Privacy Policy
The version applicable as of 16 June 2022
1. Why should I read this Privacy Policy?
This Privacy Policy (‘Policy’) describes how Telogen, JSC (hereafter referred to ‘we’, ‘us’, ‘our’) collects, uses, discloses, and stores your personal information and what statutory rights do you have under applicable data protection laws. We may amend this policy unilaterally from time to time. Any such amendments will be effective immediately upon publication. Please visit our website regularly for the latest version of this policy.
2. Who is responsible for protecting my information?
We are: hello100 (owned and operated by JSC “telogen”)
Our company code is: 305846612
Our office address: 630 Third Ave. Suite 1502 NY 10017
Our registered address: Antakalnio st. 17, Vilnius, Lithuania
Our e-mail address: [email protected]
3. Why do you collect, and how do you use my information?
3.1 To provide you with services and supply goods
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When you are our client | Identification data: your name, surname, e-mail address, phone number and other data that you provide while registering or using our services, as well as your purchase history
Service data: your contact details (such as your e-mail address and billing address), bank account and transaction details, as well as other information that you provide to us while filling up the relevant questionnaires. |
Performance of a contract between you and us. | It is a contractual requirement. If you do not provide this information, we will not be able to provide our services | No longer than 5 (five) years following the end of the provision of services |
3.2 To operate our website, ensure its security and set default options
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When you are browsing our website | Device data: IP address, geographical location, browser type and version, operating system, device type, screen resolution and (in case you agree to share such) your location data as well as information on the motion activity, use of our website (i.e., referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use). | We have a legitimate interest to properly administrate our website and ensure its security. | No | Data collected by cookies is stored as described in section 13 of this policy. Other data – 1 year |
3.3 To maintain communications with you
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When you contact us by submitting your inquiry | Correspondence data: e-mail address, subject of your inquiry, date of your inquiry, the content of your inquiry, attachments to your inquiry, your name and (or) surname provided in your inquiry, reply to your inquiry, information provided by you, other communication content and metadata associated with the communication | Your consent
We also have a legitimate interest to ensure uniform and high-quality consultation practice and investigate disputes between you and our employees |
No | No longer than 2 years following the end of such communication |
3.4 To send you relevant messages and newsletters
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When you consent to receive relevant messages and newsletters, or we have already sold goods or provided services | Messaging data: your name, surname, e-mail address, the content of the message | Your consent
In case we have already sold goods or provided services for you via our website, and you do not object: we have a legitimate interest to maintain and improve customer relations. |
No | No longer than 2 (two) years following the provision your consent, or no longer than 2 (two) years following the end of the provision of the respective services, unless you respectively withdraw your consent earlier or object to such processing |
3.5 To manage our social media profiles
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| If you interact with our social media profiles (e.g., send a message, follow our profiles, share a post, react to a post) | Social media account data: name and surname indicated in your profile, e-mail address, gender, country, picture, message, time, and date the message was received, the content of the message, message attachments, response to the message, time of response to the message, information about our rating, comments on a post, post shares, information about post reactions | Your consent | No | 10 years from the moment you interact with our social media profiles |
3.6 To carry out the selection of potential employees
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When we receive your application for a job position, when you give us your consent for storing your CV, or we contact you based on the information you publicly disclose on professional social media platforms | Recruitment data: full name, e-mail, phone number, CV, work experience, and other information you provide us with | Your consent
Contract (taking steps to enter into an employment contract with us) We also have a legitimate interest to contact you when you publicly disclose your information on professional social media platforms |
It is a requirement necessary to enter into a contract only where we intend to enter into an employment contract with you. If you do not provide this information, we will not be able to enter into an employment contract with you. | 3 years after the end of the relevant recruitment process
5 years after you give us your consent or publicly disclose your information on professional social media platforms |
3.7 To fulfill statutory accounting requirements
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| When you use our services | Accounting data: full name, e-mail address, telephone number, address, invoices, reports, accounting documents, payments, paid amounts, and other information we are statutorily required to collect | We have a legal obligation | It is a statutory requirement. If you do not provide this information, you will not be able to buy goods or services from us | 10 years following a transaction |
3.8 To establish, exercise or defence legal claims
| When is this relevant for me? | What information do you collect about me? | What is your legal basis for collecting my information? | Am I obliged to provide this information? | How long do you store information about me? |
| In case we become a party to a legal process to which you are subject, or we are statutorily required to collect or provide information about you | All of the aforementioned information, accounting and legal case files, legal documents, other information you provide us with, additional information that we are statutorily required to collect and/or provide | We have a legal obligation to process this data | Provision of data may be a statutory requirement. | 10 years following the end of the contractual relationship with us or, whichever is longer, for the duration of the legal process and 3 years after a final authority decision came into full force |
4. Where do you collect my data from?
We collect most of the data from you. In addition, for certain purposes, we may receive data from other sources, as explained below.
| Data source | Purpose of collecting data |
| Social media service providers | To manage our social media profiles (see section 3.5. above) |
| HR service providers | To carry out the selection of potential employees (see section 3.6. above) |
| Law enforcement authorities, courts | To establish, exercise or defense legal claims (see section 3.9. above) |
| Parties that are subject or related to legal processes | To establish, exercise or defense legal claims (see section 3.9. above) |
5. Who do you share my data with?
We share your data with data recipients, both within and outside the European Economic Area (EEA), in cases where necessary for the above-described purposes and allowed in accordance with applicable laws.
| No | Recipients or categories of recipients | Location of the recipient | What is the legal basis to transfer my data outside the EEA? |
| 5.1. | PayPal Holdings, Inc. (payment service provider) | US | Standard Contractual Clauses |
| 5.2. | Stripe, Inc. (payment service provider) | US | Standard Contractual Clauses |
| 5.3. | Amazon Inc. (shipping and retail service provider) | US | Standard Contractual Clauses |
| 5.4. | jobRely, JSC (HR service provider) | Lithuania | N/A |
| 5.5. | Linkedin Inc. (social media service provider) | US | Standard Contractual Clauses |
| 5.6. | Facebook Inc., Facebook ltd. (social media service provider) | US/Ireland | Standard Contractual Clauses |
| 5.7. | 1stopVAT, JSC (tax management service provider) | Lithuania | N/A |
| 5.8. | Other our group companies | EU | N/A |
| 5.9. | Other service providers (such as providers of servers and maintenance, communication tools service providers, service providers used for data analysis or marketing, marketing service providers, compliance and legal service providers) | Worldwide | In cases where we transfer data outside the EEA, we rely on the European Commission’s Adequacy Decisions about certain countries or use Standard Contractual Clauses approved by the European Commission. |
| 5.10. | State institutions and regulatory authorities | Worldwide | In cases where we transfer data outside the EEA, we rely on the condition that the transfer is necessary for the establishment, exercise or defence of legal claims. |
6. What statutory rights do I have regarding my data?
Subject to conditions and limitations established by applicable laws, you have the rights:
- to know about the personal information collected, disclosed, or sold and to request access to that data;
- to correct inaccurate or incorrect data or to supplement it when it is incomplete;
- to delete the data, we have about you;
- to restrict the use of your data where you challenge the accuracy of the data, object to the processing of the data or need your data for legal purposes;
- to request your data in a structured, commonly used and machine-readable format
- to object to the processing of the data. It is relevant where the collection and use are based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, including profiling, as explained in Section 3 of this policy, or where you object to the collection of your personal data for direct marketing purposes.
- to withdraw any consent given to us regarding the processing of your data. You have the right to withdraw any consent given regarding the processing of your data where the processing is based on consent, as explained in Section 3 of this policy, and you seek to withdraw it at any time;
- to file a complaint with supervisory authorities;
- not to receive discriminatory treatment while exercising your rights.
More detailed information on your rights and the cases where they are applicable are provided in the sections below.
7. What is my right to know about the personal information collected, disclosed, or sold?
You have the right to request that we disclose certain data to you about our collection and use of your data. Once we receive and verify your request, we will disclose to you the categories of data we collected about you, the categories of sources for the data we collected about you, our business or commercial purposes for collecting that personal information, the categories of third parties with whom we share that data, the specific pieces of data we collected about you and other information that we are obliged to provide under the applicable laws. We have disclosed the data to third parties for business or commercial purposes as described in Section 5 of this policy.
8. What is my right to request deletion of the data?
You have the right to request the deletion of your data collected and maintained by us in the cases where (i) data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw consent on which the processing is based, and there is no other legal ground for the processing; (iii) when you object to the processing, and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes; (iv) the information have been unlawfully processed; (v) where the information has to be erased for compliance with a legal obligation; (vi) the information have been collected in relation to the offer of information society services directly to a child and subject to consent. Once we receive and verify your request, we will delete (and direct our service providers to delete) your information from our records unless applicable laws do not provide for the deletion of the information in a particular case (for instance, retaining the information is necessary for us or our service provider(s) to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, comply with a legal obligation, make other internal and lawful uses of that information that are compatible with the context in which you provided it).
9. What is my right not to receive discriminatory treatment while exercising my rights?
When you exercise your rights enshrined in applicable laws, you also have the right to non-discrimination. For example, because you exercised your rights under applicable laws, you will not be denied any goods or services, charged with a different price, provided a different quality of goods and services etc.
10. How do I submit a request?
If you would like to exercise your rights described above or have any other concerns relating to your data processing, please submit a request to us via e-mail at [email protected] or our toll-free telephone number (888) 871-7047.
11. Can I use an authorized agent?
Sure. You may use an authorized agent to submit a request to opt out on your behalf if you provide us with the authorized agent written permission to do so. If this is the case, please provide us with a copy of the said permission as instructed under Section 16 of this policy. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
12. Do you engage in automated individual decision-making, including profiling?
No, we do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.
13. Does your website use cookies or similar tracking technologies?
Yes. Cookies are small textual files containing an identifier that is sent by a web server to your web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Our website places the following cookies on your device.
| Cookie category | Cookie name | Cookie purpose | Cookie expiry |
| Necessary | cookies.js cookie-policy |
Determines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon reentry. | During the browsing session 1 year |
| subscribe-popup | Determines whether the visitor has closed subscribe popup | 20 days | |
| rc::a | This cookie is used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of our website. | Persistent | |
| rc::c | This cookie is used to distinguish between humans and bots. | During the browsing session | |
| visitor | Preserves the visitor’s session state across page requests. | 1 year | |
| wc_cart_hash_# | Remembers the items the user has placed in the shopping cart | Persistent | |
| wc_fragments_# | Ensuring shopping cart functionality works properly. | During the browsing session | |
| wp_woocommerce_session_# | The cookie contains information identifying the customer and session expiration time. | 1 day | |
| Statistics | _dc_gtm_UA-# | Used by Google Tag Manager to control the loading of a Google Analytics script tag. | 1 day |
| _ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | |
| _gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | |
| _hjAbsoluteSessionInProgress | This cookie is used to count how many times a website has been visited by different visitors – this is done by assigning the visitor an ID so the visitor does not get registered twice. | 1 day | |
| _hjFirstSeen | This cookie is used to determine if the visitor has visited the website before or if it is a new visitor to the website. | 1 day | |
| _hjIncludedInPageviewSample | Used to detect whether the user navigation and interactions are included in the website’s data analytics | 1 day | |
| _hjIncludedInSessionSample | Registers data on visitors’ website behaviour. This is used for internal analysis and website optimization. | 1 day | |
| _hjRecordingLastActivity | Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes. | During the browsing session | |
| _hjSession_# | Collects statistics on the visitor’s visits to the website, such as the number of visits, average time spent on the website and what pages have been read. | 1 day | |
| _hjSessionUser_# | Collects statistics on the visitor’s visits to the website, such as the number of visits, average time spent on the website and what pages have been read. | 1 year | |
| collect | Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels. | During the browsing session | |
| hjViewportId | Sets a unique ID for the session. This allows the website to obtain data on visitor behavior for statistical purposes. | During the browsing session | |
| mailchimp_landing_site | Used to register how the user entered the website – this function is provided by Mailchimp. | 27 days | |
| Marketing | _fbp | Used by Facebook to deliver a series of advertisement products such as real-time bidding from third-party advertisers. | 3 months |
| _hjRecordingEnabled | This cookie is used to identify the visitor and optimize ad relevance by collecting visitor data from multiple websites – this exchange of visitor data is normally provided by a third-party data center or ad exchange. | During the browsing session | |
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behavior across websites. | During the browsing session | |
| fb_sessiontraffic | Collects information on user behavior on multiple websites. This information is used in order to optimize the relevance of advertisements on the website. | 1 day | |
| IR_gbd | Registers a unique ID that identifies the user’s device during return visits across websites that use the same ad network. The ID is used to allow targeted ads. | During the browsing session | |
| tr | Used by Facebook to deliver a series of advertisement products such as real-time bidding from third-party advertisers. | During the browsing session | |
| 1P_JAR, APISID, HSID, NID, SAPISID, SEARCH_SAMESITE, SID, SIDCC, SSID | These cookies are used by Google to display personalized advertisements on Google sites, based on recent searches and previous interactions. HSID, SSID, APISID and SAPISID cookies enable Google to collect user information for videos hosted by YouTube. | 2 years | |
| Other | IR_16034 | impact.com integration (Purpose not Unknown) | During the browsing session |
| pathway | Re:amaze live chat (Purpose not Unknown) | 1 day | |
| rmz._vd | Re:amaze live chat (Purpose not Unknown) | Persistent | |
| rmz.account | Re:amaze live chat (Purpose not Unknown) | Persistent | |
| rmz.chat.minimized | Re:amaze live chat (Purpose not Unknown) | Persistent | |
| rmz.hideWhoop | Re:amaze live chat (Purpose not provided) | During the browsing session | |
| rmz.messagePrompts.state | Re:amaze live chat (Purpose not provided) | Persistent | |
| rmz.notifications_st | Re:amaze live chat (Purpose not provided) | Persistent | |
| rmz.rmz-live-url | Re:amaze live chat (Purpose not provided) | Persistent | |
| rmz.routeParams | Re:amaze live chat (Purpose not provided) | Persistent | |
| rmz.seenLabel | Re:amaze live chat (Purpose not provided) | During the browsing session | |
| rmz.siteVisitTime | Re:amaze live chat (Purpose not provided) | During the browsing session |
14. How can I manage cookies?
When you visit our website, we ask for your consent for the use of non-essential cookies. However, essential cookies are enabled by default because they are a prerequisite for our website to function.
We respect your preferences concerning cookies, and you can easily manage and disable cookies on our website. You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies, you may be unable to access certain areas or features of our website. You can control the use of functionality cookies, targeting cookies or advertising cookies by adjusting your browser settings. To find out how to manage cookies in your browser, please visit one of the links below:
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Google Chrome: https://support.google.com/chrome/answer/95647
- Opera: https://www.opera.com/help/tutorials/security/privacy
- Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-information-sfri11471/mac
15. Do you process data about minors?
We do not knowingly process the data of minors under 18 years of age. By using the website and/or our services, the user asserts they are not under 18 years of age. If you are under 18 years of age, please do not use our website and/or services and do not submit any data through our websites or services without the parents’ permission. If we become aware that we have inadvertently received information of minors under 18 years of age, we will delete such information from our records.