PRIVACY POLICY
This privacy policy (“Privacy Policy”) tells you how we use your information when you use our Photographer booking Platform mobile application(s) (the “Application”) made available by Weecent Distribution Inc. (“we,” “us” or “our”) on behalf of Hotaru Bookings.
1. Who We Are
We are Hotaru Bookings (“we”, “us” or “our”), and through our Platform, we link you to the Photographers (“Photographers”) for you to book a Photoshoot (“Photoshoot”) for a designated venue (hereinafter collectively referred to as “Services”). When you place a booking for Services from our Photographers, Hotaru Bookings acts as an agent on behalf of that Photographer to facilitate, process, and conclude the Photoshoot and subsequently for either us or the Photographer. Photographers may be owned and operated by third-party vendors, our affiliate companies, or us.
As regards the processing activities conducted on our platform, we will be the data controller responsible for what happens with your personal data. “Data controller” is a legal term and simply means that we are the party determining how your personal data is processed, for what purposes this is done, and by what means. While we are required by law to provide you with all of the following information, we do so also out of the belief that a partnership should always be honest.
If you have any questions about data protection at Hotaru Bookings, you can contact our data protection officer at any time by sending an email to hotarubookings@gmail.com.
We are also a member of the large and fascinating family of the Weecent Distribution Inc. Group. As a family, we make certain decisions together. Both our parent company, Weecent Distribution Inc., 191 Roosevelt Ave, San Francisco, Del Monte, Quezon City, Philippines, and Hotaru Bookings Philippines, to some extent, jointly decide which means we will use to process your personal data and which purposes we consider to be appropriate. Legally, this means that Hotaru Bookings Philippines and Weecent Distribution Inc. are also jointly responsible for these joint data processing activities, and you are free to assert your rights against both parties in relation to the processing activities listed in this Privacy Policy.
While visiting our platform, registering, or placing orders, you agree to this privacy policy. This privacy policy applies to all personal data obtained by us through your use of our platform. It does not apply to any websites controlled by third parties not affiliated with us that our platform may link to (“Third Party Sites”). The relevant privacy policies set out in the respective Third Party Sites shall apply in those cases.
2. Privacy is Your Right and the Choice is Yours
As a customer, you have the choice regarding which information you would like to share with us. Please be aware, however, that when signing up for our platform, you are required to accept our terms of use. Legally speaking, this means you will enter into a contract with us under which you are entitled to use the platform, in accordance with the terms of use.
Of course, we need some information from you to be able to perform our obligations under this contract. However, it is entirely up to you to choose whether you would like to provide such information or would rather not use our platform.
You can take the following steps to control and manage how much personal data you share with us:
- Cookies & Web-Tracking: You can set your device or web browser to decline cookies and other web-tracking technologies (which is also possible through our consent manager). If you deactivate web-tracking, you will no longer see any personalized content, offers, or ads.
You may also withdraw your consent for the processing of your personal data for certain purposes (e.g., marketing) by submitting your request via email to hotarubookings@gmail.com.
3. Your Legal Rights
- Right to Access:
You have the right to be informed which data we store about you and how we process this data. - Right to Rectification:
If you notice that stored data is incorrect, you can always ask us to correct it. - Right to Erasure:
You can ask us at any time to delete the data we have stored about you. - Right to Data Portability:
You can ask us to transmit the data stored about you in a machine-readable format to you or to another responsible person. - Right to Object:
You also have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is processed on the basis of Sec. 34 (b) DPA IRR; this also applies to any profiling for the purposes of Sec. 34 (b) DPA IRR. If you object, we will no longer process your personal data in the future unless we can prove compelling grounds for the processing that outweigh your interests, rights, and freedoms. - Right to Withdraw Your Consent to the Processing of Your Personal Data:
You can withdraw your consent to our collection, use, and disclosure of your personal data at any time for any or all of the purposes. Upon receiving your withdrawal request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences that may affect your rights and liabilities to us. Please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you, and we shall, in such circumstances, notify you before completing the processing of your request.
To exercise your rights, you may send in your request via email to hotarubookings@gmail.com at any time, and we will process such requests in accordance with this Privacy Policy and our obligations under applicable laws.
We will respond to your request as soon as practicable, in any case within thirty (30) working days upon receiving your request and/or the necessary supporting or additional documentation. We will also inform you within the timeframe if we are unable to adhere to your request (with reasons) or require additional time to effect the request.
We may charge you a reasonable fee for the handling and processing of your requests to access your personal data, and will inform you of the amount charged in advance. You may also delete your account through your user profile on our platform.
- An overview of the personal data we process
In this section you can find general information about the categories of personal data we process about you. For your understanding, personal data is information that directly identifies you (such as your name or photo picture) or enables us to indirectly identify you (for example, on the basis of a user ID linked with the personal information in your profile). You will find more detailed information on our processing activities below, in the next section. But our data processing activities on the platform can be summarized by reference the main categories of personal data:
a. Profile data (master data)
This includes your name, email address, password, telephone number, addresses, interests, age.
Why do weprocess this category?
This data is your master data, which we absolutely need for our services. Without an email address/telephone number and a password, you cannot create a profile. Together with your name, this is your master data. We need your age to ensure that you fit the age requirements.
c. Order history data
This includes your order history, selected photographer, invoices, order ID, comments on orders, information on payment method, successful orders and canceled orders
Why do we process this category?
Each time you place an order, this information will be added to your profile. You can view all this information in your profile at any time. We will use this information to improve our services and optimize the platform for your interests.
d. Location data
This includes your address, postcode, city, country and your device’s longitude and latitude.
Why do we process this category?
We need this data to be able to provide you with the best options based on your provided address for services that utilize regional proximity.
e. Device information and access data
This includes your device ID, device identification, operating system and corresponding
version, time of access, configuration settings, and your IP address.
Why do we process this category?
Each time you access our platform, this information is stored by us for technical reasons. We also use parts of this information to detect suspicious behaviour at an early
stage and to protect our platform.
f. Customer care data
This includes your name, telephone number, email address, and your ID from any social media (if applicable).
Why do we process this category?
If you contact us, we collect this data because we need to know who we are talking to and what we have been talking about so that we can help you with your reason for contacting us. This also applies if you leave comments on social media on our fan pages. We do not combine this data with your profile data on our platform, but we can still identify you by your social media ID.
g. Marketing contact and communications data
This includes your name, email address, telephone number, and device ID.
Why do we process this category? This category of personal data is also used by us to contact you, for example, if a product cannot be delivered and we want to offer you an alternative instead.
h. Payment data
This includes your payment method, and encrypted, pseudonymized credit card
information
Why do we process this category?
We need this information to initiate your payments and assign them to the bookings you have placed. We also need this data to store your payment information for future orders (if you give us your consent to do so).
- Who we share your personal data with
We never give your data to unauthorized third parties. However, in order to run our business efficiently, we obtain the services of selected service providers and give them limited and strictly monitored access to some of our data, in order to fulfil the Purposes. Before we forward personal data to these partner companies for processing on our behalf, each individual company undergoes an audit. All data recipients must meet the legal data protection requirements and undertake to protect your personal data to a comparable standard as required under the DPA, the DPA IRR and other relevant data protection laws.
a. Third parties
In addition to data processors, we also work with third parties, to whom we also transmit your personal data, but who are not bound by our instructions. These are, for example, our consultants, lawyers or tax consultants who receive your data from us on the basis of a contract and process your personal data for legal reasons or to protect our own interests. We do not sell or rent your personal data to third parties under any circumstances. This will never take place without your explicit, informed consent.
b. Prosecuting authorities, courts and other public bodies
Unfortunately, it can happen that a few of our customers and service providers do not behave fairly and want to harm us. In these cases, we are not only obliged to hand over personal data to public authorities due to legal obligations, it is also in our interest to prevent damage and to enforce our claims and to reject unjustified claims. We may also share your personal data with law enforcement agencies, government and regulatory bodies to meet applicable legal or regulatory obligations.
- How long we store your data
We generally delete your data after the Purposes have been fulfilled. The exact deletion rules are defined in our global policies and supporting local retention schedules. Different deletion rules apply depending on the purpose of the processing. Within our deletion concepts we have defined various data classes and assigned regular maximum retention and deletion periods to them. When the retention period has expired, the stored data will be deleted accordingly. If you have not used your user account on our platform for a period of more than three years, we will delete your account to make sure to comply with the principle of storage limitation. Before this happens, you will receive a separate notification from us to the email address registered for your user account. Furthermore, we will continue to store your data if we have a right to do so in accordance with applicable local laws. This applies in particular if we need your personal data for the
establishment, exercise or defense of legal claims. - Right of modification
We reserve the right to change this privacy notice to ensure compliance with relevant legal and statutory provisions, including the DPA and the DPA IRR. We will inform you of any significant changes, such as changes of purpose or new purposes of processing. The updated version will be posted on our website and is accessible through the App. It is your responsibility to review the Privacy Policy regularly. Your continued use of the app, website or our services, purchase products from us or through the app or continuing to communicate or engage with Hotaru Bookings Philippines following the modifications, updates or amendments to this Policy, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments