Effective Date: [10-04-2025]
Last Updated: [07-04-2025]

This Privacy Policy (“Policy“) outlines the principles and procedures by which the operator of this website (“we“, “our“, or “us“) collects, processes, stores, discloses, and otherwise manages personal information about individuals (“you” or “your“) who access, use, or interact with our websites, digital platforms, software applications, services, and any related functions or offline engagement points (collectively, the “Services”).

We recognise the importance of safeguarding personal information and are committed to ensuring compliance with applicable data protection and privacy laws, including those with extraterritorial effect. This Policy is intended to provide comprehensive transparency around our data handling practices and to inform you of your rights in relation to your personal information.

1. DEFINITIONS

1.1 “Personal Information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. This may include, but is not limited to, names, email addresses, account credentials, device identifiers, IP addresses, geolocation data, user-generated content, and any other data linked to an identifiable person.

1.2 “Content” means any data, materials, documents, files, images, recordings, or other forms of information, including metadata, that you upload, submit, transmit, or otherwise provide to or through the Services.

1.3 “Processing” means any operation or set of operations performed on Personal Information, whether by automated or manual means, including but not limited to collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, transmission, dissemination, erasure, or destruction.

1.4 “Third Party” means any person or entity other than you or us, including but not limited to subcontractors, service providers, hosting and analytics providers, professional advisers, regulators, or law enforcement bodies.

2. COLLECTION OF PERSONAL INFORMATION

2.1 We collect Personal Information through various means including, but not limited to:

  • Direct interactions (e.g. account creation, contact forms, file uploads);
  • Automated technologies (e.g. cookies, usage logs, and web analytics);
  • Referrals or integrations with third-party services;
  • Legal, regulatory, or compliance requirements.

2.2 Categories of data collected may include:

  • Identity data (e.g. full name, username);
  • Contact data (e.g. email address, phone number);
  • Technical data (e.g. device ID, browser type, operating system);
  • Content data (e.g. uploaded files and their associated metadata);
  • Communication data (e.g. support queries, feedback, chat logs);
  • Behavioural data (e.g. usage patterns, preferences, clickstream data).

2.3 You are not required to provide Personal Information. However, withholding required information may prevent us from delivering certain Services or fulfilling your requests.

3. PURPOSES FOR PROCESSING PERSONAL INFORMATION

We process Personal Information for purposes which include:

  • Delivering and improving our Services;
  • Performing identity verification, authentication, and security checks;
  • Reviewing and analysing uploaded content;
  • Customising user experiences and preferences;
  • Facilitating the development and training of machine learning and artificial intelligence systems;
  • Conducting internal research, diagnostics, and service optimisation;
  • Complying with legal and regulatory obligations;
  • Managing records and audits;
  • Resolving disputes and enforcing our legal rights;
  • Preventing, detecting, and responding to fraud, abuse, or technical issues.

4. LEGAL GROUNDS FOR PROCESSING

We rely on one or more of the following lawful bases to process Personal Information:

  • Your informed and voluntary consent (explicit or implied);
  • Fulfilment of a contractual obligation or to take steps in connection with a contract;
  • Compliance with a legal duty or regulatory requirement;
  • Protection of vital interests;
  • Pursuit of legitimate interests, provided such interests are not overridden by your rights and interests.

5. USE AND LICENSING OF UPLOADED CONTENT

5.1 You retain ownership of any original Content submitted through the Services.

5.2 By uploading or submitting Content, you:

  • Confirm that you have the legal right to do so and that the Content does not infringe any third-party rights;
  • Grant us a non-exclusive, royalty-free, worldwide, perpetual, and irrevocable licence to use, reproduce, adapt, publish, display, analyse, and store the Content for the purpose of delivering the Services and for lawful operational and commercial purposes;
  • Acknowledge and agree that anonymised, de-identified, or aggregated versions of your Content may be used to train, improve, or validate artificial intelligence models, both internally and in collaboration with vetted external partners.

5.3 We reserve the right to assert intellectual property over any derivative models or datasets generated from de-identified or transformed versions of your Content.

6. DISCLOSURE AND THIRD-PARTY ACCESS

6.1 We may share Personal Information with:

  • Cloud service providers, infrastructure partners, and data processors;
  • Advisors and consultants (legal, financial, technical);
  • Law enforcement agencies, regulators, or courts, as required by applicable law;
  • Third parties involved in corporate transactions or restructuring;
  • Any trusted third parties, including those with whom we have a contractual relationship or who have provided appropriate assurances regarding their handling of personal data, and who assist in supporting, enhancing, or delivering our Services or business operations.

6.2 All such disclosures are subject to legally binding obligations of confidentiality and data protection. We do not sell Personal Information under any circumstances.

7. INTERNATIONAL DATA TRANSFERS

Where we transfer Personal Information across borders, we take reasonable steps to ensure that the recipient jurisdiction provides an adequate level of data protection. This may include the use of contractual clauses, data processing agreements, or other legally recognised mechanisms.

8. DATA SECURITY AND SAFEGUARDS

We implement appropriate administrative, technical, and physical measures to safeguard Personal Information against loss, misuse, or unauthorised access. These measures include:

  • Encryption of data in transit and at rest;
  • Secure access controls and authentication;
  • Regular monitoring and security assessments;
  • Restricted access based on role and necessity.

Despite our best efforts, no system can be guaranteed secure, and you acknowledge that you provide data at your own risk.

9. DATA RETENTION AND DELETION

We retain Personal Information only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable law, industry standards, or contractual obligations. Where information is no longer required, we will take reasonable steps to de-identify or securely delete it.

10. INDIVIDUAL RIGHTS AND CHOICES

Depending on your jurisdiction, you may have legal rights that include:

  • Right of access to Personal Information held about you;
  • Right to rectification or correction of inaccurate data;
  • Right to erasure or deletion, where applicable;
  • Right to restrict or object to certain processing activities;
  • Right to data portability;
  • Right to withdraw consent where processing is based on consent.

To exercise any of these rights, please contact us at: info@thehonest.club. We may require proof of identity before processing requests.

11. CHANGES TO THIS POLICY

We may update this Policy periodically. Changes will be posted on this page with an updated “Last Updated” date. Where material changes are made, we will notify users via email or in-Service notification where reasonably practicable.

12. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact: email: info@thehonest.club

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