identifiable person, such as your name, e-mail address, and mobile number.

This Privacy Policy explains:

  • What Personal information we collect, including geolocation information, recorded phone calls and messages through the Handy Platform
  • How we use your Personal Information
  • How we share your Personal Information
  • How we protect your Personal Information
  • Your choices regarding your Personal Information
  • How to contact us with questions about this Privacy Policy
  • Information specific to non-US users
  • Changes to this Privacy Policy

This Privacy Policy applies only to information that we collect on the websites Handy.com, site.mopp.com, and site.iamexec.com (collectively, the "Site") and through the Handy mobile applications, including the mobile application for service requesters and the mobile application for service professionals (the "App") (collectively the "Handy Platform").

I. PERSONAL INFORMATION WE COLLECT

a) Information You Give Us

We collect information that you voluntarily share with us through the Handy Platform.

If you are using the Handy Platform to request professional services, or contact Handy or its third-party service providers, you may give us:

  • Contact information, such as your name, physical address, telephone number, and email address
  • Information about your home, such as the number of bedrooms, the types of appliances and zip code or postal code where your home is located
  • Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts
  • Ratings and reviews of the service professionals you engage through the Handy Platform

If you participate on the Handy Platform as a service professional, or contact Handy or its third-party service providers, you may give us:

  • Contact information, such as your name, email address, mailing address, and phone number
  • Log-in information, including your Handy Platform username and password
  • Application information, if requesting consideration to participate as a service professional through the Handy Platform, such as your experience, skills, eligibility to work, and availability
  • Social Security number, if you are a service professional who wishes to participate on the Handy Platform in the United States and you are selected for a background check

If you apply on the Handy Platform for employment with Handy, you may give us:

  • Contact information, including your name, email address, telephone number, and mailing address
  • Resume and LinkedIn profile

More about payment card information:

Although users can submit credit card or other payment card information to pay for a service through the Handy Platform, Handy does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, Stripe, through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. Stripe then communicates to Handy whether your payment has cleared, but does not provide payment card information to Handy.

Surveys

You may, at your choice, complete surveys on the Handy Platform about, for example, your level of satisfaction with the Handy Platform, your engagement with the Handy Platform, and your awareness of Handy Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your Handy account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.

b) Information We Collect Through Technology

We collect information through technology to enhance our ability to serve you. When you access and use the Handy Platform, or contact Handy or its third-party service providers, Handy and, in some cases, our third-party service providers collect information about you or how you interact with the Handy Platform. We describe below a few of the methods we use to collect information through technology.

When you visit the Handy Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the Handy Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.

We may also collect a unique identifier for your computer, mobile device, or other device used to access the Handy Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the Handy Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name.

Do We Use Cookies?

Yes. For more information about cookies, please visit our Cookies Policy.

Web Beacons

We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the Handy Platform by informing us what content is effective, monitoring how users navigate the Handy Platform, counting users of the Handy Platform, and counting how many e-mails sent by us were actually opened.

Your 'Do Not Track' Browser Setting

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.

We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the Handy Platform.

c) Information Collected by Mobile Applications

When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to:

  • The type of Internet browsers you use with the App.
  • Your preferred country site.
  • Your mobile operating system.
  • Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device.

We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively "App Usage Information").

We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.

Location Tracking

If you are a service professional using Handy's mobile application for service professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Service Professional Agreement available on the service professional portal.

We only collect location information about service professionals who have been accepted to participate on the Handy Platform and not about service requesters or about service professionals applying to participate in the Handy Platform.

d) Information You Provide About A Third Party

If you choose to use our referral service to tell a friend about the Handy Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Handy Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.

If you are using the Handy Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the Handy Platform.

e) Information Third Parties Provide About You

Conversion Tracking: We may supplement the information we collect about you through the Handy Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about Handy you clicked. This is often called "conversion tracking."

Background Checks: In addition, when third parties such as Hirease, Onfido or Checkr.com conduct background checks on service professionals, those third parties share the results of the background check with Handy.

Recording Phone Calls: Selected third-parties, including those who may assist in providing customer service support, may monitor and/or record the contents of phone calls made through or in relation to the Handy Platform, after notice to you and with your consent.

Social Networking Sites: If you login to the Handy Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the Handy Platform.

Ratings and Reviews: If you are using the Handy Platform as a service professional, we may receive information about you in the form of ratings and reviews from requesters who engaged your professional services through the Handy Platform.

Message Interception: If you call or text (SMS) message a service professional or service requester using the telephone number provided by Handy, Handy uses Twilio to mask your telephone number. During this process, Handy and Twilio receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.

If you send a message to a service professional or service requester in the App, Handy uses Layer to process the communications. During this process, Handy and Layer receive in real time and store message data, including the date, time, and content of the messages.

We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.

f) Information You Provide to a Third Party

The Handy Platform includes links from the Handy Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites.

For example, service professionals may be directed to a Third Party Site, such as Checkr.com, Onfido.com, or Hirease.com, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.

Some Third-Party Sites link to Handy and share information with Handy. For example, in some cases, you can book services through the Handy Platform with one of our booking partners (“Booking Partner”), such as Facebook, Walmart and Wayfair. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the Booking Partner. The Booking Partner might then share the necessary booking information with us.

Handy does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site's privacy policy.

We recommend that you read the Third-Party Site's privacy policy if you choose to enter any Third-Party Site or click on a plug-in.

II. HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the Handy Platform. Some examples include:

  • Scheduling, rescheduling, and cancelling services
  • Rating and reviewing service professionals
  • Providing public profiles of service professionals
  • Addressing service complaints
  • Communicating with you by email, telephone, or text message, in accordance with your wishes
  • Managing payments for services
  • Considering whether to engage service professionals on the Handy Platform
  • Evaluating job applications to work at Handy
  • Improving customer service
  • Sending you marketing and promotional emails, on behalf of Handy or selected third parties, unless you have told us you do not want to receive such emails
  • Troubleshooting technical problems on the Handy Platform
  • Responding to questions and feedback
  • Conducting research and analysis
  • Running online or mobile sweepstakes, contents, or other promotions
  • Marketing and advertising Handy products and services and those of selected third parties
  • Continuously evaluating and improving the online and mobile user experience
  • Preventing, discovering and investigating violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and investigating fraud, chargebacks or other matters
  • Contacting you with regard to your use of the Handy Platform and, in our discretion, changes to the Handy Platform and/or the Handy Platform policies
  • Compliance with the law or to protect the rights, property, or safety of Handy, our users, or others, including to maintain network and information security, for fraud prevention, and to report suspected criminal acts

By using the Handy platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by Handy, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages, sent by or on behalf of Handy, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the Handy Platform or Services, updates concerning new and existing features on the Handy Platform, communications concerning promotions run by us, and news concerning Handy and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the Handy Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from Handy at any time. You may opt-out of receiving all text (SMS) messages from Handy (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however you acknowledge that opting out of receiving all texts may impact your use of the Handy Platform or the Services. You also acknowledge that Handy or its third party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.

You agree to Handy’s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by Handy. During this process, Handy and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to Handy’s use and disclosure of this call data for its legitimate business purposes.

The information described in this section may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.

Data Retention

We delete the back-ups of the databases containing your Personal Information after 13 months.

III. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT

We do not sell, rent, or trade your Personal Information to third parties other than as disclosed in this Privacy Policy at the time you provide your information. The following are some of the ways we share your information:

a) Service Professional Profiles and Ratings and Reviews by Requesters

The Handy Platform may display profiles of the service professionals who participate on the Handy Platform. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by their customers. The service professional’s profile may be visible to all users of the Handy Platform and on Booking Partners’ websites.

If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile on the Handy Platform and on Booking Partners’ websites. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

b) Third Parties Providing Services on Our Behalf

Third party companies and individuals provide or facilitate certain aspects of the services offered through the Handy Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.

The following are some examples of how we share your information with third-party service providers.

  • Data Analytics. We retain third-party service providers to help us perform data analytics regarding your interactions with the Handy Platform. For example, Google Analytics and Bounce Exchange may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site. For example, Branch Metrics and Mixpanel collect and provide reports to us showing how you interact with the Handy Platform using information, such as your IP address, browser ID and Device Identifier.
  • Platform Features. Service providers help us to provide functions available through the Handy Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. We share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. We share your telephone number, call data, device id and other Handy account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App.
  • Payment Processing. We use Stripe, a third-party service provider, to process any billing information, including credit card information you submit.
  • User Reviews Aggregation. We use third-party service providers, such as Bazaarvoice, to aggregate user reviews and publish them on third party websites.
  • Email Delivery. We use third-party service providers, such as Customer.io and Sendgrid, to deliver email to our users.
  • Background Check Service Providers. When service professionals applying to participate on the Handy Platform in the United States provide their Social Security numbers for a background check, the Social Security number is transmitted using TLS encryption to the background check service provider. Handy also securely provides U.S. service professional's Social Security numbers to the check processor.
  • Digital Vault Services. If you participate in Handy Vault, Handy uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the Handy platform. As part of this service, Handy will provide KeyCafe your name and your physical keys. If you provide services to a customer who participates in Handy Vault, Handy uses KeyCafe, a third-party service provider, to provide digital access to the customer's keys. As part of this service, Handy will provide KeyCafe your mobile phone number.
  • Customer Support. We use third-party service providers to assist with providing customer support for questions you may have about your account and use of the Handy Platform. We may disclose your Personal Information to such service providers to assist with responding to your questions.
  • Legal Advice. We may disclose your Personal Information to an attorney in the process of obtaining legal advice.

c) Third Parties Providing Information on Available Services or Marketing Offers

Handy shares your Personal Information with its business partners, which may contact you directly or through Handy with information on available services or marketing offers. If you decide that you no

longer want to receive communication from such a third party, you will need to contact that third party directly.

d) Booking Partners

We share your Personal Information with Booking Partners. For example, Facebook, Wayfair and Walmart customers, including those customers

in the United Kingdom, can book services through the Handy Platform from the Facebook, Wayfair and Walmart sites and apps. Upon request, we provide our Booking Partner with information about the services you booked or provided, as applicable, through the Handy Platform.

e) Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Handy Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.

f) Social Network Site Authentication

If you choose to log-in to the Handy Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.

g) Administrative and Legal Reasons

Required Disclosures:

We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections:

We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Handy, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.

h) Corporate Transactions

We reserve the right to disclose and transfer your information, including your Personal Information:

  • To a subsequent owner, co-owner, or operator of the Handy Platform or successor database.
  • In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect any information from anyone under 13 years of age. The Handy Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Handy Platform.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE/YOUR CALIFORNIA PRIVACY RIGHTS

California residents who use the Handy Platform may request that we provide certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes. You can make such a request by e-mail to privacy@handy.com or by mail to: PO Box #1122, New York, NY 10159

IV. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT

The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.

For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.

It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.

V. YOUR CHOICES REGARDING THE PERSONAL INFORMATION WE COLLECT

You may contact privacy@handy.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the Handy Platform.

In addition, you may cancel or modify the email communications you have chosen to receive from the Handy Platform by following the instructions contained in emails from us or by emailing privacy@handy.com

VI. HAVE QUESTIONS?

If you have any questions about this Privacy Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email:
privacy@handy.com

Mailing Address:
Handy Technologies, Inc.
PO Box #1122
New York, NY 10159

VII. INFORMATION SPECIFIC TO NON-U.S. USERS

a) All locations outside of the United States

The Personal Information collected through the Site is downloaded to a server maintained by Handy in the United States. Handy will comply with requests to exercise individual data rights in accordance with applicable law. You can contact privacy@handy.com to request to exercise your data rights.

b) For Individuals in the EU, EEA and/or Switzerland

To provide an adequate level of protection for Personal Information received from the Member States of the European Economic Area ("EEA") and from Switzerland, Handy Technologies, Inc., ("Handy US") follows the principles established by the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce (“Privacy Shield Principles”) when processing the Personal Information of natural persons located in the EEA and Switzerland (collectively, "EEA Individuals"). EEA Individuals include users of the Handy Platform, such as service requesters and service professionals. EEA Individuals also include employees of Handy US’ affiliated companies located in the Member States. Please note that service professionals who provide services through the Handy Platform are independent contractors and are not employees of Handy US or employees of any of Handy US’ affiliated companies, including those located in the Member States.

If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern.

c) Notice Handy US's Use And Disclosure Of Personal Information

Before processing the Personal Information of any EEA Individual, Handy US, or its local affiliate, provides the EEA Individual with a notice concerning the processing of his or her Personal Information. The notice, including this Privacy Policy, are available for review on the Handy Platform and/or provided directly to the EEA Individual.

Handy US receives the Personal Information of Handy Platform users and processes it for the purposes described in this Privacy Policy. Handy US may disclose this Personal Information to third parties as described in the Privacy Policy.

Handy US receives the Personal Information of applicants for employee positions located in the Member States and Switzerland ("Applicants")to administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which Handy US collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer Handy US’ compliance process; and for emergency contact purposes.

The employee and Applicant Personal Information that Handy US receives from the EEA and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by Handy US or its affiliates to administer the employment relationship, such as business contact information, and compensation and benefits information.

Handy US may disclose employee and Applicant Personal Information, subject to written agreement, to authorized service providers who provide services related to the administration of the recruitment process and/or the employment relationship. Handy US also may disclose employee and Applicant Personal.

Information to corporate affiliates in connection with the recruitment process and for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning.

Handy US may be required to disclose, and may disclose, EEA and Swiss Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

d) Cross-Border Data Transfers:

The Personal Information collected through the Site will be transferred to the United States. The recipients of Personal Information collected through the Site (listed in Section III above) are located in the United States and the Philippines or in the country where the data was collected and the data that is transferred will be subject to this Privacy Policy.

e) Legal Bases For Processing:

Consent and as Required by Law: Handy processes your Personal Information with your consent and as required by law.

Contract: Users can enter into two different types of contracts through the Handy Platform: (1) a contract between service requesters and service professionals regarding professional services, and (2) a contract between the user and Handy whereby Handy facilitates the arrangement of the professional services contract in exchange for a share of the fee for the contracted professional services. To take steps necessary to respond to users’ requests to enter into both types of contracts, Handy processes Personal Information from service requesters, including contact information, services requested, and worksite location information, and from service professionals, including contact information, skills and experience, background check information, preferred times, and preferred locations. To facilitate the performance of the service professional agreement and to perform the contract with users, Handy must process Personal Information, including the service requester’s billing information, the service professional’s receivables information and geographic location information, and both parties’ text messages and phone calls through the Handy Platform.

Handy cannot facilitate service professional contracts through the Handy Platform or enter into contracts with users unless users provide this Personal Information.

Legitimate Interests: Handy also processes Personal Information as necessary for its legitimate interests as follows:

  • Marketing and advertising: Unless you opt out as described below, we use your Personal Information as necessary to provide you information about the services that we think might interest you, in accordance with applicable law.
  • Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.

Right to Object to Processing for Direct Marketing or Legitimate Interests:

EEA Individuals have the right to object to the processing of their Personal Information for purposes of Handy’s direct marketing or legitimate interests by contacting Handy at privacy@handy.com

Automated decision-making:

Handy sometimes uses EEA Individuals’ Personal Information submitted through the Site for automated decision-making. For example, Handy may display advertisements and send emails to you containing content automatically chosen based on the services you have ordered through the Handy Platform in the past. However, Handy will not use EEA Individuals’ Personal Information submitted through the Site for automated decision-making, including profiling, which produces legal effects or similarly significantly affects the EEA Individual.

Individual Rights:

EEA Individuals have the right to access their Personal Information collected by the Site and to request that Handy update, correct, or delete their Personal Information as provided by applicable law. EEA Individuals also have the right to object to, or restrict, Handy’s processing of their Personal Information.

In addition, EEA Individuals have the right to data portability concerning their Personal Information. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from Handy, or to ask Handy to send to a third party, a digital copy of the Personal Information that they provided to the Site. EEA Individuals’ right to access their Personal Information includes their right to receive a copy of all, or a portion, of their Personal Information in Handy’s possession as long as Handy’s providing the Personal Information would not adversely affect the rights and freedoms of others.

f) Choice: How To Opt Out Of Collection Of Your Personal Information By Handy US And Transfer To Third Parties

Handy US may disclose EEA Individuals’ Personal Information transferred to the United States pursuant to this Privacy Policy to non-agent third parties as described in Section III above. In some cases, as described in Section III of this Privacy Policy, our third-party service providers may in turn share the Personal Information of Handy Platform users with other third parties. You may opt out of such disclosures and onward transfers by writing to privacy@handy.com

Handy US will offer EEA Individuals whose Personal Information has been transferred to the United States pursuant to this Privacy Policy the opportunity to opt out from: (a) the disclosure of their Personal Information to any non-agent third parties not already listed in Section III above and (b) the use of their Personal Information for purpose(s) that are not compatible with the purpose(s) for which the Personal Information was originally collected or subsequently authorized by the Individual. Handy US will provide EEA Individuals with clear, conspicuous, and readily available mechanisms to exercise choice. should such circumstances arise. Any withdrawal will apply only prospectively, and Handy will continue to retain the Personal Information that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.

g) Access And Correction: How You Can Exercise Your Rights

Handy US acknowledges EEA Individuals’ right to access and correct their Personal Information. Upon reasonable request, Handy US will grant EEA Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. EEA Individuals wishing to exercise these rights may do so by contacting privacy@handy.com Employees should contact their local manager to exercise these rights.

h) EU Representative:

Handy’s representative in the European Union is We Are Mop! Limited, a company incorporated in the United Kingdom under registration number 08334346. You can reach We Are Mop! Limited at privacy@handy.com

VIII CHANGE TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.