Privacy Policy


Effective December 15, 2017

PalmistryHD (PalmistryHD, “we,” and “us”) respects the privacy of its users (“you”) and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our application or services or transacting business with us. By using our website or the PalmistryHD application (our “Service”), you are accepting the practices described in this Privacy Policy.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on
how to contact us.

Information we collect about you

In General. We may collect information that can identify you such as your name and email address (“personal information”) and other information that does not identify you. We may collect this information through a website or a mobile application. By using the Service, you are authorizing us to gather, parse and retain data related to the provision of the Service. When you provide personal information through our Service, the information may be sent to servers located in Canada and countries around the world.

  • Information you provide. In order to register as a user with PalmistryHD, you may be asked to sign in by creating an account by using your e-mail. In addition, we may collect and store any personal information you provide while using our Service or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos, a personal description and information about your gender, personality traits and personality profile. If you chat with other PalmistryHD users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.

Use of technologies to collect information.

We use various technologies to collect information from your device and about your activities on our Service.

  • Information collected automatically. We automatically collect information from your browser or device when you visit our
    Service. This information could include your IP address, device ID and type, your browser type and language, the operating
    system used by your device, access times, your mobile device’s geographic location while our application is actively
    running, and the referring website address.
  • Cookies and Use of Cookie Data. When you visit our Service, we may assign your device one or more cookies to facilitate access
    to our Service and to personalize your experience. Through the use of a cookie, we also may automatically collect information
    about your activity on our Service, such as the pages you visit, the time and date of your visits and the links you
    click. If we advertise, we (or third parties) may use certain data collected on our Service to show you our advertisements
    on other sites or applications.
  • Pixel tags. We embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible
    graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel
    tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number
    of ads displayed and their performance (such as how many people clicked on an ad).
  • Mobile Device IDs: If you’re using our app, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer),
    or Advertising IDs (for iOS 6 and later), instead of cookies, to recognize you. We do this to store your preferences
    and track your use of our app. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in “Settings”
    on your device. Ad companies also use device IDs or Advertising IDs to track your use of the app, track the number
    of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device
    IDs to track information about app usage.
  • Information collected by third-parties for advertising purposes. We may allow service providers, advertising companies and
    ad networks, and other third parties to display advertisements on our Service. These companies may use tracking technologies,
    such as cookies or web beacons, to collect information about users who view or interact with their advertisements.
    We do not provide any non-anonymized personal information to third parties for advertising purposes. Some of these
    third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative,
    which offers a single location to opt out of ad targeting from member companies ( Opting
    out will not decrease the number of advertisements you see.

How we use the information we collect

In General. We may use information that we collect about you to:

  • deliver and improve our products and services, and manage our business;
  • manage your account and provide you with customer support;
  • perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
  • communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of
    interest to you either from us or other third parties;
  • develop, display, and track content and advertising tailored to your interests on our Service and other sites, including
    providing our advertisements to you when you visit other sites, our website or mobile application analytics;
  • verify your eligibility and deliver prizes in connection with contests and sweepstakes;
  • enforce or exercise any rights in our Terms of Use; and
  • perform functions or services as otherwise described to you at the time of collection.

In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on
our behalf who will be obligated to use your personal information only to perform services for us. Also, if you access
our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform
to the extent permitted by your agreement with it and its privacy settings.

With whom we share your information

Personal information. We do not share your personal information with others except as indicated in this Privacy Policy
or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information (name, email, phone and ip address) with:

  • Service providers: We may share information, including personal and financial information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These
    service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
  • Other trusted advertisers, third party marketers and our affiliated entities for their online and/or offline marketing programs. As a result, you may receive information on additional products, services and offers that may be of interest to you via email, social media or messenger.
  • Other Situations. We may disclose your information, including personal information:
    • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement
      or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise
      required by law. In such cases, we may raise or waive any legal objection or right available to us.
    • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding
      illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of
      our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement;
      or to enforce our Terms of Use or other agreements or policies.
    • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation,
      or asset sale, or in the unlikely event of bankruptcy.

Aggregated and/or non-personal information.

We may use and share non-personal information we collect under any of the above circumstances. We may also share it with
other Online Commerce Group companies and third parties to develop and deliver targeted advertising on our Service and
on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal
information we collect with additional non-personal information collected from other sources. We also may share aggregated,
non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors,
advertisers and investors, for the purpose of conducting general business analysis or other business purposes. For example,
we may engage a data provider who may collect web log data from you (including IP address and information about your
browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized
ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted
to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form.
To opt-out of cookies that may be set by third party data or advertising partners, please go to

Third Party Websites

There are a number of places on our Service where you may click on a link to access other websites that do not operate
under this Privacy Policy. For example, if you click on an advertisement on our Service, you may be taken to a website
that we do not control. These third- party websites may independently solicit and collect information, including personal
information, from you and, in some instances, provide us with information about your activities on those websites. We
recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy”
link typically located at the bottom of the webpage you are visiting.

How you can access your information

If you have a PalmistryHD account, you have the ability to review and update your personal information within the Service
by opening your account and going to settings. More information about how to contact us is provided below. You also may
close your account at any time by visiting the “Settings” page for your account. If you close your account, we will retain
certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent
fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Service or our users,
or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third
parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

Your choices about collection and use of your information

  • You can choose not to provide us with certain information, but that may result in you being unable to use certain features
    of our Service because such information may be required in order for you to register as user; purchase products or
    services; ask a question; or initiate other transactions.
  • Our Service may also deliver notifications to your phone or mobile device. You can disable these notifications by going into
    “App Settings” on the app or by changing the settings on your mobile device.

How we protect your personal information

We take security measures to help safeguard your personal information from unauthorized access and disclosure. However,
no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise,
and you should not expect, that your personal information, chats, or other communications will always remain secure.
Users should also take care with how they handle and disclose their personal information and should avoid sending personal
information through insecure email.

Information you provide about yourself while using our Service

We provide areas on our Service where you can post information about yourself and others. Such postings are governed by
our Terms of Use.

Your data

You have the right to ask us to delete your data. You can exercise the right at any time by contacting us: [email protected].

Children’s privacy

Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above.
We do not knowingly collect, maintain, or use personal information from children under the age of 18.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information
relating to users of the website.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last
updated” date at the top of this Privacy Policy. We recommend that you check our Service from time to time to inform
yourself of any changes in this Privacy Policy or any of our other policies.

How to contact us

If you have any questions about this Privacy Policy, please contact us by email as follows:

Privacy Officer
Online Commerce Group BV.
[email protected]