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PRIVACY POLICY

Last Updated: 6/6/2025

1. Introduction

Edington Ltd ("Hidden Gems," "we," "us," or "our") operates this Privacy Policy ("Policy") to clarify how we handle your information when you use our website, software, and related services (collectively, "Services"). "You" refers to individual users or entities accessing our Services. If using our Services on behalf of an organization, you confirm authority to bind that entity to this Policy.

By using our Services, you consent to the practices described herein. If you disagree, discontinue use immediately.

2. User Eligibility

Our Services are intended for users who:

  • Are at least 18 years old in the UK, or the age of majority in their jurisdiction; or
  • Have parental/guardian consent if underage (parents assume responsibility for minors' activities).

3. Scope and Agreement

This Policy and our Terms of Service govern your use of the Services, including dispute resolution and liability limitations.

4. Information We Collect

We gather four categories of data:

4.1 Directly Provided Information

  • Contact Details: Name, email, phone, address, username, password.
  • Submissions: Data from forms, surveys, or correspondence (e.g., support inquiries).
  • Transactions: Payment details processed by third parties (e.g., Stripe). We do not store card data.

4.2 Automatically Collected Data

  • Device Data: IP address, device ID, browser type, operating system.
  • Usage Patterns: Content interactions, session duration, features used.
  • Tracking Technologies: Cookies, pixels, and similar tools (see Section 11).

4.3 Third-Party Sources

We may supplement data with information from public databases, marketing partners, or social networks (used per this Policy).

5. How We Use Your Information

5.1 Service Delivery

  • Provide and personalize Services.
  • Process transactions and send service updates.
  • Respond to inquiries and offer support.

5.2 Operational Purposes

  • Verify identities, prevent fraud, and secure systems.
  • Analyze usage trends to enhance user experience.
  • Enforce agreements and comply with legal obligations.

5.3 Marketing

  • Send promotional offers (opt-out anytime).
  • Conduct research to develop new features.

6. Information Sharing

We disclose data only under these circumstances:

  • Service Providers: Partners assisting with analytics, hosting, or payment processing (bound by confidentiality).
  • Legal Compliance: To meet legal requests or protect rights/safety.
  • Business Transfers: During mergers, sales, or asset transfers.
  • With Consent: For specific purposes you approve.

7. Your Privacy Rights

7.1 Control Options

  • Cookies: Adjust browser settings to block cookies (may impact functionality).
  • Marketing Emails: Unsubscribe via email footer or by contacting us.
  • Do Not Track: We currently don't respond to DNT signals.

7.2 Access & Corrections

Request access, correction, deletion, or data portability by emailing support@thecoolsoftwarecompany.com. We'll verify your identity before processing and respond within one month as required by UK GDPR.

7.3 UK GDPR Rights

Under UK GDPR, you have additional rights including the right to object to processing, data portability, and to lodge complaints with the Information Commissioner's Office (ICO). Submit requests here.

8. Security Measures

We implement firewalls, encryption, and access controls to protect your data. However, no system is 100% secure—report concerns promptly.

9. Children's Privacy

Our Services are not designed for users under 18. We delete underage data upon discovery in compliance with UK GDPR requirements for children's data protection. Contact us if a minor has shared data without consent.

10. International Data Transfers

Data may be transferred globally, including outside the UK and EU. We safeguard transfers using appropriate measures such as Standard Contractual Clauses and adequacy decisions per UK GDPR requirements.

11. Cookies & Tracking

We use cookies for functionality, analytics, and ads. Third parties (e.g., Google Analytics) may also track usage. Adjust preferences via browser settings.

12. Policy Updates

We'll notify you of material changes via email or Service notices. Continued use implies acceptance.

13. Third-Party Links

Our Services may link to external sites. We don't control their practices—review their policies separately.

14. Contact Us

Questions? Reach our Data Protection Officer at:

Edington Ltd (operating as Hidden Gems)

Registered in England and Wales

Email: support@thecoolsoftwarecompany.com

ICO Registration: Available upon request